ML18011A132

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Application for Amend to License NPF-63,revising TS 2.1.1, 2.2.1,3.1.1,3.2.5,3.9.1,5.4.2 & Associated Bases Re Cycle 6 Fuel Transition
ML18011A132
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 08/27/1993
From: Habermeyer H
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18011A133 List:
References
GLS-93-839, NUDOCS 9309070277
Download: ML18011A132 (19)


Text

ACCELERATE DOCUMENT DIST IBUTION'SYSTEM gin REGULE Y'NFORMATION DISTRIBUTI SYSTEM (RIDS) it ACCESSION NBA:9309070277 DOC.DATE: 93/08/27 NOTARIZED: YES DOCKET ¹ FACIL:S0t-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION HABERMEYER,H.

Carolina Power a Light Co.

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

SUBJECT:

Application for amend to License NPF-63,revising TS 2.1.1, 2.2.1,3.1.1,3.2.5,3.9.1,5.4.2 a associated bases re Cycle 6

fuel transition.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED:LTR I

ENCL /

SIZE:

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

05000400 RECIPIENT ID CODE/NAME

';PD2-1.,LA LE,N INTERNAL: ACRS NRR/DORS/OTSB NRR/DRPN NRR/DSSA/SRXB OC DCB REG FILE 01-EXTERNAL: NRC PDR COPIES LTTR ENCL 1

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2 6

1 1

1 1

1 1

1 0

1 1

RECIPIENT ID CODE/NAME PD2-1 PD NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT OGC/HDS1 NSIC COPIES LTTR ENCL 1

1 1

1 1

1 1

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. NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE H LP US TO REDUCE WASTE! CONTACf THE DOCUMENT CONTROL DESK, ROOM Pl-3i (EXT. 504-2065) TO ELIh4INATE YOUR NAhIE FROM DISTRIIIUTION LISTS FOR DOCUMENTS YOU DON"fNEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 22 ENCL 20

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ie CML Carolina Power 8 Light Company P.O. Bex 1551

~ Raleigh, N.C. 27602 H.W. HABERMEYER,JR.

Vice President Nuclear Services Department ti'AUG 37 )993 SERIAL:

GLS-93-839 10 CFR 50.90 Letter Number:

HO-930146 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 CYCLE 6 FUEL TRANSITION - ADDITIONALCHANGES 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).

The proposed amendment revises Technical Specifications 2.1.1, 2.2.1, 3.1.1, 3.2.5, 3.9.1, 5.4.2 and associated BASES.

The changes result from the transition from nuclear fuel supplied by Westinghouse to nuclear fuel supplied by Siemens Power Corporation beginning with Cycle No.

6 and an RCS average temperature reduction effort.

Specifically, the proposed changes will incorporate changes to reactor core safety limits, reactor trip system instrumentation setpoints, power distribution limits, and shutdown Boron concentration control to support the transition.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 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.

Enclosure 3 provides 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'1.22(b),

no environmental assessment needs to be prepared in connection wit:h the issuance of the amendment.

Enclosure 4 provides page change instructions for incorporating the proposed revisions.

Enclosure 5 provides the proposed Technical Specification pages.

9309070277, 930827 PDR'DOCK 05000400 P

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Document Control Desk HNP-93-839 / Page 2

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.

CP&L 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 amendment, 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, H.

W. Habermeyer, J

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 H. W. Habermeyer, Jr., 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 TO SERIAL:

HNP-93-839 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 6 FUEL TRANSITION - ADDITIONALCHANGES BASIS FOR CHANGE RE UEST

~Back round Starting with Cycle No.

6, the Shearon Harris Nuclear Power Plant (SHNPP) will begin transitioning from nuclear fuel supplied by Westinghouse Electric Corporation to nuclear fuel designed and fabricated by Siemens Power Corporation (SPC).

The transition will span 5 fuel cycles.

Cycles 6 through 10 will have a mixed fuel core of varying composition during the transition.

The SPC-designed fuel will be supported by SPC design methodology, while the Westinghouse fuel (such as allowed peaking and burnup limits) will continue to be supported by the original Westinghouse calculations.

The transition to SPC fuel will require Technical Specification changes in the following areas:

reactor core safety limits, reactor trip system instrumentation setpoints, power distribution limits, shutdown Boron concentration control, and Core Operating Limits Report (COLR) references.

CP6L submitted part of the Cycle No.

6 Technical Specification changes on July 16, 1993 (HNP-93-826).

As discussed at a meeting between CP&L and the NRC in White Flint, Maryland on April 22, 1993 and at SHNPP on June 28,

1993, the changes submitted in the July amendment request are proposed references to NRC-approved methodologies and methodologies which are currently under review by the NRC for approval~.

The remainder of the plant-specific changes are included in this submittal.

Pro osed Chan e

The proposed amendment revises Technical Specifications 2'.1, 2.2.1, 3.1.1, 3.2.5, 3.9.1, 5.4.2 and associated BASES.

The changes result from the transition from nuclear fuel supplied by Westinghouse to nuclear fuel supplied by Siemens Power Corporation beginning with Cycle No.

6 and an RCS average temperature reduction effort.

Specifically, the proposed changes will incorporate changes to reactor core safety limits, reactor trip system instrumentation setpoints, power distribution limits, and shutdown Boron concentration control to support the transition.

The changes proposed in this amendment request are outlined in the attached table.

Reference:

CPGL Letter to USNRC, July 16, 1993 (HNP-93-826),

"Request for License Amendment

- Cycle 6 Fuel Transition" enclosed change pages to Specification 6.9.1.6.2 Items 1, m and n.

Page El-1

ENCLOSURE TO SERIAL:

HNP-93-839 Summary of Technical Specification Changes Technical S ecification

~Chan e

Reason for the Chan e

2.1.1 Reactor Core

- Safety Limits Figure 2.1-1 and BASES Revise Reactor Core Safety Limits Incorporate analyses using DNB correlation for Siemens fuel.

2.2.1 Limiting Safety Systems Settings-Reactor Trip System Instrumentation Trip Setpoints Table 2.2-1, Functional Unit:

7. Overtemperature AT
8. Overpower AT and BASES T'

588.8'F to T'

580.8'F q~-qb exceeds

+6.0%

to qt-qb exceeds

+12.0%

T S 588.8'F to T ~ 580.8'F Program to reduce primary coolant average temperature Reduce potential of invoking OTAT fz(bl) function during normal operation.

Program to reduce primary coolant average temperature 3.1.1.3 BASES, Reactivity Control Systems-Moderator Temperature Coefficient Remove references to MDC used by Westinghouse.

Incorporate Siemens use of MTC.

3.2.5 Power Distribution Limits DNB Parameters and BASES T~, ~ 594.1'F to Program to reduce primary coolant average temperature 3.9.1 Refueling Operations-Boron Concentration Add conditions to open Boric Acid Batch Tank outlet valve Ensure consistency within the Specification and with accident analyses for Cycle 6 operations.

5.4.2 Design Features-RCS Design Volume T~~ of 588.8'F to T,~, of 580.8'F Program to reduce primary coolant average temperature Page El-2

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ENCLOSURE TO SERIAL:

HNP-93-839 Basis The proposed changes are discussed below in three segments:

a)

Those changes related to the Transition core, b)

Those changes related to efforts to reduce the primary coolant average temperature, and c)

Changes related to shutdown boron concentration control.

a)

Transition Core Related Changes The reactor fuel supplied by Siemens (HTP) is somewhat different from that supplied by Westinghouse (LOPAR and Vantage5) with respect to thermal, hydraulic, and neutronic characteristics.

Also, the methodologies used by Siemens to evaluate the accidents postulated in the Final Safety Analysis Report (FSAR) are different from the methodologies used by Westinghouse.

The Technical Specifications and BASES have been revised to reflect the transition differences as follows:

Technical S ecification 2.1.1 Fi ure 2.1-1 "Reactor Core Safet Limits-Three Loo s in 0 eration" Figure 2.1-1 (Page 2-2) provides a series of curves which define the limiting combinations of thermal power, Reactor Coolant System pressure, and average temperature below which the calculated DNBR is no less than the design DNBR value and the average enthalpy at the vessel exit is less than the enthalpy of saturated liquid.

The existing Figure 2.1-1 was developed by Westinghouse for a core composed of only Westinghouse fuel assemblies.

These curves have been revised for the Cycle 6 core which is composed of both Siemens HTP and Westinghouse Vantage 5 and LOPAR fuel assemblies.

In all cases the curves on the revised figure are more restrictive than those on the existing figure.

As

such, the revised figure bounds the Siemens assemblies and any Westinghouse assemblies which might be used in future core designs.

The new set of reactor safety limit curves have been established for the transition core using Siemens HTP correlations.

An explanation of the HTP correlation is given in Item m of the previous Cycle 6 Transition Technical Specification Change Request~.

The BASES-associated with this Specification have also been revised to reflect the use of a transition core, the use of Siemens methodologies and the Safety Limit curves are based on limiting or bounding axial power shapes.

The discussion of employing' statistical combination method to establish the "DNBR Uncertainty" used in the Westinghouse methodologies has been deleted because Siemens methodologies do not compute such an uncertainty.

Page El-3

ENCLOSURE TO SERIAL:

HNP-93-839 Technical S ecification 2.2.1 Table 2.2-1 "Reactor Tri S stem Instrumentation Tri Set pints" The Trip Setpoints have been selected to ensure that the core and Reactor Coolant System are prevented from exceeding their Safety Limits during normal operation and design basis anticipated operational occurrences and to assist the Engineered Safety Features Actuation System in mitigating the consequences of accidents.

Table 2.2-1 Functional Item 7,

Overtemperature AT trip (OTAT) provides core protection to prevent DNB for specified combinations of pressure, power, coolant temperature, and axial power distribution.

One component of the OTET trip setpoint, the f(AI),

reduces the OTAT setpoint for axial power distributions that fall outside a specified deadband.

The upper limit of the f(AI) function deadband associated with the OTAT Reactor Trip function has been changed from +6.0 to

+12.0 percent.

Siemens methodologies allow for a larger range of operating Axial Flux Distributions (AFDs) than Westinghouse methodologies.

As such, actual operating GIs may be between

+6.0 and +12.0 at the beginning of cycle.

The deadband was increased to ensure that the difference between the setpoint and actual AT does not narrow for AFDs that may be experienced during normal operation of the plant.

Reducing the difference between the setpoint and actual AT would result in less margin to an inadvertent trip caused by spurious temperature or pressure signals.

Siemens used the methodologies described in the previous Cycle 6 Transition Technical Specification Change Request Items b and 1 to verify that the revised OTAT function adequately mitigates applicable events.

The BASES statements on Page B 2-4 associated with Table 2.2-1 Items 3 &

4, Power range neutron flux high positive and low negative rate trips, has been revised to delete the statement that no credit will be taken for the negative flux rate trip.

The Siemens analysis will take credit for the negative flux rate trip.

The negative flux rate trip is required to be operable by Technical Specifications Table 2.2-1 Item 4 and Table 3.3-1 Item 4.

The BASES statements on Page B 2-5 associated with Table 2.2-1 Item 8, Overpower AT (OPAT), have been revised to delete the reference to WCAP-9226 (a Westinghouse study of the Reactor Core

Response

to Excessive Secondary Steam Releases).

Siemens does not taken credit for this trip function in the analyses of excessive secondary steam releases since OPAT is not a primary mitigating trip for these events.

Technical S ecification BASES 3.1.1.3 "Moderator Tem erature Coefficient" The BASES statements on Page B 3/4 1-2 describe an approach used by Westinghouse to determine the most negative MTC based on its relationship to MDC.

The description has been deleted since it refers to an approach Page El-4

ENCLOSURE TO SERIAL:

HNP-93-839 that Siemens does not use.

Siemens uses Moderator Temperature Coefficient (MTC) rather than Moderator Density Coefficient (MDC) in its analytical models.

b)

T,z Reduction Related Changes The Shearon Harris Nuclear Power Plant (SHNPP) has undertaken a effort to reduce the average coolant temperature in the reactor coolant system for Cycle 6 in order to extend the service life of the steam generators.

The T,~ reduction affects the initial conditions assumed in the accident analyses.

The reduction in nominal T~~ at Rated Thermal Power from 588.8 F to 580.8 F will provide additional margin to DNB.

Various Technical Specifications have been revised to incorporate the lower Tzzg to ensure the analytical results of DNBR events better represent the actual margin to DNB.

These Technical Specifications are as follows:

Technical S ecification 2.2.1 Table 2.2-1 Reactor Tri S stem Instrumentation Set pints" The Trip Setpoints have been selected to ensure that the core and Reactor Coolant System are prevented from exceeding their Safety Limits during normal operation and design basis anticipated operational occurrences and to assist the Engineered Safety Features Actuation System in mitigating the consequences of accidents.

The Actual T,~ and T,~ at Rated Thermal Power (T'nd T)

are input parameters used to determine the Overtemperature AT trip (OTAT) and Overpower AT (OPAT) trip setpoints.

OTAT (Table 2.2-1 Functional Item 7) provides core protection to prevent DNB for specified combinations of pressure,

power, coolant temperature, and axial power distribution.

OPAT (Table 2.2-1 Item 8) provides core protection against fuel melt and cladding strain for specified combinations of temperature, and axial power distribution.

The Trip setpoint for OTAT (see Note 1 on page 2-4 and page 2-8) has been changed to reflect the T,~z reduction.

The value of T'n the OTAT function has been reduced from 588.8 'F to 580.8 F to reflect the change in nominal T~~ at Rated Thermal Power.

The OTAT function will be more responsive to adverse conditions (high T,~) at the revised T'han at the existing T'ecause it is closer to the new nominal T,~.

As such, this change improves DNBR margin for those events mitigated by the OTAT trip.

The trip setpoint for OPAT (see Note 3 on page 2-4 and page 2-10) has been changed to reflect the T~~~ reduction.

The value of T" in the OPAT function has been reduced from 588.8 'F to 580.8 F to reflect the change in nominal T,~ at Rated Thermal Power.

The OPAT function will be more responsive to adverse conditions (high T,z) at the revised T than at the existing T because it is closer to the new nominal T,z.

As such, this change improves margin to fuel melt and cladding strain for those overpower events mitigated by the OPAT trip.

Page El-5

ENCLOSURE TO SERIAL:

HNP-93-839 Technical S ecification 3.2.5 "DNB Parameters" Technical Specification 3.2.5.a (page 3/4 2-14 and B 3/4 2-6) establishes the limiting initial T ~ used in the analysis of events which have DNBR as an acceptance criteria.

The T,~z limit specified by T.S. 3.2.5.a and the BASES have been revised from 594.1 'F to 586.1 F to reflect the 8

F reduction in nominal T~~.

The difference between limit and nominal Tzpg (5.3 F) remains the same.

This 5.3 'F is the maximum predicted difference between controlled and reference T,~ at Rated Thermal Power.

The revised limit will produce analytical results which more realistically predict DNBR margin available than the existing limit.

Technical S ecification 5.4.2 Reactor Coolant S stem Desi n Features Volume The Design Features Specification 5.4.2 (Page 5-6) has been revised to reflect the reduced value of T,~z.

c)

Shutdown Boron Concentration Control Technical Specification 3.9.1, Refueling Operations

- Boron Concentration, places limitations on reactivity conditions during refueling (Mode 6

operations) to ensure that: (1) the reactor will remain subcritical during core alterations, and (2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel.

The LCO requires that the greater of two minimum boron concentration conditions be maintained, a concentration to maintain Kgff'ess than or equal to 0.95 as specified in the Core Operating Limits Report (COLR), or a concentration of greater than or equal to 2000 ppm.

Specification 3.9.1.b requires that the valves listed in Table 3.9-1, "Administrative controls to Prevent Dilution During Refueling", shall be in their positions required by the Table.

Valve 1CS-510, which in the outlet line of the Boric Acid Batch Tank, is required to be locked closed unless the boric acid tank boron concentration is h 2000 ppm.

This amendment request revises the conditions under which valve 1CS-510 may remain open so that it more fully reflects the LCO and Action Statement requirements for minimum boron concentration in the RCS and refueling canal.

This revision would replace the "h 2000 ppm" with "the greater of 2000 ppm or the boron concentration required to maintain Kgff less than or equal to 0.95, as specified in the COLR."

The addition of the wording to Table 3.9-1 eliminates the potential during Cycle 6 operations for a

"dilution" path from the boric acid batch tank to the RCS when the RCS is required to be at a minimum concentration greater than 2000 ppm.

This potential did not exist in previous cycles because the boron concentration necessary to maintain k,<< less than or equal to 0'5 has always been less than or equal to 2000 ppm.

Page El-6

ENCLOSURE TO SERIAL:

HNP-93-839 ENCLOSURE 2

SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 6 FUEL TRANSITION - ADDITIONALCHANGES 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 ifoperation 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 proposed amendment revises Technical Specifications 2.1.1, 2.2.1, 3.1.1, 3.2.5, 3

~ 9

~ 1, 5.4.2 and associated BASES.

The changes result from the transition from nuclear fuel supplied by Westinghouse to nuclear fuel supplied by Siemens Power Corporation beginning with Cycle No.

6 and an Reactor Coolant System average temperature reduction effort.

Specifically, the proposed changes will incorporate changes to reactor core safety

limits, reactor trip system instrumentation setpoints, power distribution limits, and shutdown Boron concentration control to support the transition.

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.

a)

The Reactor Core Safety Limits lines of Figure 2.1-1 provide the limits on T,~ and pressure which protect against DNB and hot leg saturation.

These lines incorporate the results of analyses with both Siemens and Westinghouse DNB correlations.

The revisions of these lines do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The lines are explicitly determined to provide the limits to protect against DNB and hot leg saturation.

There is no change to the system, thus the accident precursors are unaffected.

Therefore, there is no increase Page E2-1

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ENCLOSURE TO SERIAL:

HNP-93-839 in the probability of an accident previously evaluated.

Because the limits are established to protect to the same criteria, there is no increase in the consequences of the accidents previously evaluated.

The expanded OTAT deadband limits in this table reduce the potential of invoking the f~(AI) function during normal operation.

the revised OTAT fz(AI) setpoints have been incorporated in the plant analyses supporting Cycle 6 operation.

Based on these analyses, the revision of this table does not involve a significant increase in the probability of consequences of an accident previously evaluated.

The system is unchanged by this amendment, so the precursors to the accidents are unchanged.

The revised setpoints were incorporated in the safety analyses.

The results of these evaluations demonstrate compliance with the criteria identified in Chapter 15 of the Standard Review Plan (NUREG-0800).

b)

The average coolant temperature is a boundary condition used in the plant neutronic and safety analyses.

Siemens Power Corporation has incorporated the reduced Tzpg in the plant analyses supporting Cycle 6 operation.

Based on these

analyses, the reduction does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The reduction in temperature does not change precursors that could cause any of the accidents previously evaluated.

Therefore, the probability of the event is unchanged.

The consequences of all of the accidents which are sensitive to the temperature reduction are evaluated by Siemens Power Corporation using their reload analysis methodologies.

The results of these evaluations demonstrate compliance with the criteria identified in Chapter 15 of the Standard Review Plan.

Therefore, there is not an increase in the consequences of an accident previously evaluated.

c)

The addition of wording to Table 3.9-1 (valve 1CS-510) to reference the COLR required refueling boron concentration has no effect on the consequences of accidents previously evaluated in the FSAR.

The change places more restrictive conditions on the boric acid batch tank boron concentration before the tank discharge valve may be opened.

The additional conditions reduce the probability of an accident previously evaluated in the FSAR (boron dilution accident in Mode

6) if the required refueling boron concentration is in excess of 2000 ppm.

It has no impact on the probability of a dilution accident if the required refueling boron concentration is equal to 2000 ppm.

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

Page E2-2

ENCLOSURE TO SERIAL:

HNP-93-839 The proposed amendment does not create the possibility of a

new or different kind of accident from any accident previously evaluated.

a)

The Reactor Core Safety Limits lines of Figure 2.1-1 provide the limits on T,~ and pressure which protect against DNB and hot leg saturation.

These lines incorporate the results of analyses with both Siemens and Westinghouse DNB correlations.

The revisions of these lines do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Because the system is unchanged, the precursors to any accidents are unchanged.

Therefore, the possibility of a new or different kind of accident from those previously evaluated is not changed.

The expanded OTAT deadband limits in this table reduce the potential of invoking the f>(BI) function during normal operation.

the revised OTAT f~(AI) setpoints have been incorporated in the plant analyses supporting Cycle 6 operation.

Based on these analyses, the revision of this table does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Because the system is unchanged for fuel related accidents, the possibility of a new or different kind of accident from any fuel related accident previously evaluated is unchanged.

b)

The average coolant temperature is a boundary condition used in the plant neutronic and safety analyses.

Siemens Power Corporation has incorporated the reduced T,~ in the plant analyses supporting Cycle 6 operation.

Based on these analyses, the reduction does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Because the precursors are unchanged for fuel related accidents, the possibility of a new or different kind of accident from any fuel related accident previously evaluated is unchanged.

c)

The addition of wording to Table 3.9-1 to reference the COLR required refueling boron concentration does not create the possibility of a new accident than any previously evaluated in the FSAR.

This TS change will eliminate the possibility of a dilution path in Mode 6 with the required refueling boron concentration in excess of 2000 ppm.

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.

a)

The Reactor Core Safety Limits lines of Figure 2.1-1 provide the limits on T, s and pressure which protect against DNB and hot leg Page E2-3

ENCLOSURE TO SERIAL:

HNP-93-839 saturation.

These lines incorporate the results of analyses with both Siemens and Westinghouse DNB correlations.

The revisions of these lines do not involve a significant reduction in the margin of safety.

The limits should be changed to incorporate the DNB characteristics of the Siemens fuel as well as the Westinghouse fuel.

The limits are explicitly determined using the same criteria as before.

Therefore, there is no significant reduction in the margin of safety.

The expanded OTAT deadband limits in this table reduce the potential of invoking the f>(AI) function during normal operation.

The revised OTAT f~(bl) setpoints have been incorporated in the plant analyses supporting Cycle 6 operation.

Based on these analyses, the revision of this table does not involve a significant reduction in the margin of safety.

The revised OTAT setpoint is incorporated in the safety evaluations.

These evaluations must satisfy the criteria defined in Chapter 15 of the Standard Review Plan consistent with the SHNPP licensing basis as defined in the FSAR.

Because the criteria are unchanged, there is not a significant reduction in the margin of safety.

b)

The average coolant temperature is a boundary condition used in the plant neutronic and safety analyses.

Siemens Power Corporation has incorporated the reduced T,~ in the plant analyses supporting Cycle 6 operation.

Based on these

analyses, the reduction does not involve a significant reduction in the margin of safety.

The reduction in temperature is explicitly included in the safety evaluations.

These evaluations must satisfy the criteria defined in Chapter 15 of the Standard Review Plan consistent with the SHNPP licensing basis as defined by the FSAR.

Because the criteria are unchanged, there is not a significant reduction in the margin of safety.

c)

The addition of wording to Table 3.9-1 to reference the COLR required refueling boron concentration does not reduce the margin of safety since the TS requirement on valve position will have a more restrictive condition than currently exists.

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

Page E2-4

ENCLOSURE TO SERIAL:

HNP-93-839 ENCLOSURE 3

SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 6 FUEL TRANSITION - ADDITIONALCHANGES 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 offsite; (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 needs to be prepared in connection with the issuance of the amendment.

The basis for this determination follows:

Pro osed Chan e

The proposed amendment revises Technical Specifications 2.1.1, 2.2.1, 3.1.1, 3.2.5, 3.9.1, 5.4.2 and associated BASES.

The changes result from the transition from nuclear fuel supplied by Westinghouse to nuclear fuel supplied by Siemens Power Corporation beginning with Cycle No.

6 and an Reactor Coolant System average temperature reduction effort.

Specifically, the proposed changes will incorporate changes to reactor core safety

limits, reactor trip system instrumentation setpoints, power distribution limits, and shutdown Boron concentration control to support the transition.

Basis The change meets the eligibilitycriteria 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.

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 Page E3-1

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ENCLOSURE TO SERIAL'NP-93-839 require existing 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 off-site.

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

The proposed revisions do not result in changes to Technical Specification surveillance requirements and do not affect personnel radiation exposure.

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

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ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 6 FUEL TRANSITION - ADDITIONALCHANGES PAGE CHANGE INSTRUCTIONS Removed Pa e

2-2 2-8 2-10 B 2-1 B 2-la B 2-4 B 2-5 3/4 2-14 3/4 9-2 B 3/4 1-2 B 3/4 2-6 5-6 Inserted Pa e

2-2 2-8 2-10 B 2-1 B 2-la B 2-4 B 2-5 3/4 2-14 3/4 9-2 3/4 9-2a B 3/4 1-2 B 3/4 2-6 5-6