HNP-95-067, Provides Addl Info in Support of 950405 License Amend Request Re Refueling Operations Section 3/4.9 of Shnpp TS
| ML18011A968 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/31/1995 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18011A969 | List: |
| References | |
| HNP-95-067, HNP-95-67, HO-950649, NUDOCS 9508040049 | |
| Download: ML18011A968 (8) | |
Text
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ACCESSION NBR:9508040049 DOC.DATE:.95/07/31 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION ROBINSON,W.R.
Carolina Power
& Light. Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400 P
SUBJECT:
Provides addi info in support of 950405 license amend request re refueling operations section 3/4.9 of SHNPP TS.
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(
CRISE Carolina Power &Light Company PO Box 165 New Hill NC 27562 JUL 5 t
1995 File: HO-950649 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 SHEARON HARRIS NUCLEARPOWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS SUPPLEMENTALINFORMATION William R. Robinson Vice President Harris Nuclear Plant Serial: HNP-95-067 10 CFR 50.36(a)
Gentlemen:
By letter dated April5, 1995, Carolina Power & Light Company (CP&L) submitted a Request for Liccnsc Amendmcnt to the NRC relative to the Refueling Operations Section 3/4.9 of Shcaron Harris Nuclear Power Plant Tcchnical Specifications (TS). The proposed revision would provide consistency with NUREG-1431, thc new Standard Tcchnical Specifications for Westinghouse Plants. During subsequent telephone conversations between CP&L and thc NRC staff, CP&Lwas rcqucstcd to provide additional tcchnical information related to the relocation of Refueling Operations TS 3/4.9.3, "Decay Time," 3/4.9.5, "Communications," 3/4.9.6, "Refueling Machine," and 3/4.9.7, "Crane Travel - Fuel Handling Building."
The Enclosure to this letter provides the requested information.
The staff also requested that the Bases Section for LimitingCondition for Operation (LCO) 3/4.9.1, "Boron Concentration" include a clarifying statement explaining that thc basis for required boron concentrations is to ensure that reactor core K,z remains c 0.95 during refueling operations.
This change was incorporated as discussed verbally with the NRC staff and is marked accordingly on the revised TS page attached.
CP&L's 10 CFR 50.92 Evaluation submitted on April5, 1995 remains valid and is unaffected by the submittal ofthc enclosed supplcmcntal information.
Questions regarding this matter may be rcferrcd to Mr. T. D. Walt at (919) 362-2711.
Sincerely, MV Enclosure 9508040049 95073i PDR ADQCK 05000400 P
PDR Mycommission expires:
W. R. Robinson, having bccn first duly sworn, did depose and say that thc information contained herein is true and correct to the best of his information, knowledge and belief; and that thc sources of his information are offiiccrs, cmployecs, contractors, and agents ofCarolina Power &Light Company.
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Document Control Desk HNP-95-067 / Page 2 c:
Mr. S. D. Ebncter (NRC-RII)
Mr. S. A. Elrod (NRC-SHNPP)
Mr. N. B. Le (NRR)
Enclosure to Serial: HNP-95-067 Page 1 of3 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT 3/4.9 REFUELING OPERATIONS
1.0 INTRODUCTION
By letter dated April5, 1995, Carolina Power 2 Light Company (CP&L)submitted a rcqucst for changes to the Shearon Harris Nuclear Power Plant (SHNPP) Tcchnical Specifications (TS): The proposed amendment utilized the guidance provided in NUREG-1431, the new Standard Tcclinical Specifications for Westinghouse Plants and willallow for the relocation ofRefueling Operations TS 3/4.9.3, "Decay Time,"
3/4.9.5, "Communications," 3/4.9.6, "Rcfucling Machine," and 3/4.9.7, "Crane Travel - Fuel Handling Building." The purpose of this letter is to provide supplemental information to address NRC Staff questions communicated subsequent to the April5, 1995 submittal.
Section 182a ofthc Atomic Energy Act (the Act) rcquircs that TS be included as part ofa licensee's nuclear power plant operating license.
The Commission's regulatory requirements related to the content ofthe TS are sct forth in 10 CFR 50.36. That regulation rcquircs that thc TS include items in five specific categories including: (1) safety limits, limitingsafety system settings and limitingcontrol settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
Italso states that thc Commission may include such additional TS as it finds appropriate.
However, the regulation does not specify the particular TS to be included in a plant's license.
Thc Commission has provided guidance for the contents ofTS in its "Final Policy Statement on Tcchnical Specification Improvements for Nuclear Power Reactors" (Final Policy Statement), issued on July 22, 1993 (58 FR 39132), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a ofthe Act. In particular, thc Commission indicated that certain items could bc relocated from the TS to liccnsec-controlled documents, and consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whcthcr a particular matter is required to bc included in thc TS, as follows: (1) installed instrumentation that is used to detect, and'indicate in thc control room, a significant abnormal degradation ofthe reactor coolant prcssure boundary; (2) a process variable, design fcaturc, or operating restriction that is an initialcondition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, thc integrity ofa fission product barrier; (3) a structure, system, or component that is part ofthe primary success path and which functions or actuates to mitigate a design basis accident or transient that cithcr assumes thc failure ofor presents a challenge to the integrity ofa fission product barrier; (4) a structure, system, or component which operating cxpcricncc or probabilistic safety assessment has shown to be significant to public health and safety.
As a result, thc existing LimitingCondition for Operation (LCO) requirements that fallwithin or satisfy any ofthc criteria in the Final Policy Statcmcnt should bc retained in the TS, while those LCO requircmcnts which do not fall within or satisfy these criteria may be relocated to other appropriate licensee-controlled documents.
2.0 EVALUATION In Novcmbcr 1987, thc Westinghouse Owners Group submitted to the NRC, WCAP-11618, "Methodically Engineered, Restructured and Improved Tcchnical Specifications, MERITS Program - Phase IITask 5, Criteria Application." That topical rcport applied thc Commission's scrccning criteria to thc Westinghouse Standard Tcchnical Specifications (NUREG-0452, Revision 4 and DraA Revision 5). The NRC staff documented the results oftheir review ofWCAP-11618 in a Icttcr dated May 9, 1988 to R. A. Newton, Chairman ofthe Westinghouse Owners Group. Among thc Specifications to which thc screening criteria were applied werc Standard TS Sections 3/4.9.5, "Communications," 3/4.9.6, "Refueling Machine" and 3/4.9.7, "Crane Travel - Fuel Handling Building." TS 3/4.9.5 rcquircs communication between the control room and thc rcfucling station in containmcnt, to cnsurc that any abnormal change in the facilitystatus observed on the control room instrumentation can bc communicated to thc refueling station pcrsonncl.
TS 3/4.9.6 cnsurcs that the liAingdevice on thc manipulator crane has adequate capacity to liR thc weight ofa fuel assembly and a rod control cluster assembly (RCCA), and that an automatic load limitingdcvicc is
nclosurc to Serial: HNP-95-067 Page 2 of3 available.to prevent damage to thc fuel assembly during fuel movcmcnt. This specification also ensures that the auxiliary hoist on the manipulator crane has adequate capacity for latching and unlatching control rod drive shaAs. TS 3/4.9.7 ensures that loads in excess ofone fuel assembly containing a RCCA, plus the weight ofthe fuel handling tool, willnot be moved over other fuel assemblies stored in thc spent fuel storage racks. In the event that the load is dropped, thc activity rclcascd is limited to that contained in one fuel assembly.
This specification also prevents any possible distortion offuel assemblies in the storage racks from resulting in a critical configuration.
These three specifications were screened against the Commission's criteria and a probabilistic risk asscssmcnt in WCAP-11618. The results are as follows:
~
These refueling specifications pertaining to communications, thc refueling machine and crane travel do not involve installed instrumentation that is used to dctcct, and indicate in the control room, a significant abnormal degradation ofthe reactor coolant pressure boundary.
Thus, Criterion 1 is not satisfied for retention.
~
These refueling specifications do not involve a process variable that is an initialcondition ofa design basis accident (DBA)or transient analysis that assumes cithcr the failure ofor presents a challenge to the integrity ofa fission product barrier. Thus, the specifications do not satisfy Criterion 2.
~
These refueling specifications do not involve structures, systems or components that arc part ofthc primary success path and which functions or actuates to mitigate a DBAor transient that either assumes the failure of or presents a challenge to thc integrity ofa fission product barrier. Thcrcfore, these specifications do not satisfy Criterion 3.
~
Based upon a Probabilistic Risk Assessment (PRA) Summary Report for the MERITS Program contained in Section 4 ofWCAP-11618, communications during refueling operations, requirements pertaining to thc refueling machine and spent fuel crane travel limitations were not identified as a significant risk contributors during design basis type accidents.
Therefore, retention is not rcquircd.
The screening criteria applied in WCAP-11618 were subsequently sanctioned in the Commission's Final Policy Statement issued in July 1993.
With respect to TS 3/4.9.3, "Decay Time," application ofthe screening criteria in WCAP-11618 originally concluded that the specification should be retained as a TS LCO rcquircment based on Criterion 2 (process variable that is an initialcondition ofa DBAor transient analysis).
This specification places a time limiton reactor subcriticality prior to the movcmcnt ofirradiated fuel assemblics in thc reactor vessel to ensure that sufficien time has elapsed for thc radioactive decay ofshort-lived fission products.
However, this specification was not included in NUREG-1431, Revision 0 or Revision 1, as discussed below.
Thc results ofapplying the four Commission criteria are as follows:
~
As described in WCAP-11618, the Decay Time specification docs not involve installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation ofthc reactor coolant pressure boundary. Thcrcfore, this specification does not satisfy Criterion 1 for rctcntion.
As described in WCAP-11618, the Decay Time specification involved an operating restriction or process variable that is an initialcondition ofa DBAor transient analysis that either assumes the failure ofor presents a challenge to thc integrity ofa fission product barrier. However, as discussed in the Vogtle Units 1 and 2 Technical Specifications Criteria Application Rcport, during subsequent industry/NRC mcctings during the development ofNUREG-1431, it was agrccd that this specification could bc relocated.
Thc basis for this agrccmcnt was that existing scheduling restraints associated with moving irradiated fuel following a plant shutdown willprevent thc decay time limit from being exceeded.
These activities include containmcnt entry, removal ofthc integrated reactor vessel head assembly and upper internals, as well as fillingthe refueling cavity. Thcsc scheduling constraints which cnsurc adequate decay time arc likewise applicable at the Harris Nuclear Plant.
Thcrcforc, although thc Decay Time specification technically meets Criterion 2, industry and the NRC have dctcrmincd that it can be rclocatcd.
Enclosure to Serial: HNP-95-067 Page 3 of3 As described in WCAP-11618, the Decay Time specification docs not involve a structure, system, or component that is part ofthe primary success path and which functions or actuates to mitigate a DBAor transient that either assumes the failure ofor presents a challenge to the integrity of a fission
'roduct barrier. Therefore, this specification docs not satisfy Criterion 3 for retention.
~
As described in thc Vogtle report referenced above, the Decay Time specification does not involve a structure, system, or component which operating experience or probabilistic safety asscssmcnt has shown to bc significant to public health and safety. Also, although the Decay Time specification is not directly evaluated in thc PRA Evaluation Report, Section 4, ofWCAP-11618, those refueling operations specifications which arc cvaluatcd have been detcrmincd to be not risk dominant based on the core melt and health cffccts screening criteria given in Section 4.2.D ofWCAP-11618.
Therefore, this specification does not satisfy Criterion 4 for retention.
Therefore, TS 3/4.9.3 can be rclocatcd to a liccnscc-controlled document.
The current TS rcquiremcnts for thc TS 3/4.9.3, "Decay Time," 3/4.9.5, "Communications," 3/4.9.6, "Refueling Machine" and 3/4.9.7, "Crane Travel - Fuel Handling Building TS 3/4.9.3 willbc rclocatcd to plant procedure PLP-114, "Relocated Technical Specification Requirements."
In relocating these rcquircmcnts to a plant procedure, CP&Lwillcontinue to maintain appropriate controls and ensure that any changes to this procedure willbc subjected to the requirements of 10 CFR 50.59.
3.0 CONCLUSION
The Harris Nuclear Plant was licensed based on the Standard Tcchnical Specifications for Westinghouse Pressurized Water Reactors (NUREG-0452, draft Revision 5), which was used as one ofthe bases for application ofthe screening criteria in WCAP-11618. Therefore, Carolina Power &Light Company has concluded, based on thc considerations discussed above, that the Rcfucling Operations Limiting Condition for Operation (LCO) requirements described above may bc rclocatcd to a liccnscc-controlled document, subject to thc provisions of 10 CFR 50.59.
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