ML18012A303

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Application for Amend to License NPF-63,TS 3/4.6.2, Containment Spray Sys,Extending Surveillance Interval for Performance of Air or Smoke Flow Test Through CS Nozzles from Once Every 5 Years,To Once Every 10 Years
ML18012A303
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 07/19/1996
From: Robinson W
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18012A304 List:
References
GL-93-05, GL-93-5, HNP-96-094, HNP-96-94, NUDOCS 9607290228
Download: ML18012A303 (15)


Text

CATEGORY 1

<i' REGULATOR INFORMATION DISTRIBUTION STEM (RIDS)

ACCEP)SJON NBR:9607290228 DOC.DATE: 96/07/19 NOTARIZED: YES DOCKET I FACT'=-".50,,400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAM'"" AUTHOR AFFILIATION ROBINSON,'A.R. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

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Document 'Control Branch (Document Control Desk)

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SUBJECT:

Application for amend to license NPF-63,TS 3/4.6.2, Containment Spray Sys,extending surveillance interval for performance of air or smoke flow test through CS nozzles from once every 5 years,to once every 10 years.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution E

NOTES:Application for permit renewal filed. 05000400 G

, 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 1 1 INTERNAL: ACRS 1 1 ILE CENTER 1 1 NRR/DE/EMCB 1 1 NRR HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 1 NRC PDR, 1 1 D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 4I5-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER .OF COPIES'EQUIRED:'LTTR 13 ENCL 12

Carolina Power & light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-96-094 10 CFR 50.90 JUL 19 1996 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 CONTAINMENTSPRAY NOZZLE SURVEILLANCEINTERVAL

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power 8c Light Company (CP&L) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment to TS 3/4.6.2, Containment Spray System, will extend the surveillance interval for performance of an air or smoke flow test through containment spray nozzles from once per five years to once per ten years. This'hange is consistent with experience to date and with the guidance in NRC Generic Letter 93-05, "Line Item plant'esting Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," and NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements."

Enclosure 1 provides a 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 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.

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

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i)ocument Control Desk HNP-96-094 / Page 2 Enclosure 5 provides the proposed Technical Specification pages.

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

CP&L requests approval of the proposed amendment by December 1, 1996 to support planning for the next HNP refueling outage, currently scheduled to begin in March 1997. CPkL requests that the proposed amendment be issued such that implementation will occur within 60 days of issuance to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications.

Please refer any questions regarding this submittal to Mr. T. D. Walt at (919) 362-2711.

Sincerely, J. W. Donahue for W. R. Robinson LSR/lsr

Enclosures:

1. Basis for Change Request
2. 10 CFR 50.92 Evaluation
3. Environmental Considerations
4. Page Change Instructions
5. Technical Specification Pages J. W. Donahue, 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 employees, contractors, and agents of Carolina Power 8c Light Company.

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?)ocurnent Control Desk HNP-96-094 / Page 3 Mr. J. B. Brady, NRC Resident Inspector Mr. Dayne H. Brown, N.C. DEHNR Mr. S. D. Ebneter, NRC Regional Administrator Mr. N. B. Le, NRC Project Manager

ENCLOSURE TO SERIAL: HNP-96-094 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENTSPRAY NOZZLE SURVEILLANCEINTERVAL BASIS FOR CHANGE RE UEST Pro osed Chan e The proposed amendment to TS 3/4.6.2, Containment Spray System, will extend the surveillance interval for performance of an air or smoke flow test through containment spray nozzles from once per five years to once per ten years. This change is consistent with plant testing experience to date and with the guidance in NRC Generic Letter 93-05, "Line Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," and NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements."

Basis As described in Final Safety Analysis Report, Section 6.2.2.2, the purpose of the Containment Spray System (CSS) is to spray borated sodium hydroxide solution through nozzles into the containment to cool the atmosphere and remove fission products following a loss of coolant accident (LOCA) or main steam line break (MSLB). The CSS consists of two independent and redundant trains, each containing a spray pump, stainless steel piping, valves, two spray headers, and spray nozzles.

As described in the CSS system description (SD-112), the containment spray pumps provide the borated water to the spray headers and nozzles, with spray additive eductors blending in sodium hydroxide. Spray headers are located in the containment dome to maximize heat removal. Each train of CSS has two headers containing a total of 106 spray nozzles per train. The spray nozzles have a diameter of approximately 0.375 inches. The nozzles disperse the flow to increase cooling effectiveness. As these droplets fall through the containment atmosphere they absorb heat and iodine.

HNP Technical Specification 3/4.6.2, Containment Spray System, currently requires an air or smoke flow test to be completed for each spray header at least once per 5 years to verify that each spray nozzle is unobstructed.

In December 1992, the NRC issued NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements." Section 8.1 of the NUREG provides the NRC's staff evaluation with respect to Pressurized Water Reactor (PWR) containment spray systems. That evaluation noted that the NRC only identified three plants at which problems with a containment spray system had Page El-1

ENCLOSURE TO SERIAL: HNP-96-094 been identified through testing. HNP was not one of those plants. In each of the three cases, the problem was attributable to a construction error. Since the testing only provides a qualitative verification that the nozzles are not obstructed and cannot be used to determine degradation of other performance parameters such as system flow, the NRC concluded that it provided little benefit. Therefore, NUREG-1366 recommended that this test be extended to every 10 years.

Pre-operational testing of the CSS at HNP, performed in June 1986, verified air flow through each containment spray nozzle. Also, in April 1991, a containment spray system nozzle flow test was performed to satisfy Technical Specification 4.6.2.1.d. That testing also verified air flow through each nozzle.

On September 27, 1993, the NRC issued Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation." The Generic Letter encouraged licensees to adopt the line-item TS improvements and provided guidance for licensees to use in preparing license amendments to reduce testing commensurate with the recommendations of NUREG-1366.

In Generic Letter 93-05, the NRC identified an additional problem at a plant which experienced nozzle clogging due to coating degradation in carbon steel piping. Consistent with the NRC's recommendations in Generic Letter 93-05, the containment spray piping design at the Harris Nuclear Plant is stainless steel, and thus should not be susceptible to the coating degradation described in the Generic Letter.

Conclusions Based upon the conclusions in NUREG-1366, HNP system design parameters that prevent clogging, and past performance testing results at HNP, the proposed line-item improvement to the HNP Technical Specifications is consistent with plant testing experience to date and with the guidance contained in Generic Letter 93-05 and in NUREG-1366.

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ENCLOSURE TO SERIAL: HNP-96-094 ENCLOSURE 2 SHEARON HARIUS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENTSPRAY NOZZLE SURVEILLANCEINTERVAL 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 & 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 to TS 3/4.6.2, Containment Spray System, will extend the surveillance interval for performance of an air or smoke flow test through containment spray nozzles from once per five years to once per ten years. This change is consistent with plant testing experience to date and with the guidance in NRC Generic Letter 93-05, "Line Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," and NUEEG-1366, "Improvements to Technical Specifications Surveillance Requirements."

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.

The proposed extended testing frequency of containment spray nozzles will not affect any initiators of any previously evaluated accidents or change the manner of operation for any system or component. The containment spray system serves a mitigating function by removing heat and fission products from a post-accident containment atmosphere.

Increasing the surveillance test interval will not affect the system's ability to provide this function. Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

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ENCLOSURE TO SERIAL: HNP-96-094 The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Since the proposed change affects only a surveillance frequency, it willnot involve any physical alterations to plant equipment or alter the manner in which any safety-related system performs its function. Therefore, the proposed change does 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 proposed change does not affect any Final Safety Analysis Report (FSAR) Chapter 15 accident analyses or impact the margin of safety for the containment spray system as defined in the Bases to the Technical Specifications. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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II ENCLOSURE TO SERIAL: HNP-96-094 ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CONTAINMENTSPRAY NOZZLE SURVEILLANCEINTERVAL ENVIRONMENTALCONSIDERATIONS 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 ifoperation 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 a significant increase in individual or cumulative occupational radiation exposure. Carolina Power 2 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 to TS 3/4.6.2, Containment Spray System, will extend the surveillance interval for performance of an air or smoke flow test through containment spray nozzles from once per five years to once per ten years. This change is consistent with plant testing experience to date and with the guidance in NRC Generic Letter 93-05, "Line Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operations," and NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements."

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

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ENCLOSURE TO SERIAL: HNP-96-094

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any efHuents that may be released offsite.

The proposed change does not involve any new equipment or require existing systems to perform a different type of function than they are currently designed to perform. The change does not introduce any new efHuents or increase the quantities of existing efHuents. As such, the change can not affect the types or amounts of any e61uents that may be released offsite.

3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

The proposed change does not result in any physical plant changes or new surveillances.

The reduced surveillance inter val should result in a decrease in radiation exposure, since it willlessen personnel entry into radiation-controlled areas of the plant. Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

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