ML18009A903
| ML18009A903 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/15/1991 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18009A904 | List: |
| References | |
| GL-90-06, GL-90-6, NLS-91-135, NUDOCS 9105280059 | |
| Download: ML18009A903 (12) | |
Text
',ACCELERATED DI UTION DEMONS TION SYSTEM
'r.'4.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9105280059 DOC.DATE: 91/05/15 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION VAUGHN,G.E.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
R
SUBJECT:
Application for amend to license NPF-63,revising Tech Spec 3/4.4.4, "Relief Valves"
& 3/4.4.9.4, "Overpressure Protection Sys" to address recommendations of Generic Ltr 90-06
& to increase availabilty
& reliability of PORVs.
DISTRIBUTION CODE:
A019D COPIES RECEIVED:LTR Q ENCL g SIZE:
9 ~ ~
TITLE: Generic Ltr 90-06 Resolution of GE 70N9+PORVs
& Block Valve Relxabil /
NOTES:Application for permit renewal filed.
05000400 A
RECIPIENT ID CODE/NAME PD2-1 LA MOZAFARI,B.
INTERNAL KIRKWOODi R NLS3
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NRR/EMEB PICKETTiD 13H15 RES/DSIR/EIB NUDOCS-ABSTRACT COPIES LTTR ENCL 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 12 ENCL 12
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Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602 MAY 15 1991 G. E. VAUGHN Vice President 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 PRESSURIZER PORVs AND BLOCK VALVES SERIAL: NLS-91-1 35 10 CFR 50.90 Gentlemen:
In accordance with the Code of Federal Regulations, Title'0, Parts 50.90 and 2.101, Carolina Power 5 Light Company (CP5L) hereby requests a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).
These TS changes are being submitted for NRC review as committed to in the SHNPP response to NRC Generic Letter 90-06, dated December 21, 1990.
The proposed changes to TS 3/4.4.4, "Relief Valves" and TS 3/4.4.9.4, "Overpressure Protection Systems" address the recommendations of Generic Letter 90-06 and are intended to increase the availability and reliability of the PORVs.
Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes. details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. is an environmental evaluation which demonstrates that the proposed amendment meets the eligibilitycriteria 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 needs to be prepared in connection with the issuance of the amendment. provides the proposed marked up Technical Specification pages.
In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&.L requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.
In accordance with 10 CFR 50.91(b), CPRL is providing the State of North Carolina with a copy of this letter.
9i05280059 910515
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Document Control Desk NLS-91-135 / Page 2 I
Please refer any questions regarding this submittal to Mr. R. W. Prunty at (919) 546-7318.
Yours very truly, JHE/jhe
Enclosures:
1.
Basis for Change Request 2.
10 CFR 50.92 Evaluation
- 3. Environmental Evaluation
- 4. Technical Specification Pages cc:
Mr. Dayne H. Brown Mr. S. D. Ebneter Ms. B. L. Mozafari Mr. J. E. Tedrow G. E. Vaughn G. E. Vaughn, 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 5 Light Company.
My commission expires: A(k(9(p i~C otary ea llllllllllll e
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ENCLOSURE 1
SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PRESSURIZER PORVs AND BLOCK VALVES BASIS FOR CHANGE REQUEST
~Back round On June 25, 1990, the NRC issued Generic Letter 90-06, "Resolution of Generic Issue 70, "Power-Operated Relief Valve and Block Valve Reliability," and Generic Issue 94, "Additional Low-Temperature Overpressure Protection For Light Water Reactors," Pursuant to 10 CFR 50.54(f)" ~ Included in the Generic Letter were requirements that licensees commit to submit Technical Specification (TS) changes based on new staff guidance prior to restart from the next refueling outage that started six months or later from the date of the Generic Letter.
Specifically, the TS changes required that plants that run with the block valves closed (e.g., due to leaking PORVs) maintain electrical power to the block valves so they can be readily opened from the control room upon demand.
Additionally, plant operation in MODES 1, 2, and 3 with PORVs and block valves inoperable for reasons other than seat leakage is not permitted for periods of more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
In addition, for LTOP operations, the NRC required that the current TS for Overpressure Protection be revised to reduce the allowed outage time (AOT) for a single channel from 7 days to 24.
hours when the plant is operating in MODES 5 or 6.
By letter dated December 21, 1990, CP&L responded to the Generic Letter for the Shearon Harris Nuclear Power Plant (SHNPP).
In response to the NRC TS change requirements, the SHNPP response committed to the following:
Consistent with the NRC position, the existing SHNPP TS require that when the block valves are closed due to excessive PORV seat leakage, that electrical power is maintained to the block valves so that they can be readily opened from the Control Room upon demand.
However, in response to the staff position concerning plant operation with the PORVs inoperable for reasons other than seat leakage, CP&L will submit a TS change request modifying the limiting conditions of operations (LCO) of PORVs and block valves in MODES 1, 2, and 3 which will meet the intent of the staff guidance.
During the upcoming refueling outage, a modification is scheduled which will upgrade two of the three PORVs (Valve Nos. 1-PCV-445A and 1-PCV-444B) manual control function and associated control circuits and power supplies to safety related.
Prior to achieving criticality during restart from this next refueling outage, currently scheduled for completion in May, 1991, CP&L will submit a TS change request modifying the PORV and block valve LCO to incorporate the requirement that plant operation is not permitted for periods of more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if either safety related PORV or its associated block valve is inoperable for reasons other than excessive seat leakage.
The combination of upgrading two of the three PORVs to safety related and revising the LCO as described above meets the intent of the staff guidance.
Prior to achieving criticality during restart from the next refueling outage, currently scheduled for completion in May, 1991, CP&L will submit a TS change request modifying the allowed outage time (AOT) for a single channel of LTOP equipment from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating in MODES 5 or 6.
Based on these commitments, CP&L hereby submits the following proposed TS changes.
In addition to the TS changes recommended by the Generic Letter, the proposed TS changes include additional changes which are intended to provide consistency with other comments included in the Generic Letter and revisions to the TS LCOs and Bases to provide clarifying wording which will enhance operator understanding.
Pro osed Chan e
The Technical Specification (TS) changes proposed in this submittal revise TS 3/4.4.4, "Relief Valves" and TS 3/4.4.9.4, "Overpressure Protection Systems" in accordance with the recommendations of Generic Letter 90-06, concerning Pressurizer Power Operated Relief Valves (PORVs) and their associated block valves.
The proposed changes to TS 3/4.4.4 are as follows:
1.
Revise the mode applicability to MODES 1, 2, and 3 to be consistent with the guidance of Generic Letter 90-06.
2.
Revise the Limiting Conditions for Operation (LCO) Action Statement wording to more clearly specify that power be maintained to a block valve which is closed due to its associated PORV being inoperable due to excessive seat leakage.
3.
Revise the shutdown requirement from COLD SHUTDOWN to HOT SHUTDOWN to be consistent with the mode applicability requirements.
4.
Wording changes necessary to reflect the plant design which includes two safety grade PORVs and one non-safety grade PORV.
5.
Eliminate the option of continued operation for periods of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with an inoperable safety grade PORV if the PORV is inoperable for reasons other than excessive seat leakage.
6.
Clarify the 18-month Surveillance Requirement for the PORVs to clearly identify the surveillance test requirements including the requirement for testing in MODES 3 or 4 prior to cooldown below 325 degrees Fahrenheit.
7.
Revise the Surveillance Requirements for the backup Air/Nitrogen supply which operates the PORVs to clearly indicate that this backup supply is the accumulator.
8.
Revise the associated TS Bases to reflect the proposed changes and to better define the basis for operability of the PORVs and block valves.
The proposed change to TS 3/4.4.9.4 is as follows:
1.
Add a new Action Statement that reduces the allowed outage time from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an inoperable PORV in MODES 5 or 6.
afe Evalua ion The changes described above increase the probability the PORVs would be available if needed for Low Temperature Overpressure Protection (LTOP), mitigation of a Steam Generator Tube Rupture (SGTR), or for RCS cooldown.
No function previously required of the PORVs has been deleted nor has the probability of inadvertent opening been increased.
Since the proposed TS changes would increase the probability the PORVs would be available if needed for accident recovery, there is no adverse impact on safety with regards to accident recovery.
The proposed changes to the SHNPP TS are consistent with the recommendations of Generic Letter 90-06.
However, there are some differences between the proposed changes to the SHNPP TS and the NRC proposed TS revisions in Generic Letter 90-06.
These differences are discussed below.
The proposed TS 3/4.4.4. with respect to the non-safety grade PORV and its associated block valve differs from the guidance proposed in the Generic Letter.
However, the proposed TS with respect to the non-safety grade PORV and block valve is consistent with the current TS requirements.
The proposed TS would allow continued operation with the non-safety grade PORV unavailable to control RCS pressure for accident mitigation as long as the block valve or PORV can be closed to maintain the RCS pressure boundary.
This is acceptable since both safety grade PORVs would still be available to control RCS pressure for accident mitigation. Operation of any one of the PORVs is adequate to recover from a Steam Generator Tube Rupture or provide RCS pressure control for RCS cooldown.
The TS surveillance requirement 4.4.4.2 proposed in the Generic Letter would require the removal of the exception for testing the block valves when they are closed to isolate an inoperable PORV. The NRC basis for this change was that the allowed outage time for a PORV inoperable for reasons other than seat leakage was limited to a maximum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> which is well within the allowable limits (25 percent) to extend the block valve surveillance interval (92 days).
However, this position is not valid for SHNPP since the allowed outage time for a non-safety grade PORV to be inoperable is not limited to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and might extend beyond the surveillance extension limit of 25 percent of the 92 day surveillance interval.
The TS 3/4.4.4 Bases proposed in the Generic Letter would require the automatic pressure control function of the PORVs to be operable for the PORVs to be operable.
The proposed SHNPP TS Bases would only require manual actuation capability for the PORVs to be operable.
The automatic RCS pressure control function of the PORVs is not a safety related function in MODES 1, 2, and 3. The automatic pressure control function limits the number of challenges to the safety valves, but the safety valves perform the safety function of RCS overpressure protection.
The automatic pressure control function in MODES 1, 2, and 3 is not required to safely shutdown the plant or mitigate the consequences of accidents.
Therefore, the automatic pressure control function is not a safety related function in MODES 1, 2, and 3, and is not necessary for the PORVs to be considered operable.
The proposed changes increase the availability and reliability of the PORVs, do not increase the probability of an accidental RCS depressurization, and are consistent with the recommendations of Generic Letter 90-06, except as noted above.
Therefore, there is reasonable assurance that the proposed changes to TS 3/4.4.4 and TS 3/4.4.9.4 would not adversely affect the health and safety of the public.
E1-3
ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PRESSURIZER PORVs AND BLOCK VALVES 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(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 5 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 sed Chan e
The Technical Specification (TS) changes proposed in this submittal revise TS 3/4.4.4, "Relief Valves" and TS 3/4.4.9.4, "Overpressure Protection Systems" in accordance with the recommendations of Generic Letter 90-06, concerning Pressurizer Power Operated Relief Valves (PORVs) and their associated block valves.
The proposed changes to TS 3/4.4.4 are as follows:
h 1.
Revise the mode applicability to MODES 1, 2, and 3 to be consistent with the guidance of Generic Letter 90-06.
2.
3.
5.
7.
8.
Revise the Limiting Conditions for Operation (LCO) Action Statement wording to more clearly specify that power be maintained to a block valve which is closed due to its associated PORV being inoperable due to excessive seat leakage.
Revise the shutdown requirement from COLD SHUTDOWN to HOT SHUTDOWN to be consistent with the mode applicability requirements.
Wording changes necessary to reflect the plant design which includes two safety grade PORVs and one non-safety grade PORV.
Eliminate the option of continued operation for periods of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with an inoperable safety grade PORV if the PORV is inoperable for reasons other than excessive seat leakage.
Clarify the 18-month Surveillance Requirement for the PORVs to clearly identify the surveillance test requirements including the requirement for testing in MODES 3 or 4 prior to cooldown below 325 degrees Fahrenheit.
Revise the Surveillance Requirements for the backup Air/Nitrogen supply which operates the PORVs to clearly indicate that this backup supply is the accumulator.
Revise the associated TS Bases to reflect the proposed changes and to better define the basis for operability of the PORVs and block valves.
The proposed change to TS 3/4.4.9.4 is as follows:
1.
Add a new Action Statement that reduces the allowed outage time from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an inoperable PORV in MODES 5 or 6.
Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The PORVs are used by operators for recovery from postulated accidents such as a Steam Generator Tube Rupture.
Automatic actuation of the PORVs is needed for Low Temperature Overpressure Protection (LTOP) of the Reactor Coolant System.
The proposed changes to the TS increase the availability and reliability of the PORVs for these functions.
Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes to the TS increase the availability and reliability of the PORVs.
The requested TS changes do not involve any physical changes to the plant and, in particular, the PORVs and block valves.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the margin of safety.
The proposed changes to the TS increase the availability and reliability of the PORVs.
The proposed TS changes do not involve any changes to actuation setpoints of the PORVs or LTOP system.
There is no impact of the proposed changes on any safety analysis assumptions.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
E2-2
ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PRESSURIZER PORVs AND BLOCK VALVES ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(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 an determined that the proposed amendment meets the eligibilitycriteria 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 needs to be prepared in connection with the issuance of the amendment.
The basis for this determination follows:
Pro osed Ch n e The Technical Specification (TS) changes proposed in this submittal revise TS 3/4.4.4, "Relief Valves" and TS 3/4.4.9.4, "Overpressure Protection Systems" in accordance with the recommendations of Generic Letter 90-06, concerning Pressurizer Power Operated Relief Valves (PORVs) and their associated block valves.
The proposed changes to TS 3/4.4.4 are as follows:
1.
Revise the mode applicability to MODES 1, 2, and 3 to be consistent with the guidance of Generic Letter 90-06.
2.
Revise the Limiting Conditions for Operation (LCO) Action Statement wording to more clearly specify that power be maintained to a block valve which is closed due to its associated PORV being inoperable due to excessive seat leakage.
3.
Revise the shutdown requirement from COLD SHUTDOWN to HOT SHUTDOWN to be consistent with the mode applicability requirements.
4.
Wording changes necessary to reflect the plant design which includes two safety grade PORVs and one non-safety grade PORV.
5.
7.
Eliminate the option of continued operation for periods of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with an inoperable safety grade PORV if the PORV is inoperable for reasons other than excessive seat leakage.
Clarify the 18-month Surveillance Requirement for the PORVs to clearly identify the surveillance test requirements including the requirement for testing in MODES 3 or 4 prior to cooldown below 325 degrees Fahrenheit.
Revise the Surveillance Requirements for the backup Air/Nitrogen supply which operates the PORVs to clearly indicate that this backup supply is the accumulator.
E3-1
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8.
Revise the associated TS Bases to reflect the proposed changes and to better define the basis for operability of the PORVs and block valves.
The proposed change to TS 3/4.4.9 4 is as follows:
1.
Add a new Action Statement that reduces the allowed outage time from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an inoperable PORV in MODES 5 or 6.
Basis The change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
1.
As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.
2.
3.
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 introduce any new equipment nor does it require existing equipment or systems to perform a different type of function than they are currently designed to perform. As such, the change can not affect the types or 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.
The proposed TS change clarifies the wording of existing surveillance requirements including specifying that the existing 18-month PORV surveillance be conducted in MODES 3 or 4 prior to cooldown below 325 degrees Fahrenheit.
The proposed change does not add any additional surveillances or testing requirements.
Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
E3-2