ML18010A341

Application for Amend to License NPF-63,changing Tech Spec 3/4.6.3 to Address Recommendations in Generic Ltr 91-08 Re Applicability of Spec 3.0.4 on Surveillance Requirements

ML18010A341
Person / Time
Site:	Harris
Issue date:	07/26/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18010A342	List: ML18010A341 ML18010A343
References
GL-91-08, GL-91-8, NLS-91-169, NUDOCS 9108050010
Download: ML18010A341 (10)

Text

tACCELERATED DISTRIBUTION DEMONST TION SYSTEM i~ ',i REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS}

ACCESSION NBR:9108050010 DOC.DATE: 91/07/26 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina'5000400 AUTH. NAME AUTHOR AFFILIATION VAUGHN,G.E. Carolina Power & Light Co.

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

SUBJECT:

Application for amend to License NPF-63,changing Tech Spec DISTRIBUTION CODE'OOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution NOTES:Application for permit renewal filed.

l 3/4.6.3 to address recommendations in Generic Ltr 91-08 re applicability of Spec 3.0.4 on suxveillance requirements.

ENCL 2 SIZE:

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RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-1 LA 1 1 PD2-1 PD 1 1 MOZAFARI,B. 2 2 D INTERNAL: ACRS 6 6 NRR/DET/ECMB 7D 1 1 NRR/DET/ESGB 1 1 NRR/DOEA/OTS B1 1 1 1 NRR/DST 8E2 1 1 NRR/DST/SELB 7E 1 1 NRR/DST/SICB8H7 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 OC/LEHB~ 1 0 OGC/HDS 1 1 0 EG FILE 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 22

Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602

~JUL 26 mg~ SERIAL: NLS-91-169 10CFR50.90 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 CONTAINMENT ISOLATION VALVES 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 (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).

This TS change is being submitted for NRC review in accordance with the guidance provided in NRC Generic Letter 91-08, dated May 6, 1991. The proposed change to TS 3/4.6.3 addresses the recommendations of the Generic Letter as it pertains to the applicability of Specification 3.0.4.

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 '2(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.

Enclosure 4 provides the proposed 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 such that implementation will occur within 60 days from the issuance of the amendment.

In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina with a copy of this letter.

9108050010 910726 PDR /DOCK 05000400 '

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'(NLS-91-169) / Page&

Please refer any questions regarding this submittal to Mr. R. W. Prunty at (919) 546-7318.

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 & Light Company.

I pgg Notary ( S My commission expires ~/@fry(p LSR/jbw (1191HNP) r ', Pgg ee

Enclosures:

1. Basis for Change Request <os)

2. 10CFR50.92 Evaluation )t>so~'c:

3. Environmental Evaluation

4. Technical Specification Pages Mr. Dayne H. Brown Mr. S. D. Ebneter Ms. B. L. Mozafari Mr. J. E. Tedrow

ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENT ISOLATION VALVES BASIS FOR CHANGE RE UEST

~Back round On November 24, 1986, the NRC issued the Low Power Operating License and Technical Specifications for the Shearon Harris Nuclear Power Plant (SHNPP),

including Table 3.6-1 of Specification 3/4.6.3 which provided a listing of all containment isolation valves. Included in this table was a footnote, applicable to selected valves, which identified that Specification 3.0.4 was not applicable.

Upon issuance of the Full Power Operating License on January 12, 1987, Table 3.6-1 was relocated to the Technical Specification Equipment List Program, referenced in Specification 6.8.1.i. This program is contained and controlled in plant procedure PLP-106 and FSAR Section 16.3.

On June 4, 1987, the NRC issued Generic Letter 87-09 which, in part, identified changes which licensees could make to Specification 3.0.4. These changes permitted rewording of the specification so that entry into operational modes or other conditions could be made when the action requirements allowed continued operation of the facility for an unlimited period of time. The generic letter provided the basis for these changes, i.e. that conformance to the action requirements of certain specifications establishes an acceptable level of safety.

Based on a review of the guidance contained in Generic Letter 87-09, CP&L determined this to be applicable to Specification 3/4.6.3. Per this specification, the action requirements allowed containment penetrations to be isolated by closed, deactivated isolation valves, manual valves, or blind flanges. With these action requirements met, continued operation would be permitted. Since the applicability of Specification 3.0.4 was contained in plant procedure PLP-106, a controlled document, the note was applied to each valve in the table in order to implement the generic letter.

Based upon reviews performed by the NRC, it was determined that a plant procedure cannot in itself specify the applicability of Technical Specification requirements such as 3.0.4. Rather, the Technical Specifications must contain this requirement. Accordingly, based on this interpretation, the note was deleted from PLP-106. On May 6, 1991, the NRC issued Generic Letter 91-08 which provided further guidance on amending Technical Specifications relative to Specification 3.0.4. The Generic Letter states:

The list of containment isolation valves typically includes footnotes that modify the TS requirements for these valves. Such notes must be incorporated into the associated LCO so that they will remain in effect when the table containing these footnotes is removed from the TS. One of these footnotes involves valves that are exempt from the requirements of TS 3.0.4. TS 3.0.4 precludes entry into an operational mode or condition when an LCO woul.d not be met without reliance on the provisions of the action requirements.

The action requirements for containment isolation valves permit continued operation with an inoperable valve when the associated penetration is isolated. Therefore, an exception to the limitation of TS 3.0.4 on changes in operational modes or conditions is acceptable for this specification, and a statement may be added to the LCO under the action requirements to state "The provisions of Specification 3.0.4 do not apply." This exception will apply to all containment isolation valves.

(1191HMP)

ENOLOSURE 1 (continued)

The intent of this Request for License Amendment is to restore the non-applicability of Specification 3.0.4 to Specification 3/4.6.3 in accordance with the guidance provided in Generic Letter 91-08.

Pro osed Chan e The Technical Specification (TS) change proposed in this submittal revises TS 3/4.6.3, "Containment Isolation Valves" in accordance with the recommendations and guidance of NRC Generic Letter 91-08, "Removal of Component Lists From Technical Specifications," dated May 6, 1991.

The proposed change to TS 3/4.6.3 is as follows:

l. Add a statement to the LCO under the action requirements to the effect that the provisions of Specification 3.0.4 do not apply.

Safet Evaluation When the action requirements of Specification 3/4.6.3 are met to permit continued indefinite operation, a containment penetration is isolated in a manner such that no single active failure will breach the containment boundary at that penetration. This provides the same level of safety which is achieved when the penetration is open and relying on operable isolation valves, since a double barrier is provided for each penetration, whether valves, or closed systems.

it be two valves, locked manual The bases for Specification 3/4.6.3 are therefore met when the action requirements of the Specification are complied with, permitting continued operation for an unlimited period of time. No reduction in the margin of safety of the containment boundary occurs.

Containment isolation valves do not initiate accidents analyzed in Chapter 15 of the Final Safety Analysis Report (FSAR); therefore, no increase in the probability of such accidents occurs. Since the containment boundary is not adversely impacted when a penetration is isolated per the action requirements, it remains capable of performing mitigating an accident.

its design function and fully capable of Therefore, there would be no increase in the consequences of an accident previously evaluated.

When a containment penetration has been isolated without reliance on the automatic isolation signal, the probability of an equipment malfunction involving containment isolation valves is not increased, and in fact is decreased, since the affected valve will not be challenged when it is closed and deactivated.

Similarly, when a penetration has been isolated, any equipment malfunction which requires the containment isolation function to mitigate the impact will be mitigated; therefore, the consequences of equipment malfunctions is not affected.

The proposed amendment to the Technical Specifications do not require any physical changes to the plant and do not alter existing Technical Specificati.on requirements or those components to which they apply. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes are consistent with the guidance provided in NRC Generic Letter 91-08 and do not increase the probabilities or consequences or accidents previously evaluated, create the possibility of new or different accidents, increase the probability or consequences of equipment malfunctions, or reduce the margin of safety. Therefore, there is reasonable assurance that the proposed change to Specification 3/4.6.3 would not adversely affect the health and safety of the public.

ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENT ISOLATION 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 6 Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:

Pro osed Chan e The Technical Specification (TS) change proposed in this submittal revises TS 3/4.6.3, "Containment Isolation Valves" in accordance with the recommendations and guidance of NRC Generic Letter 91-08, "Removal of Component Lists From Technical Specifications," dated May 6, 1991.

The proposed change to TS 3/4.6.3 is as follows:

1. Add a statement to the LCO under the action requirements to the effect that the provisions of Specification 3.0.4 do not apply.

Basis This 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.

Containment Isolation Valves do not initiate accidents analyzed in Chapter 15 of the Final Safety Analysis Report (FSAR). Further, the containment boundary is not adversely impacted when a penetration is isolated per the action requirements of the Technical Specifications, remains capable of performing its design function, and is fully capable of mitigating an accident. 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 Technical Specifications do not require any physical changes to the plant. As such, existing Technical Specification requirements and the components to which they apply remain unaltered; and the existing systems continue to perform the same functions which they are currently designed to perform.

NCLOSURE 2 (continued)

The proposed amendment does not involve a significant reduction in the margin of safety.

The bases of Specification 3.0.4 are met when the action requirements of Specification 3/4.6.3 are complied with, permitting continued operation for an unlimited period of time. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENT ISOLATION VALVES ENVIRONMENTAL CONSIDERATIONS 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 off-site; (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power 6 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 needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e The Technical Specification (TS) change proposed in this submittal revises TS 3/4.6.3, "Containment Isolation Valves" in accordance with the recommendations and guidance of NRC Generic Letter 91-08, "Removal of Component Lists From Technical Specifications," dated May 6, 1991.

The proposed change to TS 3/4.6.3 is as follows:

l. Add a statement to the LCO under the action requirements to the effect that the provisions of Specification 3.0.4 do not apply.

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 off-site.

The proposed amendment does not introduce any new equipment, nor does it require existing systems to perform a different type of function than they are currently designed to perform. Existing Technical Specification requirements and the components to which they apply remain unaltered. As such, the change cannot affect the types or amounts of any effluents that may be released off-site.

(1191HHP )

NCLOSURE 3 (continued)

The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposures 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.