ML18005A833

Application for Amend to License NPF-63,revising Tech Specs 3/4.9.1 Re Boron Concentration & 3/4.9.2 Re Instrumentation. Proposed Change Allows Alternate Valve Arrangement to Permit Makeup to Refueling Water Storage Tank to Be Refilled

ML18005A833
Person / Time
Site:	Harris
Issue date:	03/30/1989
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18005A835	List: ML18005A833 ML18005A837
References
NLS-89-070, NLS-89-70, NUDOCS 8904040419
Download: ML18005A833 (11)

Text

' ACCELERATED D1S+Bt'>0K DEMONSTRQOY, SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR'904040419 DOC DATE'9/03/30

~ NOTARIZED YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION tt, CUTTERiA BE Carolina Power & Light Co.

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

SUBJECT:

Application for amend to License NPF-63,revising Tech Spec 3/4.9.1 8( 3/4.9.2.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:Application for permit renewal filed. 05000400 ~

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 BECKER,D 5 5 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/ICSB 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/RSB 8E 1 1 NRR/DOEA/TSB 11 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS 1 1 0 E E 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR NSIC 1 1 I

D NOTE 'ZO ALL "RIDS" RECIPIENIS'LEASE HELP US 'ZO REZQCE HASTE.'XNZACT 'IHE EGCUMEÃZ CONSOL DESK, ROOM Pl-37 (EXT. 20079) TO KZJMNATE YOUR NAME HKH DISTRIBUTION LISTS H)R DOCQMEMZS YOU DGNiT NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 26

CHAL Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.c. 27602 MAR 30 $ 89 A. 8 CUTTER SERIAL: NLS-89-070 Vice President 10CFR50.90 Nuclear Services Department 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 MISCELLANEOUS REFUELING OPERATIONS 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 1.

The proposed amendment affects two Technical Specifications associated with refueling operations. The first is Specification 3/4.9.1, Boron Concentration. Currently, Table 4.9-1 provides a valve arrangement intended to prevent a boron dilution event while in Mode 6. The specified valve arrangement does not allow the Refueling Water Storage Tank (RWST) to be refilled while in Mode 6. The proposed change allows an alternate valve arrangement, permitting makeup to the RWST. Also, administrative changes have been made to Specification 3'/4.9.1 to make it easier to use and avoid possible operator confusion.

The second change is to Specification 3/4.9.2, Instrumentation. This change is purely administrative in nature intended to clarify that both action requirements must be fulfilled with two inoperable Source Range Neutron Flux Monitors.

Enclosure 1 provides a detailed description of the proposed changes and t: he 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.

M Enclosure 3 is an environmental evaluation which'emonstrates 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.

89040404i9 89'0330 PDR ADOCK 05000400 P PDC

Document Control Desk NLS-89-070 / Page 2 i provides the proposed Technical Specification pages.

Carolina Power & Light Company requests i.ssuance of this amendment by October ll, 1989 to support the upcoming SHNPP refueling outage. Please refer any questions regarding this submittal to Mr. Mark A. Turkal at (919) 362-2985.

Yours very truly, A. B. Cutter ABC/MAT

Enclosures:

1. Basis for Change Request

2. 10CFR50.92 Evaluation

3. Environmental Evaluation

4. Technical Specification Pages cc: Mr. R. A. Becker Mr. W. H. Bradford Mr. Dayne H. Brown Mr. S. D. Ebneter A. B. Cutter, 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 MISCELLANEOUS REFUELING OPERATIONS BASIS FOR CHANGE RE UEST Pro osed Chan e The proposed amendment affects two Technical Specifications associated with refueling operations. The first is Specification 3/4.9.1, Boron Concentration. Currently, Table 4.9-1 provides a valve arrangement intended to prevent a boron dilution event while in Mode 6. The specified valve arrangement does not allow the Refueling Water Storage Tank (RWST) to be refilled while in Mode 6. The proposed change allows an alternate valve arrangement, permitting makeup to the RWST. Also, administrative changes have been made to Specification 3/4.9.1 to make it easier to use and avoid possible operator confusion.

The second change is to Specification 3/4.9.2, Instrumentation. This change is purely administrative in nature intended to clarify that both action requirements must be fulfilled with two inoperable Source Range Neutron Flux Monitors.

Basis Technical Specification 3/4.9.1 establishes administrative controls over certain valves during refueling operations to preclude the possibility of uncontrolled boron dilution of the filled portion of the RCS. This action prevents flow to the RCS of unborated water by closing flow paths from sources of unborated water. However, the current arrangement requires valve 1CS-149 to be locked closed which prevents makeup of borated water to the Refueling Water Storage Tank (RWST). After the RWST is partially drained to fill the refueling cavity, the potential exists for exhausting this supply leaving the Boric Acid Tank (BAT) as the only remaining source of borated water.

Technical Specification 3.1.2.5 requires, as a minimum, that either the BAT or the RWST be operable while in Modes 5 or 6. With no borated water source operable, all operations involving core alterations or positive reactivity changes must be suspended. In order to maintain the operational flexibility allowed by Specification 3.1.2.5, the proposed amendment allows valve 1CS-149 to be opened provided valves 1CS-155 and 1CS-156 are maintained closed with their main control board control switches in the "Shut" position and manual valves 1CS-265, 1CS-274, and 1CS-287 are locked closed (see Figure 1). This arrangement provides operational flexibility with respect to borated water sources while administratively precluding the possibility of uncontrolled boron dilution event in Mode 6.

E The remainder of the changes made to Technical Specification 3/4.9.1 are administrative in nature. The intent is to put further emphasis on the required valve positions established by the specification and to clearly state that core alterations and/or positive reactivity changes must be suspended if the valve positions are not as required by the specification. This will avoid possible operator errors in interpreting the requirements of the specification. Table 4.9-1, Administrative Controls To Prevent Dilution During Refueling, has been relabeled as Table 3.9-1 to be consistent will the labeling used throughout the SHNPP Technical Specifications.

The second change involves Specification 3/4.9.2 which requires a minimum of two operable Source Range Neutron Flux Monitors while in Mode 6. The proposed change is purely administrative in nature.

Currently, it is not specifically stated that Action a must be performed with either one or two inoperable Source Range Neutron Flux Monitors.

The proposed changes insert the following underlined phrases to Actions a and b.

Action a: With one or more of the above required monitors inoperable or not operating, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

Action b: With both of the above required monitors inoperable or not operating, in addition to Action a above, determine the boron concentration of the Reactor Coolant System at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This will avoid the possibility of operator confusion with regard to the requirement to suspend core alterations or positive reactivity changes when either one or two of the monitors is inoperable.

El-2

TO OTHER Desired Flowpath MAKEUP WATER i'to RNST EPEUF FUEL POOL LOADS'ocked RMwsy Ql' Rtll Ly LETOOWII ICS-FCV- idi Closed Closed eLENOIHO TEE X/

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ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT MISCELLANEOUS REFUELING OPERATIONS 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 & 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 affects two Technical Specifications associated with refueling operations. The first is Specification 3/4.9.1, Boron Concentration. Currently, Table 4.9-1 provides a valve arrangement intended to prevent a boron dilution event while in Mode 6. The specified valve arrangement does not allow the Refueling Water Storage Tank (RWST) to be refilled while in Mode 6. The proposed change allows an alternate valve arrangement, permitting. makeup to the RWST. Also, administrative changes have been made to Specification 3/4.F 1 to make it easier to use and avoid possible operator confusion.

The second change is to Specification 3/4.9.2, Instrumentation. This change is purely administrative in nature intended to clarify that both action requirements must be fulfilled with two inoperable Source Range Neutron Flux Monitors. r 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.

Technical Specification 3/4.9.1 establishes administrative controls over certain valves during refueling operations to preclude the possibility of uncontrolled boron dilution of the

filled portion of the RCS. This action prevents flow to the RCS of unborated water by closing flow paths from sources of unborated water. However, the current arrangement requires valve 1CS-149 to be locked closed which prevents makeup of borated water to the Refueling Water Storage Tank (RWST). The proposed change allows an alternate valve arrangement, permitting makeup to the RWST.

Requiring valves 1CS-155 and 1CS-156 to be maintained closed with their main control board control switches in the "Shut" position and manual valves 1CS-265, 1CS-274, and 1CS-287 to be locked closed provides operational flexibility with respect to borated water sources while administratively precluding the possibility of uncontrolled boron dilution event in Mode 6. Therefore, boron dilution while in Mode 6 remains a non-credible event and neither the probabi.lity or consequences of a Mode 6 boron dilution event are affected by the proposed change.

The remaining changes to Technical Specifications 3/4.9.1 and 3/4.9.2 are administrative in nature and, therefore, can not increase the probability or consequences of an accident previously evaluated.

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

The change merely provides an alternate valve arrangement which isolates sources of unborated water while in Mode 6. This valve arrangement offers an equivalent method for ensuring that boron dilution while in Mode 6 remains a non-credible event to that of the existing specification. As such, this change does not create a new or different kind of accident.

The remaining changes to Technical Specifications 3/4.9.1 and 3/4.9.2 are administrative in nature and, therefore, can 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. As stated above, the alternate valve arrangement of the proposed amendment provides an equivalent method for ensuring that boron dilution while in Mode 6 remains a non-credible event. As such, the margin of safety is not affected by the proposed amendment.

The remaining changes to Technical Specifications 3/4.9.1 and 3/4.9.2 are administrative in nature which clarify the specifications and, therefore, do not involve a reduction in the margin of safety.

E2-2

ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT MISCELLANEOUS REFUELING OPERATIONS 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 affects two Technical Specifications associated with refueling operations. The first is Specification 3/4.9.1, Boron Concentration. Currently, Table 4.9-1 provides a valve arrangement intended,to prevent a boron dilution event while in Mode 6. The specified valve arrangement does not allow the Refueling Water Storage Tank (RWST) to be refilled while in Mode 6. The proposed change allows an alternate valve arrangement, permitting makeup to the RWST. Also, administrative changes have been made to Specification 3/4.9.1 to make it easier to use and avoid possible operator confusion.

The second change is to Specification 3/4.9.2, Instrumentation. This change is purely administrative in nature intended to clarify that both action requirements must be fulfilled with two inoperable Source Range Neutron Flux Monitors.

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.

E3-1

The proposed change to Specification 3/4.9.1 provides an alternate valve arrangement which allows makeup of borated water to the RWST while in Mode 6. Under both the existing Technical Specification 3/4.9.1 and the proposed revision, boron dilution while in Mode 6 is a non-credible event. Other changes to Specifications 3/4.9.1 and 3/4.9.2 are administrative in nature. Therefore, 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 proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

Achieving the alternate valve arrangement does not require operators to access higher radiation areas or spend more time in a radiation area than the existing arrangement, as such, their manipulation will not result in a higher individual or cumulative occupational radiation exposure.

The other changes to Specifications 3/4.9.1 and 3/4.9.2 are administrative in nature. and, therefore, can not result in an increase in individual or cumulative occupational radiation exposure.

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