ML18010A917
| ML18010A917 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/17/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18010A914 | List: |
| References | |
| GL-87-09, GL-87-9, GL-91-08, GL-91-8, NUDOCS 9211230338 | |
| Download: ML18010A917 (4) | |
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+p*y4 UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
TO FACILITY OPERATING LICENSE NO.
NPF-63 CAROLINA POWER 5 LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1
DOCKET NO. 50-400
- 1. 0 INTRODUCTION By letter dated July 26, 1991, Carolina Power 5, Light Company (CP8L or the licensee) submitted a request for a change to the Shearon Harris Nuclear Power Plant, Unit 1 (Harris), Technical Specifications (TS).
The requested change would restore the nonapplicability of TS 3.0.4 to TS 3/4.6.3 in accordance with the guidance provided in Generic Letter (GL) 91-08, "Removal of Component Lists from the Technical Specifications,"
by adding a statement to the Limiting Condition for Operation (LCO) 3.6.3 to state "The provisions of Specification 3.0.4 are not applicable."
This exception would apply to all containment isolation valves.
Enclosure 1 to Generic Letter 87-09, "Alternatives to the STS Requirements to Resolve Three Specific Problems with Limiting Conditions for Operation and Surveillance Requirements,"
states that although TS 3.0.4 may unduly restrict facility operation, nothing in the staff position should be interpreted as endorsing or encouraging a plant startup with inoperable equipment.
- However, even with the staff guidance and recommendations in GL 87-09, the staff believes there is still room for misinterpretation of the intent of an exception to Specification 3.0.4.
Therefore, included in this Safety Evaluation is a discussion of the staff's intent and expectations in granting a TS 3.0.4 exception.
- 2. 0 EVALUATION Prior to the issuance of the full power operating license for Harris, TS Table 3.6-1, Containment Isolation Valves, and a footnote were removed from the TS and relocated to the Technical Specification Equipment List Program, plant procedures PLP-106.
The list of containment isolation valves typically includes footnotes that modify the TS requirements for these valves.
As outlined in GL 91-08, these footnotes must be incorporated into the LCO so that they will remain in effect when the table containing the footnotes is removed from the TS.
One of these footnotes involves valves that are exempt from the requirements of TS 3.0.4.
In the case of the Harris TS, TS 3.0.4 precludes entry into an operational mode or condition when an LCO would not be met without reliance on the provisions of the action requirements.
The action requirements for containment isolation valves permit continued operation with 92ii230338 92iii7 PDR ADOCK 05000400 P
PDR an inoperable valve when the associated penetration is isolated.
Therefore, as long as the staff intent and expectations regarding the exceptions from TS 3.0.4.
(discussed below) are met, an exception to the limitation of TS 3.0.4 on changes in operational modes or conditions is acceptable for this specification.
In 1987, to implement the guidance provided in GL 87-09, the licensee applied a note to the valves listed in Plant Procedure (PLP)-106, Table 3.6-1, stating that the provisions of TS 3.0.4 were not applicable.
The NRC staff subsequently performed a review and determined that a Plant Procedure alone can not state the applicability of the TS requirements.
The applicability for these requirements must be contained within the TS.
Based on this staff determination, the note was deleted from PLP-106.
To implement the staff guidance provided in GL 91-08, the licensee proposed a
statement be added into the LCO for TS 3.6.3 as follows:
The provisions of Specification 3.0.4 are not applicable.
The staff has reviewed the licensee's submittal and has found the proposed change to be acceptable.
The exc'eption from requirements of TS 3.0.4 is applicable to all containment isolation valves.
This change is acceptable because it is consistent with the guidance provided in GL 91-08 as long as the intent and expectations regarding the exception from TS 3.0.4 (discussed below) are met.
The guidance provided in GL 91-08 and GL 87-09 should not be interpreted to allow containment isolation valves (CIVs) to remain in a degraded condition indefinitely.
CIVs serve a significant safety function in that they establish containment integrity.
Therefore, there is an urgency in returning these valves to an operable status at the earliest possible opportunity.
In general, the staff believes that nuclear plants should start up from an
- outage, e.g.,
a refueling outage, with all CIVs in an OPERABLE condition.
But because of extenuating circumstances, such as unavailability of equipment needed for repair or replacement, or the discovery of inoperable CIVs just prior to startup, there will be isolated instances where allowances will be made for restart with inoperable CIVs.
HoWever, these isolated instances should coexist with the understanding that the inoperable CIV(s) undergo repair or replacement at the earliest possible opportunity in accordance with 10 CFR Part 50, Appendix B.
And the licensee is expected to keep the NRC staff abreast of such isolated instances.
Moreover, in approving the above licensee-proposed change to TS 3/4.6.3, the staff holds the following position which is contained in TS 4.0.4:
Entry into an operational mode or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation has been performed within the stated surveillance interval or as otherwise specified.
3.0 STAT CONSULTATION In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment.
The State official had no comments.
- 4. 0 ENYIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation'xposure.
The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (56 FR 43804).
Accordingly, the 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 be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed
- above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
T. Dunning K. Bristow A. Young N.
Le Date:
November 17, 1992
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