ML18010B146

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Application for Amend to License NPF-63,proposing Changes Incorporating AFW Sys TS 3.7.1.2 Surveillance Subparagraph b.1 Revised Capabilities of AFW Initiation Signal
ML18010B146
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 07/26/1993
From: Robinson W
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18010B147 List:
References
HNP-93-821, NUDOCS 9308040169
Download: ML18010B146 (14)


Text

A.CCEI ERAT D DOCUMENT DISTRIBUTION SYSTEM REGULA I INFORMATION DISTRIBUTIOYSTEM (RIDE)

ACCESSION NBR:9308040169 . DOC.DATE 93/07/26 NOTARIZED: YES DOCKET ¹ FACIL:.50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFIL1ATION ROBINSON,W.R. Carolina Power 6 Light'o.

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

SUBJECT:

Application for amend to license NPF-63,proposing changes incorporating AFW sys TS 3.7.1.2 surveillance subparagraph b.l revised capabilities of AFW initiation signal.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: /o+ g 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 LE,N 2 2 INTERNAL: ACRS 6 NRR/DE/EELB 1 1 NRR/DRCH/HICB 1 NRR/DRPW/OTSB 1 1 NRR/DSSA/SPLB 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 =:OB/KFDCB 1 0 OGC/HDS1 REG FILE 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19

@ME Carolina Power & Light Company SERIAL: HNP-93-821 10 CFR 50.90 gUL S6 1893 Letter Number: HO-930120 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 - AUXILIARYFEEDWATER 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 (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).

This proposed Technical Specification change would incorporate into the Auxiliary Feedwater System (AFW) Technical Specification 3.7.1.2, Surveillance Sub-paragraph b.l the revised capabilities of the AFW System design. In addition, the BASES for TS 3.7.1 2 has been updated to incorporate the new

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design capabilities and is included for your information. provides a detailed description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides 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 assessment needs to be prepared in connection with the issuance of the amendment. provides page change instructions for incorporating the proposed revisions. provides the proposed Technical Specification pages.

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

O20076 9308040ih9 930726 PDR ADOCK 05000400 P , PDR

k Document Control Desk HNP-93-821 / Page 2 Carolina Power & Light Company requests approval of the proposed amendment by March 1, 1994 in order to support the next SHNPP refueling outage, currently scheduled to begin in March 1994. 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 of issuance of the amendment.

Please refer any questions regarding this submittal to Mr. D. C. McCarthy at (919) 362-2100.

Yours very truly, W. R. Robinson General Manager - Harris Plant SDC/sdc

Enclosures:

1. Basis for Change Request
2. 10 CFR 50.92 Evaluation
3. Environmental Considerations
4. Page Change Instructions
5. Technical Specification Pages W. R. Robinson, 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.

Notary ( eal)

My commission expires: g-6 9S cc: Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. N. B. Le Mr. J. E. Tedrow

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ENCLOSURE TO SERIAL: HNP-93-821 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AUXILIARYFEEDWATER SYSTEM - FLOW CONTROL VALVE POSITION BASIS FOR CHANGE RE UEST

~Back round The Auxiliary Feedwater System serves as a backup system for supplying feedwater to the secondary side of the steam generators at times when the normal feedwater system is not available, thereby maintaining the heat sink capabilities of the steam generators. The design of the Auxiliary Feedwater System (AFW) ensures that the Reactor Coolant System (RCS) can be cooled down to less than 350'F from normal operating conditions in the event of a total loss of offsite power. Below 350'F the Residual Heat Removal System may be placed into operation for long term decay heat removal.

The AFW System is primarily an emergency system lined up to automatically start in the event of a loss of normal feedwater to the steam generators. As an Engineered Safety Features System, the Auxiliary Feedwater System is directly relied upon to prevent core damage in the event of transients such as.

loss of normal feedwater or a secondary system pipe rupture. In the case of a secondary system line rupture, the AFW System is designed to automatically detect the existence of a steam line or feed line rupture, locate the faulted loop, and isolate flow to the affected steam generator.

The individual AFW branch lines to the steam generators from either the motor-driven or turbine-driven pumps contain a flow control valve (FCV). The FCVs give the operator the capability to control the rate of feedwater flow to each steam generator as dictated by existing plant conditions. Once the syst: em starts, the operator can adjust the feed addition rate to maintain or regain normal operating levels in the steam generators.

The Shearon Harris Nuclear Power Plant (SHNPP) Technical Specifications (TS),

Section 3.7.1.2, Auxiliary Feedwater System, Surveillance 4.7.1.2.1 Sub-paragraph a.3 requires periodic ... "verif[ication] by flow or position check that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position;...". Given the current AFW System design and a conservative reading of the Surveillance requirements, this requires that the FCVs be maintained in the fully open position to support the automatic emergency safety feature function the AFW System provides.

Although the Auxiliary Feedwater System functions as an emergency system, it also serves as an alternate feedwater system during hot standby and cooldown operations whenever conditions are such that shutting down the Main Feedwater System is advantageous. The Auxiliary Feedwater System may also be used to adjust steam generator water levels prior to and during plant start-up and to establish and maintain wet layup conditions in the steam generators. However, Page El-1

I I f ENCLOSURE TO SERIAL: HNP-93-821 the TS Surveillance requirements limit the ability to utilize the AFW System during these operations by requiring the flow control valves to be fully open.

Carolina Power & Light Company will modify during the upcoming refueling outage (RFO ¹ 5) the AFW system control logic for the FCVs inline from the motor-driven AFW pumps to the steam generators so that they will automatically open upon receipt of an AFW initiation signal. Incorporation of this auto-open signal into the control logic for these valves will provide a system design whereby regardless of each valve's position, they will be automatically opened on an AFW initiation signal.

Pro osed Chan e This proposed Technical Specification change would incorporate into the AFW System Technical Specification 3.7.1.2, Surveillance Sub-paragraph b.l the revised capabilities of the AFW System design. In addition, the BASES for TS 3.7.1.2 has been updated to incorporate the new design capabilities and is included for your information.

This proposed amendment involves three specific changes: 1) It incorporates the AFW flow control valve automatic opening feature in periodic surveillance testing, and clarifies in the AFW BASES that given the FCV's auto-open design feature, there is no longer a need or benefit to include these FCVs in the periodic position verification of Surveillance Sub-paragraph b.1; 2) It deletes periodic surveillance testing of the auto-close feature for the AFW motor-driven pump recirculation line valves; 3) It revises the general description of the AFW BASES so that they are more concise and address directly the basis of the surveillance requirements.

Basis The intent of the first change described above, which includes both a plant modification and a revision to the Technical Specifications, is to incorporate auto-open logic features into the AFW flow control valves for the purpose of allowing the Auxiliary Feedwater System to remain fully operable, i.e., fully capable of automatically responding to an auto-start demand, and at the same time be utilized as an alternate to the Main Feedwater System during plant Modes 1, 2 or 3.

The logic of three flow control valves (one valve in each line from the AFW motor-driven pump discharge header to each steam generator) will be modified to provide an automatic open feature which will fully open the valves upon the receipt of any AFW auto start signal.

The auto-open initiation signals being added to the flow control valves are identical to the actuation signals presently utilized to automatically start the AFW motor-driven pumps, thus assuring system ability to maintain steam generator water inventory. Electrical independence of the safety trains will be maintained through the use of isolation cabinets. The newly introduced electrical components will be 1E qualified and identical to those presently utilized to perform protection functions.

Page El-2

ENCLOSURE TO SERIAL: HNP-93-821 The new design will assure isolation of a faulted steam generator in the event of a steam line or main feedwater pipe break. The Auxiliary Feedwater Isolation Signal, which closes the flow regulating valves for isolation purposes, will be configured such that AFW isolation will override AFW actuation. AFW isolation minimizes the effects of feeding AFW to a faulted steam generator and having insufficient flow to the other two intact steam generators. This isolation signal shuts the flow control valves and downstream motor-operated valves'he addition of the auto-open feature to the FCVs does not hinder the ability of the system to provide steam generator isolation.

With the introduction of a safety signal to the logic features of the AFW flow control valves, the subject valves will be considered as Engineered Safety Feature Actuation System components. Surveillance requirements consistent with their purpose are proposed in this amendment request.

The second change described above also involves both a plant modification and a change to the Technical Specifications. It further clarifies the Surveillance Requirements by deleting the automatic closure of the motor-driven AFW pump's recirculation line isolation valves. The automatic closure feature of each motor driven AFW pump recirculation line isolation valve closes a running AFW pump's recirculation valve bus is de-energized.

if the other train's safety The automatic closure feature was added to ensure that an AFW flow rate of 475 gpm for the Loss of Normal Feedwater (LONF) event could be achieved as specified in the FSAR Chapter 15 analysis. Reanalysis of the LONF event has shown that 430 gpm is a satisfactory flow rate~.

Automatic closure of the motor-driven AFW pump recirculation line valves is no longer necessary for the AFW system to achieve the required flow rate.

Therefore, the automatic closure feature on the recirculation valves is being deleted, and the Technical Specification Surveillance Requirements to verify operability of that feature is also being deleted.

Finally, the BASES for the AFW TS has been revised to directly address the basis for AFW System performance, i.e., reference to AFW pump performance curves as opposed to referring to a single system flowrate.'onclusions The proposed Technical Specification changes, and the plant design changes upon which they are based, do not adversely affect the design basis of the AFW System or its ability to function as an Engineered Safety Features System to prevent core damage during FSAR Chapter 15 analyzed transients including loss of main feedwater, steam line rupture, and feedwater line rupture.

License Amendment No. 29, dated September 2, 1992 incorporated the results of the reanalysis regarding the AFW flow delivery rate, i.e., 430 gpm, into Technical Specification 3.7.1.2.

Page El-3

ENCLOSURE TO SERIAL: HNP-93-821 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AUXILIARYFEEDWATER SYSTEM - FLOW CONTROL VALVE POSITION 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 ifnot:

operation of the facility in accordance with the proposed involve a significant increase in the probability or amendment would (1) 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 determination. The bases for this determination are as follows:

Pro osed Chan e This proposed Technical Specification change would incorporate into the Auxiliary Feedwater System (AFW) Technical Specification 3.7.1.2, Surveillance Sub-paragraph b.l the revised capabilities of the AFW System design. In addition, the BASES for TS 3.7.1.2 has been updated.

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.

The proposed changes will not adversely affect system performance. The proposed changes have no effect on the probability of occurrence of an accident previously evaluated since the AFW System is not related to the initiation of any analyzed accident. As an engineered safety system, AFW is required to mitigate those events which result in a decrease in secondary side inventory. With the addition of an auto-open feature, which utilizes the same signals as those which automatically start the motor driven pumps, the ability of the AFW System to maintain the heat sink capabilities of the steam generator is not affected. This project does not reduce system/equipment redundancy or independence nor does it have detrimental effects on single failure considerations. Likewi'se, the deletion of testing the auto-close feature on the AFW pump recirculation line isolation valves has no impact on the AFW System's ability to perform at its design functions.

Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

Page E2-1

ENCLOSURE TO SERIAL: HNP-93-821 The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

As stated above, the proposed changes will not adversely affect system performance. No new failure mechanisms are introduced by this change request. This request does not introduce equipment or system operating parameters, configurations, or conditions that are not bounded by current FSAR assumptions. The fail-safe position of the FCVs both before and after the logic change is open. Failure of the control logic to the flow control valves will cause the valves to fail to the open position, providing full flow to the steam generators.

Therefore, the proposed changes do 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 changes described herein do not affect any safety limit and/or limiting safety system setting as governed by the Technical Specifications. The margin of safety for the AFM System as described in the BASES to Technical Specification 3.7.1.2 is not reduced as the pump capacities and the ability to perform a plant cooldown are not affected.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Page E2-2

ENCLOSURE TO SERIAL: HNP-93-821 ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AUXILIARYFEEDWATER SYSTEM - FLOW CONTROL VALVE POSITION 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 environme'ntal 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; (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 This proposed Technical Specification change would incorporate into the Auxiliary Feedwater System Technical Specification 3.7 '.2, Surveillance Sub-paragraph b.l the revised capabilities of the AFW System design. In addition, the BASES for TS 3.7.1.2 has been updated.

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.

None of the changes to plant systems or the Technical Specifications have any direct effect on the effluent types generated or potential release mechanisms. 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.

None of the changes to plant systems or the Technical Specifications have any direct effect on occupational exposure. The changes to the plant are predominately within the instrumentation and control circuitry which are generally in areas remote from radiation sources. The changes Page E3-1

ENCLOSURE TO SERIAL: HNP-93-821 to Technical Specification Surveillance requirements themselves will have no impact on occupational radiation exposure.

Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

Page E3-2

ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AUXILIARY FEEDWATER SYSTEM - FLOW CONTROL VALVE POSITION PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e 3/4 7-5 3/4 7-5 B 3/4 7-1 B 3/4 7-1 B 3/4 7-2 B 3/4 7-2