ML18016A623

Informs That Util Proposes to Fully Implement Guidance Provided by GL 93-05 with Regard to Modifying TS 3/4.5.1 Surveillance Requirements.Encl 1 Provides Response to Rai. Encl 2 Provides Revised TS Pages Change Instructions

ML18016A623
Person / Time
Site:	Harris
Issue date:	10/15/1998
From:	Scarola J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18016A625	List: ML18016A623 ML18016A626
References
RTR-NUREG-1431 GL-93-05, GL-93-5, HNP-98-147, NUDOCS 9810190285
Download: ML18016A623 (8)

Text

CATEGORY 1 .

REGULA RY INFORMATION DZSTRIBUTIO SYSTEM (RXDS)

ACCESSION NBR:9810190285 " DOC.DATE: 98/10/15 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTHOR AFFILIATION AUTH. NAME SCAROLA',J.

RECIP.NAME

-'arolina Power &

RECIPIENT AFFILIATION Light Co.

Records Management Branch (Document Control Desk)

SUBJECT:

Informs that util proposes to fully implement guidance provided by GL 93-05 with regard to modifying TS 3/4.5.1 surveillance,recpxirements.Encl'1 provides response to RAI.

Encl 2 provides revised TS pages change instructions.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution E NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES 0

ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL R PD2-1 LA =

1 1 PD2-1 PD 1 1 FLANDERS'iS 1 1 INTERNAL: ACRS 1 1 Eg@34se0" 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/SRZB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0, D

EXTERNAL: NOAC 1 1 NRC PDR 0

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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

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Carolina Power & Ught Company James Scarola PCt Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-98-147 10CFR50.90 OCT 15 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 TECHNICALSPECIFICATION 3/4.5.1 SUPPLEMENTAL INFORMATION

Dear Sir or Madam:

By letters dated March 10, 1997 and May 23, 1997, Carolina Power & Light Company (CP&L) submitted a Request for License Amendment for the Harris Nuclear Plant (HNP). The proposed amendment revises Technical Specification 3/4.5.1, "Accumulators" and the associated Bases.

Specifically, Harris Nuclear Plant (HNP) proposed to provide an optional method of meeting Surveillance Requirement (SR) 4.5.1.1.a.1 and modify the Action statement regarding when an Accumulator does not meet the Limiting Condition for Operation for boron concentration. By letter dated May 12, 1998, the NRC requested additional information regarding this submittal. The NRC states that it appears that the proposed change to SR 4.5.1.1.a. 1 differs from the Standard Technical Specifications (STS) for Westinghouse Plants, NUREG-1431, Rev 1. Specifically, the proposed change to verify the borated water volume and nitrogen cover-pressure "by the absence of alarms or instrument readings," is not consistent with the STS. The NRC also referred to Generic Letter 93-05, "Line-Item Technical Specifications Improvements To Reduce Surveillance Requirements for Testing During Power Operations." Generic Letter 93-05 provides guidance for implementing changes to TS 3/4.5.1 surveillance requirements.

In response to this request for additional information, HNP proposes to fully implement guidance provided by Generic Letter 93-05 with regard to modifying TS 3/4.5.1 surveillance requirements. provides the response to the request for additional information. Enclosure 2 provides for revised TS page change instructions. Enclosure 3 provides revised TS pages.

These changes do not affect the conclusions of either the 10 CFR 50.92 Evaluation or the Environmental Considerations submitted as part of CP&L's letter dated March 10, 1997. The proposed TS pages in this submittal supersede the proposed TS pages previously submitted by letters dated March 10, 1997 and May 23, 1997.

5 C 98iOi90285 98iOi5 PDR ADOCK 05000400 P PDR 5413 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095

Please refer any questions regarding this matter to Mr. J. H. Eads at (919) 362-2646.

Sincerely, MSE/mse

Enclosures:

1. Response to Request for Additional Information

2. Revised TS Page Change Instructions

3. TS 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 information are employees, contractors, and agents of Carolina Power 8c Light Company.

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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-98-147 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.5.1 SUPPLEMENTAL INFORMATION NRC uestion The submittal states that the proposed changes to Technical Specifications (TS) 3.5.1 are identical with the equivalent requirements of the Standard Technical Specifications (STS) for Westinghouse Plants, NUREG-1431, Rev 1. However, it appears that the proposed change to Surveillance Requirement (SR) 4.5.1.1.a. 1 differs from the STS. Specifically, your proposed change to verify the borated water volume and nitrogen cover-pressure "by the absence of alarms or instrument readings,"

is not consistent with the STS. Please clarify.

Further, the NRC staff completed a comprehensive examination of SRs in TS as part of the TS Improvement Plan (TSIP). The results of this effort were documented in NUREG-1366, "Improvements to Technical Specification Surveillance Requirements." Removal of the requirement to verify the borated water volume and nitrogen cover-pressure "by the absence of alarms," was identified as a TS SR improvement. Guidance to assist licensees in preparing a license amendment to implement these recommendations as line-item TS improvements was included in Generic Letter 93-05, "Line-Item Technical Specifications Improvements To Reduce Surveillance Requirements for Testing During Power Operations."

Harris Nuclear Plant Res onse In response to this request for additional information, HNP proposes to fully implement Generic Letter 93-05 with respect to TS 3/4.5.1. The following are the proposed changes to letters dated March 10, 1997 and May 23, 1997 with respect to TS 3/4.5.1.

Generic Letter (GL) 93-05 dated September 27, 1993, states:

"The NRC staff and industry effoit to develop new STS recognized that accumulator instrumentation operability is not directly related to the capability of the accumulators to perform their safety function. Therefore, surveillance requirements for this instrumentation are being relocated from the new STS and the only surveillance that is being retained is that required to confirm that the parameters defining accumulator operability are within their specified limits".

Therefore, IINP proposes to modify TS 4.5.1.1.a.l, Emergency Core Cooling Systems (ECCS)-

Accumulators, to state "Verifying that the contained borated water volume and nitrogen cover-pl'essure in the tanks are within their limits". Additionally, HNP proposes deleting TS 4.5.1.2.

The calibration requirements for accumulator instrumentation are contained in existing plant maintenance procedures. Changes to maintenance procedures are controlled in accordance with plant change control procedures, the requirements of the Administrative Controls section of the TS, and 10 CFR 50.59.

In addition, GL 93-05 states:

"It should not be necessary to verify boron concentration of accumulator inventory after a volume increase of 1% or more if the makeup water is from the RWST and the minimum concentration of boron in the RWST is greater than or equal to the Page El-1

minimum boron concentration in the accumulator, the recent RWST sample was within specifications, and the RWST has not been diluted."

Therefore, I INP proposes revising TS 4.5.l.l.b to state "This surveillance is not required when the volume increase makeup source is the RWST and the RWST has not been diluted since verifying that the RWST boron concentration is equal to or greater than the accumulator boron concentration limit."The TS requirement for boron concentration in the RWST (2400ppm-2600ppm) is identical to the TS requirement for boron concentration in the accumulators. Therefore, if RWST boron concentration is within its TS requirements, then filling the accumulators from the RWST should not affect accumulator operability with respect to boron concentration.

The surveillance interval for verification of accumulator boron concentration, accumulator pressure, and accumulator level is not being modified by the proposed change. The elimination of surveillance requirements for accumulator instrumentation will not directly impact the ability of accumulators to perform their safety function. Additionally, accumulator sampling should not be required when the makeup source is the RWST. Therefore, this proposed change is compatible with plant operating experience with respect to ECCS Accumulators.

Generic Letter 93-05 provides guidance for preparing a license amendment request to change TS to reduce testing during power operation. These line-item TS improvements are based on the recommendations of an NRC study that included a comprehensive examination of surveillance requirements and is reported in NUREG-1366, "Improvements to Technical Specifications Surveillilllce Requirements," December 1992. This proposed change is consistent with the guidance provided in GL 93-05 and NUREG-1431.

Page E1-2

ENCLOSURE 2 TO SERIAL: HNP-98-147 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.5. 1 SUPPLEMENTAL INFORMATION REVISED PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e 3/4 5-1 3/4 5-1 3/4 5-2 3/4 5-2 B3/4 5-1 B3/4 5-1 B3/4 5-la Page E2-1

ENCLOSURE 3 TO SERIAL: HNP-98-147 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 3/4.5.1 SUPPLEMENTAL INFORMATION TECHNICALSPECIFICATION PAGES Page E3-1