ML23011A015

NRR E-mail Capture - Request for Additional Information to Duke'S Request for Robinson to Add Feedwater Isolation Function to TS 3.3.2 and Remove Obsolete Content from TSs 2.1.1.1 and 5.6.5.b

ML23011A015
Person / Time
Site:	Robinson
Issue date:	01/11/2023
From:	Luke Haeg Plant Licensing Branch II
To:	Duc J Duke Energy Progress
References
L-2022-LLA-0137
Download: ML23011A015 (5)

Text

From: Luke Haeg Sent: Wednesday, January 11, 2023 8:09 AM To: Duc, Joshua Brian Cc: Ryan.Treadway@duke-energy.com; David Wrona

Subject:

Request for Additional Information to Duke's Request for Robinson to Add Feedwater Isolation Function to TS 3.3.2 and Remove Obsolete Content from TSs 2.1.1.1 and 5.6.5.b (EPID L-2022-LLA-0137)

Attachments: Final RAI L-2022-LLA-0137.pdf

Dear Mr. Duc,

By letter dated September 21, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML222264A419), Duke Energy Progress, LLC (Duke Energy, the licensee), submitted a license amendment request (LAR) to amend the Technical Specifications (TSs) for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson). The proposed amendment would add a Feedwater Isolation on High-High Steam Generator Level function to Table 3.3.2-1 of Technical Specification (TS) 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, and remove obsolete content from TSs 2.1.1.1, Reactor Core SLs [Safety Limits], and 5.6.5.b, Core Operating Limits Report (COLR).

The U.S. Nuclear Regulatory Commission staff is reviewing your submittal and determined that additional information is required in order to complete the review.

A request for additional information (RAI) is attached. The draft RAI was sent to you ensure that it was understandable, the regulatory basis for the question was clear, and to determine whether the information was previously docketed.

Based on a discussion with Mr. Duc, a response to the attached RAI is requested within 30 days from the date of this email.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-0272 or Lucas.Haeg@nrc.gov.

Luke Haeg Project Manager NRR/DORL/LPL2-2 U.S. Nuclear Regulatory Commission 301-415-0272

Hearing Identifier: NRR_DRMA Email Number: 1904 Mail Envelope Properties (DM8PR09MB6407E95E7D276B6345299F2D98FC9)

Subject:

Request for Additional Information to Duke's Request for Robinson to Add Feedwater Isolation Function to TS 3.3.2 and Remove Obsolete Content from TSs 2.1.1.1 and 5.6.5.b (EPID L-2022-LLA-0137)

Sent Date: 1/11/2023 8:08:54 AM Received Date: 1/11/2023 8:08:00 AM From: Luke Haeg Created By: Lucas.Haeg@nrc.gov Recipients:

"Ryan.Treadway@duke-energy.com" <Ryan.Treadway@duke-energy.com>

Tracking Status: None "David Wrona" <David.Wrona@nrc.gov>

Tracking Status: None "Duc, Joshua Brian" <Joshua.Duc@duke-energy.com>

Tracking Status: None Post Office: DM8PR09MB6407.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1712 1/11/2023 8:08:00 AM Final RAI L-2022-LLA-0137.pdf 91009 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT TO ADD FEEDWATER ISOLATION ON HIGH-HIGH STEAM GENERATOR LEVEL FUNCTION TO TECHNICAL SPECIFICATION (TS) 3.3.2, AND REMOVE OBSOLETE CONTENT FROM TS 2.1.1.1 AND 5.6.5.b DUKE ENERGY PROGRESS, LLC H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 EPID L-2022-LLA-0137 INTRODUCTION By letter dated September 21, 2022, (Agency wide Document Access Management System (ADAMS) Accession No. ML222264A419), Duke Energy Progress, LLC (Duke Energy, the licensee), requested a license amendment request (LAR) for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson). The proposed amendment would add a Feedwater Isolation on High-High Steam Generator Level function to Table 3.3.2-1 of Technical Specification (TS) 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, and remove obsolete content from TSs 2.1.1.1, Reactor Core SLs [Safety Limits], and 5.6.5.b, Core Operating Limits Report (COLR).

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by the licensee. The staff finds that the following additional information is required to complete the review of the LAR.

REGULATORY BASIS Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical Specifications, requires, in part, that the TS shall be included by applicants for a license authorizing operation of a production or utilization facility. 10 CFR 50.36(c) requires, in part, that Technical Specifications include items in the following categories: (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation (3) Surveillance requirements [SRs], (4) Design features, and (5) Administrative controls.

10 CFR 50 Appendix A, General Design Criteria (GDC) 13, Instrumentation and control, states in part, that Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic

Testing and Calibration of Instrument Channels, dated August 24, 2006 (ADAMS Accession No. ML051810077), discusses issues that could occur during testing of limiting safety system settings (LSSSs) and could therefore have an adverse effect on equipment operability. The RIS also represents an approach that is acceptable to the NRC staff for addressing As-Found and As-Left Tolerance Limits for use in licensing actions.

ISSUE Section 3.0 of the LAR stated, in part:

Modules in the high-high SG level setpoint loop considered in the calculation of TLU [total loop uncertainty] consist of a transmitter and comparator. The negative TLU associated with this setpoint is -16.73% span, which considers effects of reference accuracy, calibration tolerance, drift, measurement and test equipment (M&TE) effect, static pressure effect, temperature effect, power supply effect, seismic effect, process measurement effect, and analyzed drift bias. The random component of this loop is +/- 2.49% span and the bias component is -14.24%

span.

the transmitter/sensor is not included in tolerance calculations for this allowable value (AV) because testing consists of a simulated signal injected in place of the field instrument signal. Therefore, the Group As-Found Tolerance (GAFT) used to calculate the AV consists of only the As-Found Tolerance (AFT) of the comparator. This value is 1.16% span, which includes effects of calibration tolerance, drift, and M&TE uncertainties combined using the SRSS [Square-Root-Sum-of-the-Squares] method.

The NRC staff determined that the LAR did not provide enough detail on how the TLU and AFT were calculated.

INFORMATION REQUESTED

1. Provide summary of calculations and relevant supporting information for the following:

a. The calculated TLU (-16.73% of span) of the transmitter and comparator. The summary calculations should include the effects of reference accuracy, calibration tolerance, drift, M&TE effect, static pressure effect, temperature effect, power supply effect, seismic effect, process measurement effect, and analyzed drift bias.

Supporting information should be provided for the values used in the calculations of the random component of this loop (+/-2.49% span) and the bias component (-14.24%

span) with any necessary justification.

b. The calculated AFT (1.16% of span) of the comparator. The summary calculations should address the effects of calibration tolerance, drift, and M&TE uncertainties.

Supporting information should be provided for the values used in the calculation of AFT with any necessary justification.

2. Provide the full catalog/part number and vendor performance specification datasheet of the transmitter and comparator, which provides the performance specifications including accuracy, drift, associated drift interval, and any other relevant inputs to the TLU and AFT

calculations. If any of these values are not provided in the datasheet, provide a justification for the use of these values in the TLU and AFT calculations.

This information is necessary for the staff to confirm that the calculate values for the guidance listed above are being met for the selection and periodic surveillance of the setpoint, and to understand how the vendor performance specifications were used to establish the as-found, as-left, and AV to address the performance monitoring criteria within RIS 2006-17.

Alternatively, the full setpoint uncertainty calculation may be provided for convenience but is not necessary.

Note: The summary of calculations of TLU and AFT could be similar to the example in Section 6, Determine uncertainty equations, of Reference 15 of the LAR (ISA-RP67.04.02).