ML18004A604
| 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
ACCESSION NBR:
P'AC IL: 50-000 AUTH. NAHE
'UTTER, A. B.
RECIP. NANE DENTONt H. R.
REGULA
.Y INFORlfATION DISTRIBUTIC SYSTEN (R IDS) 86i 02i Oi75'OC. DATE:, 86/10/06 NOTARIZED:
NO DOCKET Shearon Hav v is Nuclear Power Plant>
Unit i>
Cav olina 05000400 AUTHOR AFFILIATION Cav'olina Potoer 8< Light Co.
RECIPIENT AFFILIATION 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 ID CODE/Nhl'1E PWR-A EB PWR-A FOB PWR-A PD2 PD PWR-* PSB INTERNAL: ADN/LFNB IE FILE IE/DGAVT/GAB 2i NRR PWR-B ADTS NRR/DHFT/NTB RQN2 EXTERNAL: BNL(ANDTS ONLY)
LPDR 03 NSIC 05 COPIES LTTR ENCL i
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0i 3
3 RECIPIENT ID CODE/MANE PWR-A EICSB PWR-A PD2 LA BUCKLEYtB 0i PWR-A RSB ELD/HDSi IE/DEPER/EPB 36 NRR BWR ADTS NRR 04 ANI/NIB DNG/DSS (ANDTS)
NRC PDR 02 PNL QRUELt R COPIES LTTR ENCL 2
2i 2
2i 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 ABC/GAS/crs (5023GAS)
Attachments cc:
Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC-RII)
. B. C tter - Vice
'dent Nuclear Engineering dc Licensing Sb102aol78 000400; PDR ADOCK o
@DR A
411 Fayettevitte Street o P. O. Box 1551
~ Raleigh, N. C, 27602
~ '
ATTACHMENT1 TO NLS-86-385
Corriment No.
Page No.
License Reference Comment 2.
General 2.
I.H Change "Carolina Power and Light Company" to "Carolina Power k Light Company" to reflect legal Company name.
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.
7.
5.
2.C.(3) 2.C.(O) 2.C.(5)
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.
Change "Amendment No. 30" to "Amendment No. 37" to reflect the latest FSAR Amendment issued prior to licensing.
Add "... after initiallyproceeding above Mode 0" at the end of the sentence.
9.
50 2.C.(8) 2.C.(9)
These license conditions should be deleted 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.
(1102NEL/crs )
P
Comment No.
Page No.
License Reference Comment 10.
12.
5.
5.
6.
2.C.(8) 2.C.(10) 2.D.
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.
Change "Appendix C" to "Appendix B".
consistent with deletion of the current Appendix B.
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
'imited quantities of incore fission chambers and sealed sources for irradiation surveillance, the staff hereby determines that granting such an exemption willnot 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.
13.
2.E.
Also, in the next sentence change "... of this exemption" to "... of these exemptions".
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.
(1102NEL/crs )
Comment No.
Page No.
License 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 willprevent reporting for minor changes allowed under these license conditions.
16.
17.
7.
Federal Register First Paragraph Under "Enclosures" delete Appendix B and relable Appendix C to be Appendix B.
Delete reference to the Environmental Protection Plan in the seventh line. Also add "reactor core power" between "limiting"and "operation" in the seventh line.
18.
Federal Register Last Paragraph The local public document room is located at the R. B. Harrison Branch of the Wake County Public Library, 1313 New Bern Avenue, Raleigh, NC.
19.
20.
- Attachment 1
Appendix B The attached table provides comments on Attachment 1 to License NPF-53 and justification for each comment.
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 No. 6 Delete second "... service area...
power supply...". Typographical error.
(I102NEL/crs )
I 4
F
Page 1 of 2 COMMENTS ON ATTACHMENT1 TO DRAFT SHNPP OPERATING LICENSE SHNPP License Condition Change to 3ustification 2c 2d 2nd Sentence "Ifbolt tension is less than that produced by 1600 ft-lbs of torque, then the cause..."
1st Sentence
- Allconnecting rod bolts should be visually inspected for thread damage (e.g., galling) and the two pairs of connecting rod bolts above the crankpin should be inspected by magnetic particle (MT) testing to verify the continued absence of cracking.
The 1-1/2" diameter bolts are installed with a nominal torque of 1700 ft-lbs. As identified in CPRL's letter of 9/11/86 to the NRC (NLS-86-329), the Owners'roup contractor (FaAA; see Report FaAA-80-3-10, page 3-1) has identified that the lower limitof 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.
The proposed change is to put the recommendation back to the wording utilized in the NRC's 6/20/86 SER, NUREG-1216 (page B-l), and PNL-5600 (page 0.38).
The NRC proposed license wording in essence doubles the number of bolts to be tested with no known technical justification. CPRL'S implementation of the connecting rod ultrasonic length verification of torque willbegin at the first inspection 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.
(1102ATTACH:NEL/mf)
Page 2 of 2 SHNPP License Condition Change to 3ustification 3c Concerns about "operable" status DELETE last four lines.
The SHNPP cylinder blocks have been inspected and shown crack-free (see CPRL Letter NLS-86-329).
By retaining the first sentence, any cracks found in future inspections willbe 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 willhave 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."
Delete entire item The continued leak-free performance of the Group IIIheads 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.
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.
(1102ATTACH:NEL/mf)
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