ML18005A749

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Application for Amend to License NPF-63,deleting Tech Spec 3.3.3.7 Re Chlorine Detection Sys & Associated Surveillance Requirement 4.7.6.d.5.Fee Paid
ML18005A749
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/04/1989
From: Mcduffie M
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18005A750 List:
References
NLS-88-281, NUDOCS 8901120074
Download: ML18005A749 (11)


Text

AC CEREBRATED D1SIRIBUTION DE M ASTRA,TlON SYSTEM REGULATC INFORMATION DISTRIBUTION+STEM (RIDE)

ACCESSION NBR:89011200'74 DOC.DATE: 89/01/04 NOTARIZED: NO . DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION MCDUFFIE,M.A. Carolina Power a Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to License NPF-63,deleting Tech Spec 3.3.3.7 6 associated Surveillance Requirement 4.7.6.d.5.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR I ENCL / SIZE: 8 + /

TITLE: OR Submittal: General Distribution D

NOTES:Application for permit renewal filed. 05000400 B

RECIPIENT COPIES RECIPIENT COPIES

'ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA .1 0 PD2-1 PD 2 2 BUCKLEY,B 1 1 INTERNAL: ACRS 6 6 ARM/DAF/LFMB 1 0 NRR/DEST/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SICB 1 1 NRR/DOEA/TSB 11 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS- B TRACT 1 1 OGC/HDS1 1 0 G FI 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 .1 D

NOTE 10 ALL RIDS" R1XXPIENTS:

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TOTAL NUMBER OF COPIES REQUIRED:. LTTR 26 ENCL 23

CHILL Carolina Power 8 Light Company P. O. Box 1551 ~ Raleigh, N.C. 27602 JAN 04 1989 M. A. McOUFFIE SERIAL: NLS-88-281 SenIor Vlcc Prealdent 10CFR50.90 Nuclear Generation United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CHLORINE DETECTION SYSTEM Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina. Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications for the Shearon Harris Nuclear Power Plant, Unit l.

The proposed amendment deletes Technical Speci.fication 3.3.3.7, Chlorine Detection Systems and the associated Surveillance Requirement 4.7.6.d.5 which verifies that on a high chlorine test signal, the Control Room Emergency Filtration System automatically isolates the control room.

The Company has reanalyzed the probability of accidental release of chlorine in the vicinity of SHNPP and determined that the probabilities are sufficiently low to justify deletion of the chlorine detection system.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 is an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides the proposed Technical Specification pages.

Enclosure 5 provides a probabilistic risk analysis of accidents related to the transportation of chlorine in the vicinity of SHNPP.

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. ~ . Document Control Des NLS-88-281 / Page 2 In accordance with the requirements of 10CFR170.12, a check for $ 150 is also enclosed.

Please refer any questions regarding this submittal to Mr. Mark A.

Turkal at (919) 362-2985.

Yours very truly, M. A. McDuffie MAM/MAT

Enclosures:

1. Basis for Change Request
2. 10CFR50.92 Evaluation
3. Environmental Evaluation
4. Technical Specification Pages
5. Probabilistic Risk Analysis cc: Mr. R. A. Becker Mr. Dayne H. Brown Mr. W. H. Bradford Mr. M. L. Ernst M. A. McDuffie, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power &

Light Company.

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ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CHLORINE DETECTION SYSTEM BASIS FOR CHANGE RE UEST Pro osed Chan e The proposed amendment deletes Technical Specification 3.3.3.7, Chlorine Detection Systems and the associated Surveillance Requirement 4.7.6.d.5 which verifies that on a high chlorine test signal, the Control Room Emergency Filtration System automatically isolates the control room.

The Company has reanalyzed the probability of accidental release of chlorine in the vicinity of SHNPP and determined that the probabilities are sufficiently low to justify deletion of the chlorine detection system.

Basis The Chlorine Detection System consists of two independent chlorine detector trains with each train consisting of a detector at each Control Room Area Ventilation System intake (both normal and emergency) and a detector at the chlorine storage area. The purpose of the system is to ensure that sufficient capability is available to promptly 'detect and initiate protective action in the event of an accidental chlorine release from either an onsite or an offsite location. The storage area detectors alarm and isolate the control room in the event of a release of chlorine at the storage area while the chlorine detectors located in the control room intakes are intended to isolate the control room should an offsite chlorine release threaten plant operators.

Carolina Power & Light Company has previously performed studies to assess the habitability of the SHNPP control room in case of postulated accidental ruptures of stationary or transient sources of chlorine in the vicinity of SHNPP. Originally, it was anticipated that liquified chlorine far in excess of 20 pounds would be stored at the chlorine storage area. Therefore, in accordance with Regulatory Guide 1.95, chlorine detectors were required to be installed at the chlorine storage area in order to isolate the control room in the event of an accidental release from the chlorine storage area.

Since performance of these studies, CPSL ceased storing large quantities (i.e., quantities greater than 20 pounds) of liquid chlorine onsite. At present, liquid sodium hypochlorite in concentrations of 15 weight percent or less is used for water treatment at SHNPP. The Company does not intend to resume onsite storage of large quantities of liquid chlorine. On August 23, 1988, the NRC issued Amendment 8 to the SHNPP Technical Specifications. This amendment allowed the chlorine detectors

at the chlorine storage area to be operable only when there is liquified chlorine in amounts in excess of 20 pounds stored at the chlorine storage area. Since large quantities of liquid chlorine will not be stored onsite, deletion of the chlorine detectors at the chlorine storage area is justified.

As stated above, the chlorine detectors located at the Control Room Area Ventilation System intakes are intended to provide protection in the event of accidental offsite release of chlorine. The Company has performed a probabalistic risk assessment to determine the probability of an accidental chlorine release in the vicinity of SHNPP (Enclosure 5). The analyses calculated the probability of accidents involving the transportation of chlorine on U. S. Highway 1 and on the Seaboard Coast railroad line, the only major routes of transportation of liquid chlorine near the SHNPP site. The results of the analysis show that the total probability of an accidental release of chlorine which results in toxic chlorine concentrations in the control room bein~ exceeded before the operators can don breathing apparatus is 2.5 x 10 per yIar. The total probability reflects an accid~nt frequency of 2.2 x 10 per year for the railroad line and 3.0 x 10 per year for trucks on U. S.

Highway 1. Regulatory Guide 1.70 and the Standard Review Plan, NUREG-0800 do not require copsideration of accidents with an annual probability of less than 10 per year. Therefore, deletion of the chlorine detectors located at the Control Room Area Ventilation System intakes is justified.

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ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CHLORINE DETECTION SYSTEM 10CFR50 92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power 6 Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this determination are as follows'.

Pro osed Chan e The proposed amendment deletes Technical Specification 3.3.3.7, Chlorine Detection Systems and the associated Surveillance Requirement 4.7.6.d.5 which verifies that on a high chlorine test signal, the Control Room Emergency Filtration System automatically isolates the control room.

The Company has reanalyzed the probability of accidental release of chlorine in the vicinity of SHNPP and determined that the probabilities are sufficiently low to justify deletion of the chlorine detection system.

Basis The change does not involve a significant hazards consideration for the following reasons:

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. The Chlorine Detection System consists of two independent chlorine detector trains with each train consisting of a detector at each Control Room Area Ventilation System intake (both normal and emergency) and a detector at the chlorine storage area. The purpose of the system is to ensure that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chlorine release from either an onsite or an offsite location. Deletion of the Chlorine Detection System does not affect the probability of an accidental release of chlorine, therefore, only the consequences of such an event must be addressed.

The storage area detectors alarm and isolate the control room in the event of a release of chlorine at the storage area. The Company does not store large quantities (i.e., quantities greater than 20 pounds) of liquid chlorine onsite at SHNPP, therefore, there is no possibility of an accidental onsite release of chlorine which could potentially affect operators's such, deletion of the storage area chlorine detectors can not increase the consequences of an accidental onsite release of chlorine.

The chlorine detectors located at the Control Room Area Ventilation System intakes are intended to provide protection in the event of accidental offsite release of chlorine. The Company has performed a probabalistic risk assessment to determine the probability of an accidental chlorine release in the vicinity of SHNPP. The analyses calculated the probability of accidents involving the transportation of chlorine on U. S. Highway 1 and on the Seaboard Coast railroad line, the only major routes of transportation of liquid chlorine near the SHNPP site. The results of the analysis show that the total probability of an accidental release of chlorine which results in toxic chlorine concentretione in the control room being exceeded IIegore the operators can don breathing apparatus is 2e5 x 10 per year. The total probability reflects an accident fiequency of 2.2 x 10 per year for the railroad line and 3.0 x 10 per year for trucks on U. S. Highway 1. Regulatory Guide 1.70 and the Standard Review Plan, NUREG-0800 do not require con~ideration of accidents with an annual probability of less than 10 per year. Therefore, deletion of the chlorine detectors located at the Control Room Area Ventilation System intakes will not increase the consequences of an accidental offsite release of chlorine.

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Deletion of the Chlorine Detection System does not require the use of a new or different system than currently exists, nor does it require existing systems to perform functions for which they were not originally designed. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not involve a significant reduction in the margin of safety. The purpose of the Chlorine Detection System is to ensure that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chlorine release. Carolina Power & Light Company does not store liquid chlorine in quantities in excess of 20 pounds onsite at SHNPP. As such, an onsite chlorine release accident is not a credible scenario. In addition, the Company has performed a probabalistic risk assessment to determine the probability of an accidental chlorine release in the vicinity of SHNPP. The analyses calculated the probability of accidents involving the E2-2

transportation of chlorine on U. S. Highway 1 and on the Seaboard Coast railroad line, the only major routes of transportation of liquid chlorine near the SHNPP site. The results of the analysis show that the total probability of an accident release of chlorine

.which results in toxic chlorine concentrations in the control room being exceeded before the operators can don breathing apparatus is 2.5 x 10 per year. Pe total probability reflects an accident freIuency of 2.2 x 10 per year for the railroad line and 3.0 x 10 per year for trucks on U. S. Highway 1. Regulatory Guide 1.70 and the Standard Review Plan, NUREG-0800 do not require con~ideration of accidents with an annual probability of less than 10 per year. Since both an onsite and an offsite chlorine release accidents are no longer credible events, the proposed amendment to delete the Chlorine Detection System does not reduce the margin of safety.

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ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CHLORINE DETECTION SYSTEM ENVIRONMENTAL CONSIDERATION 10CFR51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and (3) result in an increase in individual or cumulative occupational radiation exposure.

Carolina Power & Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e The proposed amendment deletes Technical'pecification 3.3.3.7, Chlorine Detection Systems and the associated Surveillance Requirement 4.7.6.d.5 which verifies that on a high chlorine test signal, the Control Room Emergency Filtration System automatically isolates the control room.

The Company has reanalyzed the probability of accidental release of chlorine in the vicinity of SHNPP and determined that the probabilities are sufficiently low to justify deletion of the chlorine detection system.

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The purpose of the Chlorine Detection System is to ensure that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chlorine release. The Chlorine Detection System is not associated with the processing or control of any

radioactive materials. As such, deletion of the system can not result in a change in the types of effluents that may be released offsite.

As stated above, the purpose of the Chlorine Detection System is to ensure that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chlorine release. Carolina Power & Light Company does not store liquid chlorine in quantities in excess of 20 pounds onsite at SHNPP. As such, an onsite chlorine release accident is not a credible scenario. In addition, the Company has performed a probabalistic risk assessment to determine the probability of an accidental chlorine release in the vicinity of SHNPP. The analyses calculated the probability of accidents involving the transportation of chlorine on U. S. Highway 1 and on the Seaboard Coast railroad line, the only major routes of transportation of liquid chlorine near the SHNPP site. The results of the analysis show that the total probability of an accident release of chlorine which results in toxic chlorine concentrations in the control room being exceeded before the operators can don breathing apparatus is 2.5 x 10 per year. Pe total probability reflects an accident frequency of 2.2 x 10 per year for the railroad line and 3.0 x 10 per year for trucks on U. S. Highway 1. Regulatory Guide 1.70 and the Standard Review Plan, NUREG-0800 do not re'quire con~ideration of accidents with an annual probability of less than 10 per year. Since both onsite and offsite chlorine release accidents are no longer credible events, the proposed amendment to delete the Chlorine Detection System does not result in an increase in any effluents that may be released offsite.

The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure. The Chlorine Detection System does not perform any function associated with processing or control of radioactive material. As such, deletion of the system can not result in an increase in any radiation exposures.

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