HNP-98-119, Application for Amend to License NPF-63,revising TS Re Applicability of LCO & Surveillance Requirements,Per GL 87-09
| ML18016A539 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/27/1998 |
| From: | Scarola J CAROLINA POWER & LIGHT CO., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18016A540 | List: |
| References | |
| GL-87-09, GL-87-9, HNP-98-119, NUDOCS 9809020118 | |
| Download: ML18016A539 (19) | |
Text
~, i CATEGORY 1.
REGULA RY INFORMATION DISTRIBUTIO SYSTEM (RIDS)
ACCESSION NBR:9809020118 DOC.DATE: 98/08/27 NOTARIZED: YES DOCKET ¹ FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME.
AUTHOR AFFILIATION SCAROLA,J.
Consumers Energy Co.
(formerly Consumers Power Co.),
RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Application for amend to license NPF-63,revising TS re applicability of LCO
& surveillance recpxirements,per GL 87-09 DZSTRZBUTZON CODE:
A001D CORTES RECEZVED:LTR i
ENCL S1ZE: jg TITLE: OR Submittal: General Distribution NOTES:Application for permit renewal filed.
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1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
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LTTR 14 ENCL 13
Carolina Pawer & Ught Company PCt Box 165 New Hill NC 27562 James Scarola Vice President Harris Nuclear Plant AUG 27 1998 SERIAL:
HNP-98-119 10CFR50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARMS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT APPLICABILITYOF LIMITINGCONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
Dear Sir or Madam:
In accordance with the Code ofFederal Regulations, Title 10, Part 50.90, Carolina Power Ec Light Company (CP8cL) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment revises the TS concerning the applicability of Limiting Conditions for Operation and Surveillance Requirements. Specifically, HNP proposes to revise TS 3.0.4 and associated specifications; TS 4.0.4; and Bases for TS 3.0.3, TS 3.0.4, and TS 4.0.4 to be consistent with Generic Letter 87-09 dated June 4, 1987.
This proposed TS change is needed due to the verbatim requirements ofTS 3.0.4 and inoperable TS equipment that would prevent plant shutdown. A verbatim reading of the current HNP TS 3.0.4 would not allow entry into a lesser operational mode ifrequired TS components were inoperable.
Currently, HNP has inoperable Source Range Nuclear Instrumentation (SR NI). SR NI is not required for Power Operation (Mode 1) but is required for Startup (Mode 2) and Hot Standby (Mode 3). Verbatim compliance with current HNP TS 3.0.4 would prevent HNP from plant shutdown with inoperable SR NI.
Resolution of this issue is needed prior to the upcoming refueling outage currently scheduled to begin on October 24, 1998.
HNP previously requested implementation of Generic Letter 87-09 by letter dated November 9, 1987.
HNP subsequently withdrew the amendment request as documented in NRC letter dated March 8, 1990.
Enclosure 1 provides a description ofthe proposed changes and the basis for the changes. Enclosure 2 details, in accordance with 10 CFR 50.91(a), the basis for the CP&L'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 is required for approval of this amendment request. provides page change instructions for incorporating the proposed revisions. Enclosure 5 provides the proposed Technical Specification pages.
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Si cerely, James Scarola ONW/onw James Scarola, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best ofhis information, knowledge and belief, and the sources ofhis informatio loyees, contractors, and agents ofCarolina Power 2 Light Company.
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Enclosures:
- 1. Basis for Change Request 2.- 10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages Mr. J. B. Brady, NRC Sr. Resident Inspector Mr. Mel Fry, Acting Director, N.C. DEHNR Mr. S. C. Flanders, NRC Project Manager Mr. L. A. Reyes, NRC Regional Administrator
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< the facility by placing it in a mode or condition ofoperation in which the LCO does not apply.
Specification 3.0.4 states that entry into an operational mode or other specified condition shall not be made unless the LCO is met without reliance on the provisions of the Action Requirements.
GL 87-09 states that the intent ofSpecification 3.0.4 is to ensure that a higher mode ofoperation is not entered when equipment is inoperable or when parameters exceed their specified limits. This precludes a plant startup when actions are being taken to satisfy an LCO, which ifnot completed withinthe time limitsofthe Action Requirements would result in a plant shutdown to comply with the Action Requirements.
Specification 3.0.4 also precludes entering a mode or specified condition ifan LCO is not met, even ifthe Action Requirements would permit continued operation ofthe facilityfor an unlimited period of time.
Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply. However, as stated in GL 87-09, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well Page El-l
documented.
For example, approximately two-thirds of the actions which permit continued operation in the Westinghouse Standard Technical Specifications (NUREG-0452) are exempt from Specification 3.0.4. In general, the TS do not preclude entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level ofsafety for continued operation.
Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. A conflict with this TS exists when a mode change is required as a consequence ofshutdown Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. This problem arises because conformance with Specification 4.0.4 would require the performance ofthese sur veillances before entering a mode for which they apply.
Pr hne Harris Nuclear Plant (HNP) proposes modifying Technical Specification (TS) 3.0.4 and associated specifications; TS 4.0.4; and the Bases for TS 3.0.3, TS 3.0.4, and TS 4.0.4 to be consistent with Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 ofthe Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,"
dated June 4, 1987. Specifically:
HNP proposes modifying TS 3.0.4 to state that entry into an operational mode or other specified condition shall not be made when the conditions for the LimitingConditions for Operation are not met and the associated action requires a shutdown ifthey are not met within a specified time interval. Entry into an operational mode or specified condition may be made in accordance with Action Requirements when conformance to them permits continued operation ofthe facilityfor an unlimited period oftime.
2.
HNP proposes deleting "The provisions ofSpecification 3.0.4 do not apply" from those TS whose Action Requirements permit continued operation.
The reference to Specification 3.0.4 is proposed to be deleted from the followingSpecifications: 3.2.4, 3.3.1, 3.3.2, 3.3.3.1, 3.3.3.3, 3.3.3.4, 3.3.3.9, 3.3.3.11, 3.4.10, 3.6.1.3, 3.6.3, 3.7.1.1, 3.7.1.5, 3.7.9, 3.8.4.1, 3.9.9, 3.9.11, 3.9.12, 3.11.1.4, and 3.11.2.5.
3.
HNP also proposes clarifying TS 4.0.4 to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements.
A similar provision is already included in HNP TS 3.0.4.
4.
HNP also proposes modifying the Bases to TS 3.0.3, TS 3.0.4, and TS 4.0.4 for consistency with GL 87-09. These revisions reflect the modifications to TS 3.0.4 and TS 4.0.4 discussed above, and provide a clarification to the Bases for TS 3.0.3 concerning voluntary entry into TS 3.0.3.
In proposing to adopt guidance from GL 87-09, portions ofthe current TS willbe modified. The followingis a summary ofthe differences between current TS and the proposed change and the basis for making the change. The guidance in GL 87-09 was used to determine acceptability of the proposed change.
Page E1-2
Current HNP TS 3.0.4 states that entry into an operational mode or other specified condition shall not be made unless the conditions for the LimitingCondition for Operation are met without reliance on provisions contained in the Action Requirements.
Harris Nuclear Plant (HNP) proposes modifying TS 3.0.4 to state that entry into an operational mode or other specified condition shall not be made when the conditions for the LimitingConditions for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval.
Entry into an operational mode or specified condition may be made in accordance with Action Requirements when conformance to them permits continued operation of the facilityfor an unlimited period of time.
The TS are inconsistent in application ofexceptions to Specification 3.0.4. This impacts the operation of the facilityin several ways. First, it delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility. Second, it delays a return to power operation when the facilityis required to be in a lower mode of operation as a consequence of other Action Requirements.
In this case, the LCO must be met without reliance on the Action Requirements before returning the facility to that operational mode or other specified condition for which unlimited continued operation was previously permitted in accordance with the Action Requirements.
Generic Letter (GL) 87-09 states that the intent of Specification 3.0.4 is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits.
GL 87-09 states that Specification 3.0.4 unduly restricts facilityoperation when conformance to the Action Requirements provides an acceptable level of safety for continued operation.
For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements.
This is consistent with the Nuclear Regulatory Commission's (NRC) regulatory requirements for an LCO.
GL 87-09 states that the restriction on a change in operational modes of other specified conditions should apply only where the Action Requirements establish a specified time interval in which the LCO must be met or a shutdown of the facilitywould be required.
HNP proposes modifying TS 3.0.4 as described above to be consistent with GL 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability ofLimitingConditions for Operation and Surveillance Requirements," dated June 4, 1987.
In conjunction with this modification to TS 3.0.4, HNP willrequire Manager - Operations or designee approval prior to each usage ofTS 3.0.4 to allow entry into an operational mode when the conditions for the LCO are not met. The purpose ofthis approval is to ensure that:
(1) the remedial measures prescribed by the applicable TS Action Requirements provide a sufficient level of protection to permit operational mode changes and safe long-term operation consistent with the licensing basis described in the Final Safety Analysis Report, (FSAR) and (2) it willbe the exception when plant startup commences to have important safety features inoperable. This commitment willalso be incorporated into the FSAR.
As a consequence of this proposed modification to TS 3.0.4, individual specifications with Action Requirements permitting continued operation no'longer need to indicate that Specification 3.0.4 does not apply. Therefore, HNP proposes deleting "The provisions of Specification 3.0.4 do not apply" from those TS whose Action Requirements permit Page E1-3
continued operation to avoid confusion about the applicability of Specification 3.0.4. The reference to Specification 3.0.4 is proposed to be deleted from the following Specifications:
3.2.4,3.3.1,3.3.2,3.3.3.1,3.3.3.3,3.3.3.4,3.3.3.9,3.3.3.11,3.4.10,3.6.1.3,3.6.3,3.7.1.1, 3.7.1.5, 3.7.9, 3.8.4.1, 3.9.9, 3.9.11, 3.9.12, 3.11.1.4, and 3.11.2.5.
However, exceptions to Specification 3.0.4 are not being deleted for individual specifications ifa mode change would be precluded by Specification 3.0.4 as proposed for revision. This is also consistent with the guidance ofGL 87-09. As stated in GL 87-09, it is not the staff s intent that the revision ofSpecification 3.0.4 should result in more restrictive requirements for individual specifications.
This effects Specifications 3.3.2, 3.3.3.5, 3.3.3.6, 3.4.4, 3.4.8, and 3.4.9.4.
Current HNP TS 4.0.4 states that entry into an operational mode or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation has been performed within the stated surveillance interval or as otherwise specified.
HNP proposes clarifying TS 4.0.4 to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. Asimilar provision is already included in HNP TS 3.0.4.
A conflict with Specification 4.0.4 exists when a mode change is required as a consequence of shutdown Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. For instance the plant could previously have been in a mode for which the Surveillance Requirements were not applicable, and therefore, the surveillance may not have been performed within the specified time interval. This problem arises because conformance with Specification 4.0.4 would require the performance ofthese surveillances before entering a mode for which they apply.
Source and intermediate range nuclear instrumentation and cold overpressure protection systems are examples of systems for which Surveillance Requirements may become applicable as a consequence of mode changes to comply with shutdown Action Requirements.
The potential for plant upset and challenge to safety systems is heightened ifsurveillances are performed during a shutdown to comply withAction Requirements.
GL 87-09 states that it is not the intent ofSpecification 4.0.4 to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements.
HNP proposes modifying TS 4.0.4 as described above to be consistent with GL 87-09, "Sections 3.0 and 4.0 ofthe Standard Technical Specifications (STS) on the Applicability ofLimitingConditions for Operation and Surveillance Requirements," dated June 4, 1987.
HNP also proposes modifying the Bases to TS 3.0.3, TS 3.0.4, and TS 4.0.4. These revisions to the Bases reflect the modifications to TS 3.0.4 and TS 4.0.4 described above, and provide a clarification to the Bases for TS 3.0.3 concerning voluntary entry into TS 3.0.3.
These revisions are consistent with GL 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," dated June 4, 1987.
Page E1-4
Q}nclusion:
HNP proposes to implement guidance from GL 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," dated June 4, 1987, forTS 3.0.4 and associated specifications, TS 4.0.4, and the Bases for TS 3.0.3, TS 3.0.4, and TS 4.0.4.
The proposed change is consistent with the provisions ofGL 87-09.
Page E1-5
ENCLOSURE 2 TO SERIAL: HNP-98-119 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT APPLICABILITYOF LIMITINGCONDITIONS FOR OPERATION AND SURVEILLANCEREQUIREMENTS F
. 2FV TI 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 facilityinvolves 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 ofan accident previously evaluated, (2) create the possibility ofa new or different kind ofaccident 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:
r ed hne Harris Nuclear Plant (HNP) proposes modifying Technical Specification (TS) 3.0.4 and associated specifications; TS 4.0.4; and the Bases for TS 3.0.3, TS 3.0.4, and TS 4.0.4 to be consistent with Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 ofthe Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,"
dated June 4, 1987. Specifically:
HNP proposes modifying TS 3.0.4 to state that entry into an operational mode or other specified condition shall not be made when the conditions for the LimitingConditions for Operation are not met and the associated action requires a shutdown ifthey are not met within a specified time interval. Entry into an operational mode or specified condition may be made in accordance with Action Requirements when conformance to them permits continued operation ofthe facilityfor an unlimited period oftime.
2.
HNP proposes deleting "The provisions ofSpecification 3.0.4 do not apply" from those TS whose Action Requirements permit continued operation.
The reference to Specification 3.0.4 is proposed to be deleted from the followingSpecifications: 3.2.4, 3.3.1, 3.3.2, 3.3.3.1, 3.3.3.3, 3.3.3.4, 3.3.3.9, 3.3.3.11, 3.4.10, 3.6.1.3, 3.6.3, 3.7.1.1, 3.7.1.5, 3.7.9, 3.8.4.1, 3.9.9, 3.9.11, 3.9.12, 3.11.1.4, and 3.11.2.5.
3.
HNP also proposes clarifying TS 4.0.4 to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements.
Asimilar provision is already included in HNP TS 3.0.4.
4.
HNP also proposes modifying the Bases to TS 3.0.3, TS 3.0.4, and TS 4.0.4 for consistency with GL 87-09. These revisions reflect the modifications to TS 3.0.4 and TS 4.0.4 discussed above, and provide a clarification to the Bases for TS 3.0.3 concerning voluntary entry into TS 3.0.3.
Page E2-1
This change does not involve a significant hazards consideration for the followingreasons:
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed revision to TS 3.0.4 allows entry into an operational condition in accordance with action requirements when conformance to the action requirements permits continued operation of the facility for an unlimited period of time.
This operational flexibilityis consistent with that allowed by the existing individual LCOs and their associated action requirements which provide an acceptable level ofsafety for continued operation.
The proposed revision to TS 4.0.4 clarifies that Specification 4.0.4 does not prevent passage through or to operational conditions as required to comply with action requirements.
This is consistent with the existing Specification 3.0.4. In addition, the potential for plant upset and challenge to safety systems is heightened ifsurveillances are performed during a shutdown to comply with Action Requirements.
The revisions to the Bases Section 3.0 and 4.0 and the elimination ofspecific exceptions to Specification 3.0.4 are administrative in nature and, therefore, do not involve a significant increase in the probability or consequences ofan accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
There is no physical alteration to any plant system, nor is there a change in the method in which any safety related system performs its function.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because there is no physical alteration to any plant system, nor is there a change in the method in which any safety related system performs its function.
The revisions to the Bases Sections 3.0 and 4.0 and the elimination ofspecific exemptions to Specification 3.0.4 are administrative in nature and, therefore, do not create the possibility ofa new or different kind ofaccident from any accident previously evaluated.
Therefore, the proposed change does not create the possibility ofa new or different kind of accident from any accident previously evaluated.
The proposed amendment does not involve a significant reduction in the margin ofsafety.
The revision to Specification 3.0.4 allows operational flexibilitywhich is consistent with that allowed by the existing individual LCOs and their associated action requirements which provide an acceptable level of safety for continued operation.
The proposed revision to Specification 4.0.4 is a clarification to the specification and as such is administrative in Page E2-2
nature. The revision makes itclear that Specification 4.0.4 does not prevent passage through or to operational conditions as required to comply with action requirements.
This is consistent with the existing Specification 3.0.4.
These revisions result in improved Technical Specifications, and therefore, increase the margin ofsafety.
The revisions to the Bases Sections 3.0 and 4.0 and the elimination ofspecific exemptions to Specification 3.0.4 are administrative in nature.and, therefore, do not involve a significant reduction in a margin ofsafety.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
Page E2-3
ENCLOSURE 3 TO SERIAL: HNP-98-119 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT APPLICABILITYOF LIMITINGCONDITIONS FOR OPERATION AND SURVEILLANCEREQUIREMENTS 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 facilityrequires 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 ofany eAluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure.
Carolina Power &,LightCompany has reviewed this request and determined that the proposed amendment meets the eligibilitycriteria 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 ofthe amendment.
The basis for this determination follows:
Harris Nuclear Plant (HNP) proposes modifying Technical Specification (TS) 3.0.4 and associated specifications; TS 4.0.4; and the Bases for TS 3.0.3, TS 3.0.4, and TS 4.0;4 to be consistent with Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 ofthe Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,"
dated June 4, 1987. Specifically:
1.
HNP proposes modifying TS 3.0.4 to state that entry into an operational mode or other specified condition shall not be made when the conditions for the LimitingConditions for Operation are not met and the associated action requires a shutdown ifthey are not met within a specified time interval. Entry into an operational mode or specified condition may be made in accordance with Action Requirements when conformance to them permits continued operation ofthe facilityfor an unlimited period oftime.
2.
HNP proposes deleting "The provisions ofSpecification 3.0.4 do not apply" from those TS whose Action Requirements permit continued operation.
The reference to Specification 3.0.4 is proposed to be deleted from the following Specifications: 3.2.4, 3.3.1, 3.3.2, 3.3.3.1, 3.3.3.3, 3.3.3.4, 3.3.3.9, 3.3.3.11, 3.4.10, 3.6.1.3, 3.6.3, 3.7.1.1, 3.7.1.5, 3.7.9, 3.8.4.1, 3.9.9, 3.9.11, 3.9.12, 3.11.1.4, and 3.11.2.5.
3.
HNP also proposes clarifying TS 4.0.4 to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. Asimilar provision is already included in HNP TS 3.0.4.
4.
HNP also proposes modifying the Bases to TS 3.0.3, TS 3.0.4, and TS 4.0.4 for consistency with GL 87-09. These revisions reflect the modifications to TS 3.0.4 and TS 4.0.4 discussed above, and provide a clarification to the Bases for TS 3.0.3 concerning voluntary entry into TS 3.0.3.
Page E3-1
0 The change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the followingreasons:
1.
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 increase in the amounts ofany effluents that may be released offsite.
The change does not introduce any new effluents or increase the quantities of existing effluents. As such, the change cannot affect the types or amounts ofany effluents that may be released offsite.
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 which would require additional personnel entry into radiation controlled areas.
Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.
Page E3-2
ENCLOSURE 4 TO SERIAL: HNP-98-119 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT APPLICABILITYOF LIMITINGCONDITIONS FOR OPERATION ANDSURVEILLANCEREQUIREMENTS PA F AN E TR Tl N 3/4 0-1 3/4 0-2 3/4 2-13 3/4 3-2 3/4 3-3 3/4 3-4 3/4 3-6 3/4 3-18 3/4 3-22 3/4 3-23 3/4 3-24 3/4 3-50 3/4 3-57 3/4 3-60 3/4 3-74 3/4 3-82 3/4 4-43 3/4 6-4 ve e
3/4 0-1 3/4 0-2 3/4 2-13 3/4 3-2 3/4 3-3 3/4 3-4 3/4 3-6 3/4 3-18 3/4 3-22 3/4 3-23 3/4 3-24 3/4 3-50 3/4 3-57 3/4 3-60 3/4 3-74 3/4 3-82 3/4 4-43 3/4 6-4 Page E4-1
3/4 6-14 3/4 7-1 3/4 7-9 3/4 7-25 3/4 8-19 3/4 9-11 3/4 9-13 3/4 9-14 3/4 11-7 3/4 11-15 B 3/4 0-1 B 3/4 0-2 B 3/4 0-2a B 3/4 0-2b B 3/4 0-3 3/4 6-14 3/4 7-1 3/4 7-9 3/4 7-25 3/4 8-19 3/4 9-11 3/4 9-13 3/4 9-14 3/4 11-7 3/4 11-15 B 3/4 0-1 B 3/4 0-2 B 3/4 0-2a B 3/4 0-2b B 3/4 0-3 Page E4-2