ML18011A191

Application for Amend to License NPF-63,revising TS 3/4.8.1, AC Sources & Associated Bases to Be Consistent W/ NUREG-1431,Rev 0, Sts,Westinghouse Plants.

ML18011A191
Person / Time
Site:	Harris
Issue date:	09/28/1993
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18011A192	List: ML18011A191 ML18011A193
References
RTR-NUREG-1431 HO-930147, NUDOCS 9310060370
Download: ML18011A191 (20)

Text

', '.,'. '-",- ACCELERATE~DOCUMENT DISTRIBI TION SYSTEM

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REGUDA~Y INFORMATION DISTRIBUTI YSTEM (RIDE)

'ACCESSION NBR:9310060370 DOC.DATE: 93/09/28 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400

'UTH. NAME AUTHOR AFFILIATION ROBINSON,W.R. Carolina Power 6 Light Co.

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

SUBJECT:

Application for amend to License NPF-63,revising TS 3/4.8.1, "AC Sources" a associated bases to be consistent w/

NUREG-1431,Rev 0, "STS,Westinghouse Plants."

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SI ZE: I TITLE: OR Submittal: General Distribution (+15'5ooo4oo NOTES:Application for permit renewal filed. A D

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1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1. OC/LFDCB 1 0 OGC/HDS1 1 0 REG FILE Ol 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

D PLEASE HEI P US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESI, ROOM I'1-37 (E>CI'. 504-2065) TO ELIMINATEYOUR NAME FROM DIS'I'RIIIUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

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Carolina Power & Light Company P. O. Box 165 New Hill, NC 27562 SEP 2 8 1995 SERIAL: HNP-93-836 10 CFR 50.90 File: HO-930147 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 AC SOURCES-OPERATING Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CPAL) hereby requests a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP). The proposed amendment revises Technical Specification 3/4.8.1, "A.C. Sources," and associated Bases to be consistent with NUREG-1431, Revision 0, "Standard Technical Specifications, Westinghouse Plants," dated September 1992. Specifically, the proposed, amendment (1) revjses the Action Statements in TS 3/4.8.1 and adds additional Action Statements, (2) provides for slow start testing of the Emergency Diesel Generators (EDGs) and separates the EDG start and load testing into separate requirements, and (3) revises TS Table 4.8-1, Diesel Generator Test Schedule. In addition, Technical Specification 3/4.7.1.2, "Auxiliary Feedwater System," Action Statement c is revised to be consistent with NUREG-1431 by adding a note regarding mode changes while all AFW trains are inoperable. 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.

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NR'C Document Contr eck Page 2 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.

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. Lewis S. Rowell at (919) 362-2287.

Yours very truly, W. R. Robinson General Manager Harris Nuclear Plant LSR:che

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.

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My commission expires: Q$Q So Op c: Mr. D. H. Brown a+ O~

Mr. S. D. Ebneter 'oraav Mr. N. B. Le PUQUC Mr. J. E. Tedrow Coon<

(MEM/HO930147/2/OS1)

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ENCLOS TO SERIAL: HNP-93-836 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AC SOURCES - OPERATING BASIS FOR CHANGE RE UEST

~Back round By letter dated August 6, 1991, Carolina Power & Light Company (CP&L) expressed concerns to the NRC regarding having Emergency Diesel Generators (EDGs) out of service for long periods of time while performing maintenance during plant shutdowns. Subsequently, CP&L has been actively involved in the Transamerica Delaval, Incorporated (TDI) Owners'roup activities focused on removal of license conditions imposed under NUREG-1216. On May 15, 1993, CP&L submitted a Request for License Amendment which proposed to remove license conditions specified by Condition 2.D.(8) and defined in Attachment 1 to Operating License NPF-63 for the Shearon Harris Nuclear Power Plant.

CP&L now proposes to adopt the guidance contained in previous NRC correspondence (Generic Letter 84-15 and Information Notice 84-69) and the new Standard Technical Specifications contained in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants" dated September 1992. The proposed amendment intends to eliminate unnecessary testing and EDG starts, thereby reducing wear and stress on the engines and ultimately improving the overall EDG reliability.

Pro osed Chan e The proposed amendment revises Technical Specification 3/4.8.1, "A.C. Sources,"

and associated Bases to be consistent with NUREG-1431, Revision 0, "Standard Technical Specifications, Westinghouse Plants," dated September 1992.

Specifically, the proposed amendment (1) revises the Action Statements in TS 3/4.8.1 and adds additional Action Statements, (2) provides for slow start testing of the Emergency Diesel Generators (EDGs) and separates the EDG start and load testing into separate requirements, and (3) revises TS Table 4.8-1, Diesel Generator Test Schedule. In addition, Technical Specification 3/4.7.1.2, "Auxiliary Feedwater System," Action Statement c is revised to be consistent with NUREG-1431 by adding a note regarding mode changes while all AFW trains are inoperable.

Basis Deletion of EDG 0 erabilit Verification from Actions a and e The current Standard Technical Specifications and the SHNPP Technical Specifications require operable EDGs to be started and loaded to off-site power to demonstrate their operability in the event of one or both off-site sources becoming inoperable. NUREG-1431, Revision 0 does not require testing of the EDGs in this situation.

Page El-1

ENCLOS TO SERIAL: HNP-93-836 The design of the on-site emergency AC power'system has the EDG isolated from its respective safety bus by a normally open circuit breaker. During plant operation, power to each safety bus is provided by the Unit Auxiliary Transformer (UAT) receiving power from the main generator. The required off-site source is aligned to the associated Start-Up Transformer (SUT) whose output breaker would automatically close within a seven-cycle time period should the UAT output breaker open. When the main generator is not on line, the plant buses receive power from their respective SUT. Thus, the present requirement results in paralleling and loading of the EDG to off-site power via the UAT or the SUT only during tests (special or surveillance). At all other times, the EDG remains isolated from any disturbance or condition that results in degradation or loss of an off-site source. Similarly, NRC Information Notice 84-69 warns against testing of an EDG that requires paralleling to an off-site AC source when off-site sources are threatened by severe weather or are degraded. The cause of an off-site source loss or degradation would in no way affect the reliability of either EDG except during the performance of loaded operations. Since only one EDG is tested at a time, the redundant EDG reliability remains unaffected and the EDG being tested would only be done if no threat or known degradant condition existed. Should events occur that result in the loss of an off-site power source to the SUT and if operating, a loss of the UAT, the associated EDG will already be supplying the safety bus. To require the remaining operable EDG to be tested could result in a loss of the redundant EDG and hence increase the risk of losing all AC power sources to the safety buses.

NRC Generic Letter 84-15 recommends that licensees delete testing of EDGs as a result of other systems or components becoming inoperable to reduce the degradation of the EDGs that occurs during starting. While it is recognized that the occurrence of an inoperable off-site AC source is infrequent, the present Action requirements result in an unnecessary test of the EDGs whose reliability is demonstrated by performance of the required surveillance tests. Additionally, while the proposed change results in only a small reduction in EDG degradation, the reduction in risk of a total loss of AC power to the safety buses or loss of one on-site AC source coincident with a loss of all off-site power sources is significant. Therefore, deletion of the EDG test requirement is prudent since by system design, a common failure mode does not exist and the failure risk of on-site AC sources is reduced.

Chan e to EDG Surveillance Re uirements in Actions b and c The current Standard and SHNPP Technical Specifications require a demonstration that the redundant EDG is operable by paralleling and loading to off-site power if one EDG becomes inoperable or if one EDG and one off-site source is inoperable. NUREG-1431 requires performance of an EDG start test or verification that the cause of the EDG being inoperable is an independent event that does not affect the reliability os the redundant EDG, by performance of visual observation, records review, etc.

C The performance of an EDG start demonstrates the following:

a ~ the ability of the engine starting components to achieve engine speed above minimum speed for fuel ignition;

b. the freedom of the fuel control shafts and linkage to operate through 100% travel; the ability of the engine governor to arrest engine acceleration and stabilize at no-load speed; and, Page El-2

ENCLOS TO SERIAL: HNP-93-836

d. the ability of the generator voltage regulator to arrest the voltage buildup and stabilize at no-load voltage.

Measurement of the time interval between receipt of the start signal to the time EDG no-load voltage and frequency is initially met and the time interval to

, stabilization within the voltage and frequency bands provides a measure of the governor and voltage regulator response characteristic. For the EDGs at SHNPP, the nominal time for both EDGs is 6.5 seconds and 8.0 seconds, respectively.

Engine acceleration is reduced from approximately 100 rpm/second to zero within 0.4 seconds or less when coastdown to 450 (no-load) rpm is commenced. Similarly, the voltage regulator has stopped the voltage buildup of approximately 3000 volts/second within 0.3 to 0.4 seconds and decrease to no-load (6900 V),

condition is in progress. The time interval between start and initial no-load condition effectively monitors the engine starting system, the engine ability to accelerate, the generator field flash capability, and the fuel control linkage freedom of motion. Following engine stabilization, engine fluid temperatures and pressures provide satisfactory verification that the engine auxiliary systems are properly functioning.

No-load operation of the EDG for an extended period of seven days was performed by the vendor during original qualification testing as documented in FSAR Section 8.3.1.1. The results of this test were satisfactory without any abnormal conditions noted during loading of the engine.

Thus, performance of an engine start test per NUREG-1431 is acceptable and will verify the operability of the operable EDG without any degradation of its ability of accept load due to no-load operation. The test performed per the proposed Action requirements would be in addition to, but will not fulfillthe required surveillance test. However, loading of the generator and operating at test load as prescribed would fulfillthe test requirements specified by TS Table 4.8-1.

Verification of 0 erabilit in Actions b and c The inclusion of the verification of operability implements the recommendation of NRC Generic Letter 84-15 and the provisions of NUREG-1431.

The current SHNPP Technical Specifications require testing of the OPERABLE EDG if the other EDG is declared INOPERABLE for any reason other than preplanned preventative maintenance or testing. This condition results in unnecessary testing, should the EDG be declared inoperable due to a system or sub-system component failure in the Emergency Service Water Screenwash System resulting in declaration of the associated Emergency Service Water pump and EDG being declared inoperable. Inoperabilities of EDGs caused by failures of equipment that is not, part of the defined EDG unit are categorized as invalid failures in accordance with Regulatory Guide 1.108. Likewise, component failures within the EDG design boundary that result in intentional or unintentional shutdown of the EDG and.the condition would not have resulted in ultimate failure or would have been bypassed during emergency mode operation are categorized as invalid failures. Thus, this change allows evaluation of whether the cause of the EDG inoperability either does or does not impact the operability of the remaining EDG prior to subjecting the EDG to a test.

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l ENCLOSUPFTO SERIAL: HNP-93-836 The proposed change to allow verification that the cause of an EDG being inoperable does not impact the operability of the redundant EDG will serve to determine the potential for common mode failure without causing unnecessary testing and possible increases in EDG failure due to demand as addressed in Generic Letter 84-15. Since this change does not involve a change to the plant design or operating modes as described in the FSAR, and does not decrease the probability that the EDG will be capable of performing its intended function, this proposed change does not result in any significant increase in the consequences of any accident, nor does it introduce a new or different kind of accident or mode of equipment malfunction or result in any reduction in the margin of safety as defined in the Technical Specifications.

Chan e in Action Time for Action Statement d.l The present Standard and SHNPP Technical Specifications require that, with one EDG inoperable, all required safety equipment that depends on the remaining operable EDG be verified operable within two hours or a plant shutdown must commence. This revision increases this time to four hours to be consistent with NUREG-1431.

This change does not increase the probability of occurrence of any accident analyzed in any FSAR Chapter 15 accident nor does it create a new type of accident because the safety-related components mitigate any accident. The proposed Standard Technical Specifications Bases for a four hour time period is that the probability of a design basis accident occurring in conjunction with another single failure (loss of the associated off-site AC source) has a probability of less than either event considered singularly. Thus, this change increases, on a component basis, the time period that single failure protection for a required component function may be lost; however, the function itself has not been lost.

This increased time interval is also consistent with the Regulatory Guide 1.93 allowance of a limited operating time to determine the cause and restore an inoperable component before subjecting the plant to a risk of loss of all off-site AC sources occurring with an unplanned shutdown, and possibility of grid instability during peak load conditions. Thus, this change will result in an overall decrease in risk to the plant.

Deletion of Off-site Sources Verification in Action Statement f This proposed change is similar to the proposed change in Action Statement "a" in that the reliability and availability of an off-site AC source is not decreased by the inoperability of the associated EDG, the on-site required AC source, due to the independence of the two sources supplying each train of required safety components. This proposed revision does not change the overall actions of plant personnel because Action Statement d is inclusive in this statement since one or more EDGs is inoperable. This proposed change does not change the consequences of any design basis accident nor does it introduce a new or different type of accident or mode of equipment malfunction.

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ENCLOS TO SERIAL: HNP-93-836 Verification of 0 erabilit in Action Statement a This proposed change implements the provision of NUREG-1431 Technical Specification Action Requirement A.2 to declare 'inoperable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> required features with no off-site power available when their redundant required features are inoperable'his addition results in the requirements of Action Statements a and b being consistent in scope should either required AC source become inoperable.

Addition of Action Statement This change implements the provisions of NUREG-1431. This action corresponds to a loss of all redundancy in the required AC power sources and requires plant shutdown to commence within one hour unless one or more sources are restored.

Regulatory Guide 1.93 provides no guidance regarding plant operation should loss of more than two of the required AC sources occur.

Addition of Action Statement h This change implements the provisions of NUREG-1431. This action statement limits continued plant operation for a maximum time of six days, should any combination of required AC sources be inoperable due to a series of contiguous events.

Revision of Surveillance Re uirement 4.8.1.1.2.a.4 The current SHNPP Technical Specification requirement specifies the time requirements for the EDG to reach no-load operating conditions, the time duration of the EDG load run, and the allowable operating band for generator frequency, voltage and load. The proposed revision separates the start and load run criteria into two separate requirements and allows for the diesel engine to be accelerated to no-load conditions at a rate recommended by the engine vendor.

Implementation of a gradual acceleration start (slow start) is recommended by NRC Generic Letter 84-15 and by NUREG/CR-5057 to minimize the stress and wear occurring during rapid acceleration to no-load conditions. These two requirements are 4.8.1.1.2.a.4 and 4 '.1.1.2.a.7 and both must be satisfied to complete the test requirements of Action Statement b. This proposed change is consistent with NUREG-1431.

Presently, the EDGs at SHNPP do not have the capability of being gradually accelerated to no-load conditions. This capability will exist after installation of a plant modification during the upcoming refueling outage. The proposed vendor configuration is similar to the installation on the Enterprise DSRV-20 EDGs at San Onofre Nuclear Generating Station. The proposed SHNPP design only allows a gradual acceleration start for a manual start from either the local or remote control station. In addition, the design has an emergency override capability that will override the fuel limiting cylinder and restore rapid acceleration during engine starting.

The proposed change only allows the ability to perform a gradual acceleration start of the EDG to be valid start for completion of the test requirements. The inclusion of this requirement does not change the consequences of any design basis accident nor does it introduce a new or different type of accident or mode of failure.

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ENCLOSU TO SERIAL'NP-93-836 Revision to Table 4.8-1 Diesel Generator Test Schedule The proposed test schedule implements the recommendations of NUREG-1431. This schedule is based on the studies and analysis performed in conjunction with Regulatory Guide 1.155 and NUMARC 87-00, Revision 1, "Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors." Appendix D of NUMARC 87-00 provides guidance and recommendations to assess the reliability of the EDGs. The probability analysis performed identified that if each EDG has three or less valid failures in the last 25 valid tests (approximately a two year test history), then testing on a monthly basis is sufficient to ensure the EDG will perform its intended function. The proposed test schedule also limits the number of consecutive valid tests, when an EDG has more than three valid failures in the last 25 valid tests, to seven consecutive valid tests. Reduced frequency testing at an interval between every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to seven days until completion of seven consecutive valid tests will provide sufficient assurance that EDG reliability has been restored and that a latent condition affecting reliability does not exist. This schedule also implements the recommendations of NUREG/CR-5057 and Generic Letter 84-15 by reducing the total number of demands. Hence, the wear and stress imposed by the start demand is reduced, improving the overall EDG reliability.

Thus, this test schedule will provide assurance that the EDG reliability is restored and allow EDG test frequency to be increased to at least once every 31 days. This change will improve the EDG reliability since a reduction in wear and stress on the engine power components (crankshaft, pistons, etc.) reduces the probability of an engine component failure. Industry experience has shown that a reduction in start demands does not introduce any new mode of malfunction or create any new or different failure mode.

Revision to S ecification 3.7.1.2 Action c Technical. Specification 3.7.1.2 provides operability requirements for the Auxiliary Feedwater (AFW) System. The AFW System automatically'upplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW System consists of two motor-driven AFW pumps and one steam-driven pump configured into three trains.

The System actuates automatically on low steam generator level, loss of off-site power, safety injection and trip of all feedwater pumps.

If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety-related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that, action be started immediately to restore one AFW train to operable status.

If all three AFW trains are inoperable, the current Technical Specification 3.7.1.2 Action c requires that immediate action be taken to restore one AFW train. This amendment request revises this Action statement so that it is consistent with NUREG-1431, "Standard Technical Specifications for Westinghouse Plants." Specifically, the ACTION statement is modified by adding a note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

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ENCLOS TO SERIAL: HNP-93-836 Conclusions A failure of an Emergency Diesel Generator (EDG) is not an initiator for any Final Safety Analysis Report (FSAR) Chapter 15 accident scenario. Eliminating unnecessary testing and EDG starts reduces the overall demands and wear and stress on the engines and results in greater engine reliability. Therefore, a reduction in EDG starts will not result in an increase in the consequences of any accident previously evaluated.

Although the proposed changes will involve a modification to the EDGs, it is a vendor recommended modification which has been previously demonstrated successfully at the San Onofre Nuclear Generating Station. Further, the proposed modification only alters the manual starting ability and includes a design feature to override the fuel limiting capability and restore rapid acceleration in an emergency demand situation. Therefore, this modification will not introduce the potential for a new failure mode which could affect the ability of the EDGs to perform their design function and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Consistent with the new Standard Technical Specifications for Westinghouse Plants in NUREG-1431, the proposed'changes include an increase in the allowable time (from two hours to four hours) to verify required safety equipment operable.

However, this is an insignificant reduction in the margin of safety and will result in a reduction in risk associated with a possible unplanned shutdown.

The addition of the Note to Technical Specification 3.7.1.2 Action c, ensures that if the unit is in a condition where all three AFW trains are inoperable during power operation, no action would be taken that could cause a potential demand for secondary system heat removal by the AFW System until at least one AFW train is restored to operable status.

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ENCLOS TO SERIAL: HNP-93-836 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AC SOURCES - OPERATING 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 proposed amendment revises Technical Specification 3/4.8.1, "A.C. Sources,"

and associated Bases to be consistent with NUREG-1431, Revision 0, "Standard Technical Specifications, Westinghouse Plants," dated September 1992.

Specifically, the proposed amendment (1) revises the Action Statements in TS 3/4.8.1 and adds additional Action Statements, (2) provides for slow start testing of the Emergency Diesel Generators (EDGs) and separates the EDG start and load testing into separate requirements, and (3) revises TS Table 4.8-1, Diesel Generator Test Schedule. In addition, Technical Specification 3/4.7.1.2, "Auxiliary Feedwater System," Action Statement c is revised to be consistent with NUREG-1431 by adding a note regarding mode changes while all AFW trains are inoperable.

Basis This 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.

A failure of an Emergency Diesel Generator (EDG) is not an initiator for any Final Safety Analysis Report (FSAR) Chapter 15 accident scenario.

Accordingly, there can be no increase in the probability of any accident previously evaluated. Eliminating unnecessary testing and EDG starts reduces the overall wear and stress on the engines, reduces unnecessary engine degradation, and results in a greater overall engine reliability.

Sim'ilarly, addition of the mode change restriction to the AFW Specification is not an initiator for any Final Safety Analysis Report (FSAR) Chapter 15 accident scenario. The restriction ensures that actions are not taken that could force the unit into a less safe condition.

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

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ENCLOS TO SERIAL: HNP-93-836 The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change does not in and of itself result in any change to the plant configuration or operating modes. This change will (1) allow the EDGs to be slowly accelerated during the performance of surveillance tests required every 31 days, and (2) specifically preclude plant configuration or operating mode changes when no AFW trains are available. 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.

Consistent with the new Standard Technical Specifications for Westinghouse Plants (NUREG-1431), the proposed changes include an increase in the allowable time (from two hours to four hours) to verify required safety equipment operable. However, this is an insignificant reduction and will result in a reduction in the risk associated with a possible unplanned shutdown. In addition, the proposed changes include restrictions on plant configuration or operating mode changes when three AFW trains are inoperable. This restriction, which is consistent with the new Standard Technical Specifications for Westinghouse Plants, ensures that actions are not taken that could force the unit into a less safe condition.

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

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ENCLOS TO SERIAL: HNP-93-836 ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AC SOURCES - OPERATING 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 Specification 3/4.8.1, "A.C. Sources,"

and associated Bases to be consistent with NUREG-1431, Revision 0, "Standard Technical Specifications, Westinghouse Plants," dated September 1992.

Specifically, the proposed amendment (1) revises the Action Statements in TS 3/4.8.1 and adds additional Action Statements, (2) provides for slow start testing of the Emergency Diesel Generators (EDGs) and separates the EDG start and load testing into separate requirements, and (3) revises TS Table 4.8-1, Diesel Generator Test Schedule. In addition, Technical Specification 3/4.7.1.2, "Auxiliary Feedwater System," Action Statement c. is revised to be consistent with NUREG-1431 by adding a note regarding mode changes while all AFW trains are inoperable.

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.

The proposed changes do not introduce any new equipment, nor do they 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 offsite.

Page E3-1

ENCLOS TO SERIAL: HNP-93-836 The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

The, proposed changes do not result in additional work or surveillances within radiation controlled areas 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,TO SERIAL: HNP-93-836 ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT AC SOURCES - OPERATING PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e 3/4 7-4 3/4 7-4 3/4 8-1 3/4 8-1 3/4 8-2 3/4 8-2 3/4 8-3 3/4 8-3 3/4 8-4 3/4 8-4 3/4 8-10 3/4 8-10 B 3/4 8-1 B 3/4 8-1 B 3/4 8-2 B 3/4 8-2 B 3/4 8-3 B 3/4 8-3 B 3/4 8-4