ML18003B354
| ML18003B354 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/06/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8606200326 | |
| Download: ML18003B354 (14) | |
Text
)immune 6, 1986 Docket No. 50-400 Mr. E. E. Utley, Senior Executive Yice President Power Supply and Engineering and Construction Carolina Power and Light Company Post Office Box 1551 Raleigh, North Carolina 27602 DISTRIBUTION B.
B 111 NRC PDR I. Lee Local PDR ACRS (10)
PAD82 RDG Tech Branch T. Novak Gray File H. Denton/D. Eisenhut C. Barth, OELD E. Rossi E. Jodan F.
Rosa B. Grimes J. Milhoan J. Partlow
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'ecently 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 Unit 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'er 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.
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, Revision 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.
8606200326 860606 PDR ADOCK 05000400 A
L
'I I
Mr.
E.
E. Utley 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.
However, 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.
cc:
See next page "See previous concurrence "JrFgkaPsjfne~ sy H. 8. Dentnn Harold R.
Denton, Director Office of Nuclear Reactor Regulation PM:PAD¹2 BBuckley:hc" 3/05/86 AD:PWRA ERossi" 3/05/86 OELD CBarth" 3/06/86 D:PAD¹2 AD:PWRA LRubenstein~
TNovak~
3/07/86 5/20/86
- N DE enhut D
HDegon P frlSS
l I
h L
~
\\ f, I
~A
~ )f 4
Mr.
E.
E. Utley 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 concer that you raised on the containment purging limit and that continuing our dis ssions during the "Proof and Review" phase of the Shearon Harris Technical pecifications review is warranted.
In regard to the "backfit" aspects of the second issu
, your letter of February 6, 1986, Serial No. NLS-86-055, responded to the staff etter of January 21, 1986, which provided our evaluation of your confor nce with Regulatory Guide 1.97 Revision 2 dated December 1980.
We stated i that letter that we would
- require, by first refueling outage, that either e accumulator pressure or level instrumentation be environmentally qualif d.
Your letter of February 6,
1986 states that you consider this design c
nge to be a plant specific backfit as discussed in 10 CFR 50.109.
Regulatory Guide 1.97, Revision 2 was issue in December 1980 which is approxi-mately one year prior to the docketing of y ur operating license application i.e.,
December 22, 1981.
ry Guid 1.97, Revision 2 is applicable to all nuclear power plants and is cite as guide in 10 CFR 50.49.
We do not believe that this requirement is a backf t in accordance with 10 CFR 50. 109.
Therefore, your request is denied.
How ve in our May 2, 1986 meeting, your'taff discussed the technical basis as o why either the accumulator level or pressure instrumentation were require during th post-accident phase.
Your rationale was that the accumulators e a passive ystem and the level and pressure variables are monitored as equired by the T chnical Specifications during normal operation to maintain the accumulators i
an "as-ready" condition.
Safety grade isolation valve positi n indication is prov> ed, power to the valves is locked out at the circui breakers and no immedi e operator action is required until power is restor d to the isolation valve.
urthermore, the emergency response facilitie information system computer uld record the accumulator pressure and level v riables during and following an ccident thus providing data which would indicate whether or not the accumu tors performed their design functio As you are aware, you have the opt>
n to formally appeal the technical asis for the staff's position on this matter.
Sincerely, cc:
See next page "See previous concurrence Darrell G. Eisenhut, Acting Director Office of'uclear Reactor Regulation PM:PADP2 BBuckley:hc" 3/05/86 AD: PWRA ERossi*
3/05/86 OELD CBarth*
3/06/86 D: PAD@2 LRubenstein" 3/07/86 AD: PWRA TNovak~
5/20/86 DD: NRR DEisenhut 5/
/86 D: NRR HDenton 5/
/86
~
~
Hr. E. E. Utley thus providing data which would indicate whether or t the accumulators performed their design function.
As you are aware, ou have the option to formally appeal the technical basis for the staff'osition on this matter.
Sincere cc:
See next page Da ell G. Eisenhut, Acting Director 0 fice of Nuclear Reactor Regulation
- See previous concurrence PN:PAD¹2 BBuckley:hc*
3/05/86 DD:NRR DEisenhut 5/
/86 AD:PWRA ERossi*
3/05/86 D:NRR HDenton 5/
/86 OELD CBarth*
3/06/86 D:PAD¹2 AD:PWRA LRubenstein*
TNovak*
3/07/86 5/20/86
I J
4 I
h A
Mr. E. E. Utley 4 4,
thus providing data which would indicate whether or not th accumulators performed their design function.
As you are aware, you h ve the option to formally appeal the technical basis for the staff's posi ion on this matter.
Sincerely,
- fljl, 4
I I
Darrell G. Eisenhut, Acting 'Director Office of Nuclear Reactor Regulation cc:
See next page
- See previous co urrence PM:PAD¹2 BBuckley:hc*
3/05/86 DD:NRR DEisenhut 5/
/86 AD:PMRA ERossi*
3/05/86 D:NRR HDenton 5/
/86 OELD CBarth*
3/06/86 D:PAD¹2 LRubenstein*
3/07/86 ak 5/p0/86
1 I' P
"I I
4 n ~)
II I
e II' I
'i 1
Mr. E.
E. Utley Implementation of this requirement is widespread and well kno The staff has identified its concern on containment purging as far back a
1975 which predates your docketing date of December 22, 1981 and thus ould not be characterized as a backfit in accordance with 10 CFR 50.
9.
Therefore, we deny your request for backfit status.
- However, we believe there is merit to the concern th t y'ou raised on the containment purging limit and that further discuss' between you and the staff on this matter, as would be the case on any issue arising from your review of the "Proof and Review" Technical Spec'cations for Shearon Harris Unit 1, is warranted.
We are considering this issue in B-24, and shortly expect to have some reso1ution.g Your letter of February 6, 1986, Serial No NLS-86-055, responded to the staff letter of January 21, 1986, in which the taff provided our evaluation of your conformance with Regulatory Guide 1.97 evision 2 dated December 1980.
The staff stated in the above cited letter that we would require, by first refueling
- outage, that either the accumulator essure or level instrumentation be environmentally qualified pursuant o 10 CFR 50 in which Regulatory Guide 1.97 is referenced.
Your letter of Fe uary 6, 1986 states that you consider this design change to be a plant spec fic backfit as discussed in 10 CFR 50. 109.
Regulatory Guide 1.97, Revisi 2 was issued in December 1980 which is approximately one year prior to the docketing of your operating license application i.e.,
December 2,
1981.
As you are aware, Regulatory Guide 1.97, Revision 2 is appli ble to all nuclear power plants and is cited as a guide in 10 CFR 50.49.
We do not believe that this requirement would be characterized as a bac it in accordance with 10 CFR 50. 109.
Therefore, your request is danie
. Q cc:
See ne page Harold R. Denton, Director Office of Nuclear Reactor Regulation PM: AD¹2 B
cgley:hc
/o~/86
. DD:NRR DEisenhut
'/
/86 ERossi g/G /86 D: NRR HDenton g/
/86 0
C arth yC /86 D:PAD 2 AD:PWRA LRubenstein TNovak 3/7/86
$/
/86
~
g n
'I 1
f fl I
II II
'l
Mr. E. E. Utley Carolina Power 5 Light Company I
CC:
Thomas A. Baxter, Esq.
Shaw, Pittman, Potts 5 Trowbridge 1800 M Street, NW Washington, DC'0036 k
Richard E. Jones, Esq.
Vice President and Senior Counsel Carolina Power 5 Light Company 411 Fayetteville Street Mall Raleigh, North Carolina 27602 Mr. H. A. Cole Special Deputy Attorney General State of North Carolina Post Office Box 629
" Raleigh,, North Carolina 27602 Resident Inspector/Harri s NPS c/o U.S. Nuclear Regulatory Commission Route 1,
Box 315B New Hill, North Carolina 27562 Charles D. Barham, Jr.,
Esq.
Vice President 8 Senior Counsel Carolina Power 8 Light Company Post Office Box 1551
- Raleigh, North Carolina 27602 Mr. John Runkle, Executive Coordinator Conservation Council of North Carolina 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Wells Eddleman 812 Yancey Street Durham, North Carolina 27701 Dr. Linda Little Governor's Waste Management Board 513 Albemarle Building 325 North Salisbury Street Raleigh, North Carolina 27611 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 Comm.
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
1 Hv, IV
~
s Sk Pk Vi I
1,
~,
~
V's pi H
f It
~ ~
~
~
< ~ tf
~
4 fg
~
I s
s t
~
~
Ig V
s t
VV I
.'r ls V P I
H1 i I P
I V,.
I Il I
Il" Ik,l k
SV I I =tl y