ML18004A604

Forwards Comments on Preliminary Draft Proposed Low Power License for Plant,Per NRC Request

ML18004A604
Person / Time
Site:	Harris
Issue date:	10/06/1986
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NLS-86-385, NUDOCS 8610210175
Download: ML18004A604 (14)

Text

REGULA .Y INFORlfATION DISTRIBUTIC SYSTEN (R IDS)

ACCESSION NBR: 86i 02i Oi 75'OC. DATE:, 86/10/06 NOTARIZED: NO DOCKET P'AC I L: 50-000 Shearon Hav v is Nuclear Power Plant> Unit i> Cav olina 05000400 AUTH. NAHE AUTHOR AFFILIATION A. B. 'UTTER, Cav'olina Potoer 8< Light Co.

RECIP. NANE RECIPIENT AFFILIATION DENTONt H. R. OFFice of Nuclear Reactov Regulationt Directov'post 85ii25

SUBJECT:

Fortoards comments on preliminary draft pv oposed low pouer license for plantt pev NRC v equest.

DISTRIBUTION CODE: BOOID COPIEE RECEIVED: LTR ( ENCL I SI IE:

TITLE: Licensing Submittal: PSAR/FSAR Amdts Zc Related Cov respondence NOTES: Application fov. permit v eneeal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/Nhl'1E LTTR ENCL ID CODE/MANE LTTR ENCL PWR-A EB i PWR-A EICSB 2 2 PWR-A FOB i PWR-A PD2 LA i PWR-A PD2 PD i BUCKLEYt B 0i 2 2 PWR-* PSB i PWR-A RSB i INTERNAL: ADN/LFNB 0 ELD/HDSi IE FILE i IE/DEPER/EPB 36 IE/DGAVT/GAB 2i i i NRR BWR ADTS NRR PWR-B ADTS i 0 NRR NRR/DHFT/NTB i 04 RQN2 3 3 ANI/NIB EXTERNAL: BNL(ANDTS ONLY) DNG/DSS (ANDTS)

LPDR 03 NRC PDR 02 NSIC 05 PNL QRUELt R TOTAL NUNBER OF COPIES REQUIRED'TTR 30 ENCL 25

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CKK Carolina Power & Light Company SERIAL: NLS-86-385 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. 1 DOCKET NO.50-000 COMMENTS ON THE PRELIMINARYDRAFT OF THE PROPOSED LOW-POWER LICENSE

Dear Mr. Denton:

Carolina Power R Light Company (CPRL), as requested by the NRC Staff, submits comments on the preliminary draft of the proposed low-power license for the Shearon Harris Nuclear Power Plant (SHNPP). The attachment provides the comments and justification.

Submittal of these comments does not preclude our right to later appeal or contest the statements and conditions stated in the final license. If you have any questions, please contact me at your convenience at (919) 836-6231.

Yours very tr

. B. C tter - Vice 'dent Nuclear Engineering dc Licensing ABC/GAS/crs (5023GAS)

Attachments cc: Mr. B. C. Buckley (NRC)

Mr. G. F. Maxwell (NRC-SHNPP)

Dr. J. Nelson Grace (NRC-RII)

Sb102aol78 o 000400; PDR ADOCK @DR A

411 Fayettevitte Street o P. O. Box 1551 ~ Raleigh, N. C, 27602

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ATTACHMENT 1 TO NLS-86-385

Corriment Page License No. No. Reference Comment General Change "Carolina Power and Light Company" to "Carolina Power k Light Company" to reflect legal Company name.

2. 2. I.H Delete "... subject to... Appendix B,

..." to reflect CPRL's position stated in NLS-86-367 dated September 29, 1986, Mr. S. R. Zimmerman to Mr. L. S.

Rubenstein.

3. 2. 2. Delete "... affirmations by... Board of

..." because ASLAB affirmations of the second and fourth ASLB decisions have not been issued. Also change "Atomic Safety and Licensing Boards" to "Atomic Safety and Licensing Board" as there was only one Board for Harris.

3. 2.C.(1) Add "reactor core" between "to" and "power" in the fifth line to be consistent with the second line.

5. 2.C.(2) Delete references to "Environmental Protection Plan" in the title, the second line, and the last line to reflect CPRL's position stated in NLS-86-367 dated September 29, 1986, Mr. S. R. Zimmerman to Mr. L. S. Rubenstein.

6. 2.C.(3) Delete this license condition in its entirety based on NLS-86-386 dated October 6, 1986, Mr. A. B. Cutter to Mr. H. R.

Denton. Renumber the remaining license conditions accordingly.

7. 2.C.(O) Change "Amendment No. 30" to "Amendment No. 37" to reflect the latest FSAR Amendment issued prior to licensing.

5. 2.C.(5) Add "... after initially proceeding above Mode 0" at the end of the sentence.

9. 50 2.C.(8) These license conditions should be deleted 2.C.(9) in their entirety because they are redundant to established CPRL Commitments. Reference letters NLS-86-373 dated September 29, 1986 and NLS-86-067 dated 3une 2, 1986.

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P Comment Page License No. No. Reference Comment

10. 5. 2.C.(8) In the event that this condition is not deleted per comment No. 9, then replace

"... by the first..." with "... prior to startup from the first "to establish a fixed point in time.

5. 2.C.(10) Change "Appendix C" to "Appendix B".

consistent with deletion of the current Appendix B.

12. 6. 2.D. After "10 CFR 50.12." add the following:

The facility requires an exemption from the provisions of IOCFR70.20. Because of the inherent features associated with the storage and inspection of unirradiated fuel containing uranium enriched to less than 5 percent in the V-235 isotope when no fuel processing activities are to be performed and the inherent safety features in handling quantities of incore fission 'imited chambers and sealed sources for irradiation surveillance, the staff hereby determines that granting such an exemption will not endanger life or property, or the common defense and security, and is otherwise in the public interest. This exemption is authorized pursuant to 10CFR70.10.

Also, in the next sentence change "... of this exemption" to "... of these exemptions".

13. 2.E. Delete the last sentence. The latest revision to the security plan was submitted via letter NLS-86-369 dated September 26, 1986. Future license changes should not be required each time the security plan is revised.

6. 2.F. Delete reference to the Environmental Protection Plan in the second line. This reflects CPRL's position stated in NLS-86-367 dated September 29, 1986, Mr. S. R. Zimmerman to Mr. L. S.

Rubenstein.

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Comment Page License No. No. Reference Comment

15. 6. 2.F In the fourth line after "Section 2.C." add "under the headings Maximum Power Level or Operating Experience." In any event, the license conditions on Fire Protection and TDI Diesel Generators should be removed from Section 2.C and placed into their own sections,'.e., 2.1 and 2.3. This will prevent reporting for minor changes allowed under these license conditions.

16. 7. Under "Enclosures" delete Appendix B and relable Appendix C to be Appendix B.

17. Federal First Delete reference to the Environmental Register Paragraph Protection Plan in the seventh line. Also add "reactor core power" between "limiting"and "operation" in the seventh line.

18. Federal Last The local public document room is located Register Paragraph at the R. B. Harrison Branch of the Wake County Public Library, 1313 New Bern Avenue, Raleigh, NC.

19. -

Attachment 1 The attached table provides comments on Attachment 1 to License NPF-53 and justification for each comment.

20. Appendix B Delete entire appendix. This reflects CPdcL's position stated in NLS-86-367 dated September 29, 1986, Mr. S. R.

Zimmerman to Mr. L. S. Rubenstein.

21. Appendix C Commitment Delete second "... service area ...

No. 6 power supply...". Typographical error.

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Page 1 of 2 COMMENTS ON ATTACHMENT 1 TO DRAFT SHNPP OPERATING LICENSE SHNPP License Condition Change to 3ustif ication 2c 2nd Sentence "If bolt tension The 1-1/2" diameter bolts are installed with a nominal torque is less than that produced by of 1700 ft-lbs. As identified in CPRL's letter of 9/11/86 to 1600 ft-lbs of torque, then the the NRC (NLS-86-329), the Owners'roup contractor (FaAA; cause..." see Report FaAA-80-3-10, page 3-1) has identified that the lower limit of acceptability is the 1600 ft-lbs. The major problem is with the words "value at installation". Allowances for installation tolerances must be made or each bolt will have a different numerical acceptance criteria.

'While PNL identifies the "... 93% of the value at installation..." (PNL-5600, page 0.38), they also clearly identify the 1600 ft-lb limit (on page 0.37) which should be acceptable.

2d 1st Sentence - All connecting rod The proposed change is to put the recommendation back to bolts should be visually inspected the wording utilized in the NRC's 6/20/86 SER, NUREG-1216 for thread damage (e.g., galling) (page B-l), and PNL-5600 (page 0.38). The NRC proposed and the two pairs of connecting license wording in essence doubles the number of bolts to rod bolts above the crankpin should be tested with no known technical justification. CPRL'S be inspected by magnetic particle implementation of the connecting rod ultrasonic length (MT) testing to verify the continued verification of torque will begin at the first inspection absence of cracking. interval. Appropriate ultrasonic elongation equipment is not presently available at the Shearon Harris site; however, the bolts have been properly torqued to the specified value per site procedure.

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Page 2 of 2 SHNPP License Condition Change to 3ustif ication 3c . Concerns about "operable" status The SHNPP cylinder blocks have been inspected and shown DELETE last four lines. crack-free (see CPRL Letter NLS-86-329). By retaining the first sentence, any cracks found in future inspections will be reported to the NRC. However, as demonstrated by the Phase I Report (FaAA-80-9-11.1), shallow cracks (less than 1.5 inches in depth) do not affect engine operability.

Ob Rc Delete both Given compliance with the Owners'roup program and the initial cylinder head inspections (10096 UT firedeck thickness; 2596 firedeck MT, and 2596 valve seat PT) and the fact that the engines must operate one complete cycle with no water leakage, these requirements are not necessary. The successful operation of the heads at a site will have been demonstrated by engine operation and performing the pre-and post-operation air roll for one complete plant fuel cycle. It is to be noted that the pre-operation air roll is retained.

An alternative proposed license condition is "Any replacement cylinder heads must satisfy the Owners'roup DR/QR pre-service inspection requirements."

The continued leak-free performance of the Group III heads should only be based upon the uncovering of some generic problem which would be reported to the NRC under the provisions of 10 CFR Part 21. The inclusion of this statement as a license condition is inappropriate.

Delete entire item This proposed condition (checking the base for Widmanstaetan graphite) was not a license condition in the NRC's SER of 6/20/86, is not in NUREG-1216, and is not a PNL-5600 recommendation. The OG does not concur with this recommendation and provided justification to the NRC in a 5/1/86 letter.

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