ML18003B353
| ML18003B353 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/06/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML18003B352 | List: |
| References | |
| NUDOCS 8606200177 | |
| Download: ML18003B353 (4) | |
Text
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 June 6, 1986 Docket No. 50-400 Mr. E. E. Utley, Senior Executive Vice President Power Supply and Engineering and Construction Carolina Power and Light Company Post Office Box 1551
- Raleigh, North Carolina 27602
Dear Mr. Utley:
Subject:
Shearon Harris Backfit Considerations In your submittals dated February 6, 1986, Serial Nos. NLS-86-054 and NLS-86-055, you stated that you consider two design changes to be plant specific backfits in accordance with 10 CFR 50.109.
Your staff most recently discussed these issues in a meeting with NRR personnel on May 2, 1986.
We have considered your written positions and the subsequent Technical discussion and provide our comments below.
Letter dated February 6, 1986, Serial No. NLS-86-054 states that the proposed Technical Specification in Section 3.7.1.3 of the "Proof and Review" Technical Specification for Shearon Harris lJnit 1, forwarded to you by letter dated January 30, 1986, would limit the operation of the eight-inch containment purge and exhaust valves to less than one thousand hours per calendar year.
You state that to meet the one thousand hour proposed limit would require design modifi-cations and revisions to operating procedures and requested that the NRC staff review this.reqUirement as a plant specific backfit in accordance with 10 CFR 50.109; ll In regard to the backfit aspects of the issue, Carolina Power and Light Company tendered an application for an Operating License for Shearon Harris Unit 1 by letter dated June 26, 1980.
Docketing occurred on December 22, 1981.
The staff has been requiring restrictions on containment purging during operation as of 1975.
The second paragraph on page 6.2.4-11 of Branch Technical Position CSB 6-4, Revi'sion 1, "Containment Purging During Normal Plant Operations" dated 1975, states that plant designs should not rely on the use of containment purge on a routine bases.
Furthermore, page 6.2.4-12 of the above cited Branch Technical Position states "Purge system designs that are acceptable for use on non-routine basis during normal plant operation can be achieved by providing additional purge and vent lines."
Revision 4 to the "Westinghouse Standard Technical Specifications for Pressurized Water Reactors" dated September 28, 1981, reaffirmed the staff's use of a limit on containment purging during normal operation.
Moreover, recently licensed plants such as Catawba 2, River Bend, and Diablo Canyon, Unit 2 have purging limits of 2000
- hours, 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> and 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per calendar year, respectively.
8606200177 860609 PDR ADOCK 05000400 A
Mr.
E.
E. Utley "2"
June 6, 1986 Implementation of this requirement is widespread and well known.
The staff has identified its concern on containment purging as far back as 1975 which predates your docketing date of December 22, 1981 and thus would not be characterized as a backfit in accordance with 10 CFR 50. 109.
Therefore, we deny your request for backfit status.
- However, we believe there is technical merit to the concern that you raised on the containment purging limit and that continuing our discussions during the "Proof and Review" phase of the Shearon Harris Technical Specifications review is warranted.
In regard to the "backfit" aspects of the second
- issue, your letter of February 6, 1986, Serial No. NLS-86-055, responded to the staff letter of January 21, 1986, which provided our evaluation of your conformance with Regulatory Guide 1.97, Revision 2 dated December 1980.
We stated in that letter that we would
- require, by first refueling outage, that either the accumulator pressure or level instrumentation be environmentally qualified.
Your letter of February 6, 1986 states that you consider this design change to be a plant specific backfit as discussed in 10 CFR 50. 109.
Regulatory Guide 1.97, Revision 2 was issued in December 1980 which is approxi-mately one year prior to the docketing of your operating license application i.e.,
December 22, 1981.
Regulatory Guide 1.97, Revision 2 is applicable to all nuclear power plants and is cited as a guide in 10 CFR 50.49.
We do not believe that this requirement is a backfit in accordance with 10 CFR 50. 109.
Therefore, your request is denied. 'owever, in our May 2, 1986 meeting, your staff discussed the technical basis as to why neither the accumulator level or pressure instrumentation were required during the post-accident phase.
Your rationale was that the accumulators are a passive system and the level and pressure variables are monitored as required by the Technical Specifications during normal operation to maintain the accumulators in an "as-ready" condition.
Safety grade isolation valve position indication is provided, power to the valves is locked out at the circuit breakers and no immediate operator action is required until power is restored to the isolation valve.
Furthermore, the emergency response facilities information system computer would record the accumulator pressure and level variables during and following an accident thus providing data which would indicate whether or not the accumulators performed their design function.
As you are aware, you have the option to formally appeal the technical basis for the staff's position on this matter.
Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation cc:
See next page
~ Mr. E.
E. Utley Carolina Power E Light Company CC:
George F. Trowbridge, Esq.
Shaw, Pittman, Potts 5 Trowbridge 1800 M Street, NW Washington, DC 20036 Richard E. Jones, Esq.
Associate General Counsel Carolina Power 8 Light Company 411 Fayetteville Street Mall Raleigh, North Carolina 27602 Jo Anne Sanford, Esq.
Special Deputy Attorney General State of North Carolina Post Office Box 629
- Raleiah, North Carolina 27602 Thomas S. Erwin, Esq.
115 W. Morgan Street Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory Commission Route 1,
Box 315B New Hill, North Carolina 27562 Charles D. Barham, Jr.,
Esq.
Vice'President 5 Senior Counsel Carolina Power 5 Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Mr. John Runkle, Executive Coordinator Conservation Council of North Carolina 307 Granville Road
'hapel Hill, North Carolina 27514 Mr. Wells Eddleman 806 Parker Street Durham, North Carolina 27701 Mr. George Jackson, Secretary Environmental Law Project School of Law, 064-A University of North Carolina Chapel Hill, North Carolina 27514 Shearon Harris Mr. Travis Payne, Esq.
723 W. Johnson Street Post Office Box 12643 Raleigh, North Carolina 27605 Mr. Daniel F.
Read CHANGE Post Office Box 2151 Raleigh, North Carolina 27602 Bradley W. Jones, Esq.
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street Atlanta, Georgia 30303 Richard D. Wilson, M.D.
725 Hunter Street Apex, North Carolina 27502 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street Suite 2900 Atlanta, Georgia 30303 Mr. Robert P. Gruber Executive Director Public Staff -
NCUC Post Office Box 991
- Raleigh, North Carolina 27602 Dr. Linda Little Governor's Waste Management Board 513 Albermarle Building 325 North Salisbury Street
- Raleigh, North Carolina 27611
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