ML18016A592
| ML18016A592 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/23/1998 |
| From: | Scarola J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18016A593 | List: |
| References | |
| RTR-NUREG-1431 HNP-98-091, HNP-98-91, NUDOCS 9809280277 | |
| Download: ML18016A592 (11) | |
Text
CATEGORY 1 REGULAT RY INFORMATION DISTRIBUTIOh SYSTEM (RIDS)
ACCESSION NBR:9809280277 DOC.DATE: 98/09/23 NOTARIZED: YES DOCKET FACIL:50-$00
' Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AFFILIATION AUTH. NAME SCAROLA,'J, RECIP.NAME
'arolina AUTHOR RECIPIENT Power & Light Co.
AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Application for amend to license. NPF-63,revising TS 3/4.6.1.3 to be consistent with NUREG-1431,rev 1 &
DISTRIBUTION CODE: A001D TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution NOTES:Application for permit renewal filed.
C j
clarifying requirements for locking air lock door shut.
ENCL i SIZE: (0 + (O 05000400K RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 . 1 FLANDERS,S 1 1
'NTERNAL: ACRS 1 1 LE 1 1 NRR/DE/ECGB/A 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC NRC PDR 1 . 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) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL 13
Carolina Power & light Company James Scarola PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-98-091 10CFR50.90 SEP 23 1998 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 TECHNICALSPECIFICATIONS 3/4.6.1.3
Dear Sir or Madam:
In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power 8!. Light Company (CP8rL) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment revises TS 3/4.6.1.3, "Containment AirLocks". Specifically, Harris Nuclear Plant (HNP) proposes to revise TS 3/4.6.1.3 to be consistent with NUREG-1431, Revision 1 "Standard Technical Specifications, Westinghouse Plants," dated April 1995, and clarify requirements for locking an air lock door shut. 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 CPEcL'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.
CP&L 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. J. H. Eads at (919) 362-2646.
Sincerely, pool 9809280277 980923 PDR ADDCK 05000400 P PDR 5413 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095
MSE/mse
Enclosures:
- 1. Basis for Change Request
- 2. 10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages James Scarola, 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 0
information are employees, contractors, and agents of Carolina Power Light Company.
~~arcs Notary (Seal)
My commission expires: p (
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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
ENCLOSURE 1 TO SERIAL: HNP-98-091 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.6.1.3 BASIS FOR CHANGE RE UEST
~Back round The Harris Nuclear Plant (HNP) Final Safety Analysis Report (FSAR) describes the containment air lock system as consisting of one breech-type personnel air lock and one personnel emergency air lock. Each lock is a welded steel assembly having two doors which are double-gasketed with material resistant to radiation. HNP Technical Specifications (TS) are provided for containment air locks. The limitations on closure and leak rate for containment air locks are required to meet the restrictions on containment integrity and containment leak rate.
The personnel air lock (PAL) has a nine foot inside diameter with full diameter breech doors to open outwardly from each end of the air lock. Doors for the PAL are hydraulically sealed and electrically interlocked. The PAL doors are normally controlled from control panels. The control panel outside of containment is capable of opening and closing both air lock doors. The control panel inside containment can only control the inner (nearest to containment) door. There are two control panels inside the air lock that control an associated door (either inner or outer door). The electrical interlock prevents the inner and outer doors from opening simultaneously when doors are operated at the control panels. During plant shutdown (mode 5), it is necessary to open both doors at the same time to facilitate transferring equipment into and out of containment. Therefore, a means to defeat the electrical interlock is provided. Manual pumping stations are located on the inside and outside of each door to provide a means of opening one or both doors that bypasses the electrical interlock. The manual pumping stations are under strict administrative controls.
The personnel emergency air lock (EAL) has an outside diameter of five feet with a 2.5 foot diameter door located at each end of the air lock. The doors of the EAL are in series and mechanically interlocked to ensure that one door cannot be opened until the second door is sealed. Violation of this interlock can only be made by use of special tools and procedures under strict administrative control.
Current HNP TS 3.6.1.3 Action a.1 requires locking an inoperable door. The PAL doors at HNP are not designed to be locked closed. However, the mechanisms for opening a PAL door are capable of being locked to prevent door operation. Therefore, HNP proposes to clarify the TS 3/4.6.1.3 to add a note that permits locking the mechanisms used to open a PAL door once the PAL door is shut to satisfy the requirement to lock an air lock door. The EAL doors can be locked by locking the mechanical operator.
HNP will also take this opportunity to propose modifying TS 3/4.6.1.3 to be consistent with NUREG-1431, Revision 1 "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
Page El- 1
Pro osed Chan e Harris,'Nuclear Plant (HNP) proposes clarifying TS 3/4.6.1.3 to add a note that permits locking the manual pumping stations and deactivating the electrical mechanisms used to open a Personnel Air Lock door once the Personnel Air Lock door is shut. This note is used to satisfy the requirement to lock an air lock door. This note also clarifies locking an Emergency Air Lock door by stating Locking Emergency Air Lock doors shut consists of locking the mechanical operator. Additionally, HNP proposes modifying TS 3/4.6.1.3 to be consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
Basis In proposing to adopt guidance from NUREG-1431, Revision 1, some portions of the current TS will be modified . The following is a summary of the differences between current TS and the proposed change and the basis for making the change. The Bases of NUREG-1431, Revision 1 section B 3.6.2 was used to determine acceptability of the proposed change.
The proposed change has various formatting modifications for consistency with NVREG-1431, Revision 1 (Standard Technical Specifications or STS). The current HNP TS 3.6.1.3 lists two conditions for an operable air lock, (1.) both air lock doors closed except when the air lock is being used for normal transit and (2.) overall air lock leakage rate. The surveillance requirements in the current HNP TS 4.6.1.3 tests additional operability requirements not specifically listed in the Limiting Condition for Operation (LCO), such as interlock operability. This created confusion in the current HNP TS in determining the relationship between interlock operability and door or air lock operability. STS clarified this confusion, in part, by eliminating the two conditions for an operable air lock from the initial LCO statement. Additional guidance is provided by STS in action's to take ifan interlock was inoperable. The elimination of the two conditions for an operable air lock, (1.)
both air lock doors closed except when the air lock is being used for normal transit and (2.) overall air lock leakage rate, combined with the separate action for an inoperable interlock clarifies the operability requirements for containment air locks.
The actions in STS are modified by a note that allows entry and exit to perform repairs on the affected air lock component. STS bases, B 3.6.2, state this is acceptable due to the low probability of an event in which the operable door is expected to be open. At HNP, entry and exit into containment is controlled by administrative controls, such as locking controls used to open the PAL door, specific procedures for containment entries, and requirements mandating that containment entries can only be made ifa qualified air lock door operator is present. Current HNP TS allow entry through a locked operable air lock door for repairs of an inner door, except the cumulative time this can occur is limited to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per year. HNP procedures will contain a precaution to minimize the time an operable air lock door is opened if it has been locked closed to comply with a TS action.
HNP proposes eliminating the time requirement an operable door can be opened, that has been locked closed to comply with a TS action, based on not being consistent with the controls specified by STS and the low probability of an event in which the operable door is expected to be opened.
A second note has been added to provide clarification that, for this LCO, separate actions are allowed for each air lock. This explanation is necessary because there is no action for both air locks being inoperable. Since HNP has not fully implemented STS, HNP proposes using the term ACTION vice condition entry in accordance with current HNP TS formatting.
The third note directs entry into TS 3.6.1.1 when the air lock leakage results in exceeding the overall containment leakage rate per Specification 3.6.1.2.a. This is an additional requirement which is more Page E1-2
restrictive than the current HNP TS. Currently, HNP TS would allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed out of service time prior to shutting down if air lock leakage exceeded TS limits regardless of the extent of the leakage'. Ifthe overall containment leakage rate is exceeded, then containment is not operable and TS 3.6.1.1 should be entered which would allow one hour to restore containment integrity or be in hot standby within the next six hours.
HNP proposes an additional note, not specified in STS, due to the uniqueness of the HNP PAL door design. HNP PAL door design does not permit locking a PAL door to comply with TS Actions. The mechanisms used to operate the PAL doors can either be locked or power removed from the mechanism to prevent operation. The normal method of opening PAL doors relies on electrical power in order to operate. Removing the electrical power used by the various control panels to open a PAL door will prevent inadvertent operation of an inoperable PAL door via the normal means. The associated pumping stations for PAL doors are capable of being locked to prevent inadvertent operation. This method of isolating an air lock is similar to requirements for isolating a penetration that has an inoperable containment isolation valve (HNP TS 3/4.6.3) which allows isolating an affected penetration by use of one deactivated automatic valve secured in the closed position. This note also clarifies locking an Emergency Air Lock door by stating Locking Emergency Air Lock doors shut consists of locking the mechanical operator.
The proposed TS 3.6.1.3.a provides direction when one or more containment air locks are inoperable due to an inoperable containment air lock door. STS Bases 3.6.2 states that each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a design basis accident in containment. As such, closure of a single door supports containment operability. The TS Actions associated with an inoperable door in the proposed change are similar to the TS Actions in the current HNP TS in that the time to close and lock an operable air lock door are the same. The proposed change modifies the current HNP TS Actions for an inoperable air lock door by not requiring an inoperable air lock door to be restored prior to performance of the next overall air lock leakage test. As stated previously, closure of a single door supports containment operability therefore, the overall air lock leakage test can be successfully performed with an inoperable air lock door. A note is provided, in the proposed TS 3.6.1.3, to clarify that ifboth doors in the same air lock are inoperable, then Action 3.6.1.3.c should be entered and the Actions in 3.6.1.a are not applicable. Additionally, a separate note allows entry and exit for seven days under administrative controls ifboth air locks are inoperable due to an inoperable air lock door.
As stated in STS Bases 3.6.3, this seven day allowance is acceptable due to the low probability of an event that could pressurize the containment during the short time that the operable door is expected to be open. The controls associated with entry during this seven day period is described in the proposed change to B3/4.6.1.3. Entry into containment during this condition will be limited to actions associated with TS equipment or activities that would preclude a plant transient. Entry and exit into containment to repair affected air lock components is covered by a previous note. The requirement to verify an operable door closed once per 31 days is modified by a note that this verification can be performed by administrative means ifthe inoperable air lock door is located in a high radiation area. STS Bases 3.6.2 states this is acceptable since access to these areas is typically restricted (HNP restricts access to high radiation areas).
The proposed TS 3.6.1.3.b provides action when one or more containment air locks are inoperable due to a containment air lock interlock being inoperable. The actions and associated out of service times are consistent with those specified for an inoperable air lock door. A note is provided, for an air lock with an inoperable interlock, that entry and exit of containment is permissible under the control of a dedicated individual. Current HNP procedures require a dedicated individual to control all containment entries. Therefore, ifan interlock were to become inoperable and entry through the associated air lock was required, then HNP would comply with this requirement. The remaining Page E1-3
actions and notes for the proposed TS 3.6.1.3.b are similar to requirements for the proposed TS 3.6.1.3.a for an inoperable door. Additionally, Generic Letter (GL) 87-09, Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the applicability of Limiting Conditions of Operation and Surveillance Requirements, states "generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply".
The proposed TS Action for an inoperable interlock would allow continuous operation. Therefore, HNP proposes that TS 3.0.4 not be applicable for an inoperable interlock. This is consistent with HNP TS for an inoperable door and guidance provided by GL 87-09. However, since HNP TS 3.0.4 has not been modified in accordance with GL 87-09, HNP proposes including the information for TS 3.0.4 applicability in the individual action for an interlock being inoperable.
The proposed TS 3.6.1.3.c is similar to current HNP TS 3.6.1.3.b except that ifthe air lock leakage rate surveillance requirement is exceeded, then an evaluation must be performed to determine ifthe overall containment leakage has been exceeded and entry into TS 3.6.1.1, ifnecessary.
HNP proposes the following changes with regard to surveillance testing of containment air locks.
HNP proposes to adopt STS guidance for air lock leakage tests. STS provides generic guidance that specifies air lock leakage rate testing will be performed in accordance with 10 CFR 50 Appendix J.
10 CFR 50, Appendix J provides for two options in performing air lock leakage rate testing. The proposed change requires any modifications to Appendix J requirements must be done by an approved exemption. In addition, the proposed air lock interlock surveillance requirement is similar to the current HNP'TS except that the proposed change only requires the surveillance to be performed upon entry or exit through the containment air lock. The STS Bases 3.6.2 states that the interlock is only challenged when the containment air lock door is opened. Therefore, the surveillance is only required when opening an air lock door.
==
Conclusion:==
HNP proposes to implement the guidance from NUREG-1431, Revision 1 as modified by the note clarifying locking an inoperable air lock door. HNP requests this clarification of NUREG-1431, Revision 1 due to the design of the HNP PAL door which does not provide a mechanism for directly locking an inoperable air lock door. The proposed method of isolating an inoperable air lock door penetration is similar to isolating penetrations with inoperable containment isolation valves. The remainder of the proposed change is consistent with the provisions of NUREG-1431, Revision 1.
Page E1-4
ENCLOSURE 2 TO SERIAL: HNP-98-091 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.6.1.3 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 Ec 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 Harris Nuclear Plant (HNP) proposes clarifying TS 3/4.6.1.3 to add a note that permits locking the manual pumping stations and deactivating the electrical mechanisms used to open a Personnel Air Lock door once the Personnel AirLock door is shut. This note is used to satisfy the requirement to lock an air lock door. This note also clarifies locking an Emergency Air Lock door by stating Locking Emergency AirLock doors shut consists of locking the mechanical operator. Additionally, HNP proposes modifying TS 3/4.6.1.3 to be consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
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.
Containment Air Locks are not an accident initiating system as described in the Final Safety Analysis Report. The proposed change implements guidance for Technical Specifications associated with air lock doors consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. Additionally, clarification is provided to permit locking an inoperable air lock door as required by Technical Specifications. The proposed change does not affect another Structure, System, or Component. The operation and design of containment air locks will not be affected by this proposed change. The ability of containment to mitigate an accident will not be affected by this change.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Page E2-1
2.. The proposed amendment does not create the possibility of a new or different kind of
'ccident from any accident previously evaluated.
Containment AirLocks are designed to form part of the containment pressure boundary. The proposed change provides for administrative controls and operating restrictions for air lock doors consistent with guidance provided by the Commission. Containment Air Locks are not an accident initiating system as described in the Final Safety Analysis Report. The proposed change does not affect another Structure, System, or Component. The operation and design of containment air locks will not be affected by this proposed change.
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 to containment air locks does not affect any of the parameters that relate to the margin of safety as described in the Bases of the TS or the FSAR. Accordingly, NRC Acceptance Limits are not affected by this change.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
Page E2-2
ENCLOSURE 3 TO SERIAL: HNP-98-091 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.6.1.3 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 & Light Company 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 of the amendment. The basis for this determination follows:
Pro osed Chan e Harris Nuclear Plant (HNP) proposes clarifying TS 3/4.6.1.3 to add a note that permits locking the manual pumping stations and deactivating the electrical mechanisms used to open a Personnel Air Lock door once the Personnel AirLock door is shut. This note is used to satisfy the requirement to lock an air lock door. This note also clarifies locking an Emergency Air Lock door by stating Locking Emergency Air Lock doors shut consists of locking the mechanical operator. Additionally, HNP proposes modifying TS 3/4.6.1.3 to be consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
Basis The change meets the eligibilitycriteria 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.
- 2. The proposed amendment does not result in a significant change in the types or increase in the amounts of any 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 of any 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.
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ENCLOSURE 4 TO SERIAL: HNP-98-091 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.6.1.3 PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e 3/4 6-4 3/4 6-4 3/4 6-4a 3/4 6-5 3/4 6-5 B3/4 6-1 B3/4 6-1 B3/4 6-la Page E4-1