ML18016A976

Application for Amend to License NPF-63,revising TS 6.5, Review & Audit, TS 6.8, Procedures & Program & TS 6.10, Record Retention.

ML18016A976
Person / Time
Site:	Harris
Issue date:	06/02/1999
From:	Scarola J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18016A977	List: ML18016A976 ML18016A978
References
RTR-NUREG-1431 AL-95-06, AL-95-6, HNP-99-092, HNP-99-92, NUDOCS 9906080252
Download: ML18016A976 (9)

Text

CArZGOaz REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9906080252 DOC.DATE: 99/06/02 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina DOCKET 05000400 I

COUTH.NAME AUTHOR AFFILIATION SCAROLA,J. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Application for amend to license NPF-63,revising TS 6.5, "Review & Audit," TS 6.8, "Procedures & Program" 6 TS 6.10, "Record Retention."

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution 1 ENCL I SIZE: II ~ Z$

NOTES:Application for permit renewal filed. 05000400 E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0 LPD2-2 LA 1 1 LPD2-2 PD 1 1 LAUFER,R. ~

1 1 R INTERNAL: ACRS 1 1 1 NRR/DE/EEIB 1 1 NRR/DE/EMCB 1 1 NRR/DE/EMEB 1 1 NRR/DSSA/SPLB 1 1',l NRR/3 SSA/SRXB 1 1 NRR/SPSB JUNG,I NUDOCS-ABSTRACT 1 1 OGC/RP 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

'E WASTETH NOTE TO ALL "RZDS" RECIPIENTS:

PLEASE HELP US TO REDUCE TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPZES RECEIVED BY YOU OR YOUR LISTS ORGANIZATION, CONTACT THE DOCUMENT ENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 14

Carolina Power & Light Company James Scarola PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-99-(}92 JUN 2 1999 10 CFR 50.90 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 TECHNICAL SPECIFICATIONS 6.5,6.8, AND 6.10

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power 0 Light Company (CP&L) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment revises TS 6.5, "REVIEW AND AUDIT", TS 6.8 "PROCEDURES AND PROGRAMS" and TS 6.10 "RECORD RETENTION". This change is consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995 and the guidance provided by NRC Administrative Letter 95-06, dated December 12, 1995.

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 is required for approval of this amendment request.

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

Enclosure 5 provides the proposed Technical Specification pages.

9906080252 990602 l PDR AoaCV, OS000mOI

( P PDR J 5413 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095

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CPEcL 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, cw~M J. 5'cg/ddt z.

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 C. L. Burton, 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 2 Light Company.

Notary (Seal)

My commission expires:

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~UBUC Mr. J. B. Brady, NRC Sr. Resident Inspector Mr. Mel Fry, Director, NC DEHNR Mr. R. J. Laufer, NRC Project Manager +>tnsiscl4~~

Mr. L. A. Reyes, NRC Regional Administrator

ENCLOSURE 1 TO SERIAL: HNP-99-092 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 6.5,6.8, AND 6.10 BASIS FOR CHANGE RE UEST B~ack round As described in NRC Administrative Letter (AL) 95-06, dated December 12, 1995:

Among U.S. NRC efforts related to technical specification improvements are the issuance of a revision to 10 CFR 50.36, revisions to Standard Technical Specifications, some generic communications, and many individual license amendments. The revision of 10 CFR 50.36 included specific criteria for determining those design conditions that warrant inclusion in technical specifications as limiting conditions for operation (LCO). The staff has reviewed and approved many recent amendment requests that involved incorporating parts of the improved Standard Technical Specifications, relocating requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as LCO, and relocating requirements that are controlled directly by regulations and related licensee programs. The relocation of technical specification requirements has included administrative controls as well as limiting conditions for operation and related surveillance requirements.

Increasingly, licensees are requesting amendments to technical specifications that are located in the "administrative controls" section and are related to quality assurance programs. Recent amendment requests related to quality assurance have also followed the trend for other technical specifications and have included moving requirements to licensee controlled documents and programs. The quality assurance program is a logical candidate for such relocations due to the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the existence of U.S. NRC-approved quality assurance plans and commitments to industry quality assurance standards, and the established quality assurance program change control process in 10 CFR 50.54(a). The relocation of technical=specification requirements in cases where adequate controls are provided by such other means can reduce the resources spent by licensees and the U.S. NRC staff in preparing and reviewing license amendment requests.

Harris Nuclear Plant (HNP) Technical Specifications (TS) contain similar administrative control requirements as described in NRC AL 95-06. HNP proposes to relocate the specified TS administrative controls requirements intact from HNP TS to the HNP Quality Assurance Program Description (QAPD) located in HNP Final Safety Analysis Report (FSAR) Section 17.3.

Pro osed Chan e Harris Nuclear Plant (HNP) proposes to relocate HNP Technical Specifications (TS) Section 6.5, "REVIEW AND AUDIT", TS Section 6.8.2, and Section 6.8.3, and TS 6.10 "RECORD RETENTION intact from HNP TS to the Quality Assurance Program Description currently located in HNP Final Safety Analysis Report Section 17.3. Future changes with the associated relocated TS willbe processed in accordance with 10 CFR 50.54(a).

Basis With respect to limiting conditions for operations (LCO), 10 CFR 50.36 provides four criteria to be used in determining whether particular safety functions are required to be included in the TS.

In adopting the revision to the rule, the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS (60 FR 36957).

Addressing administrative controls, 10 CFR 50.36 states that they "are the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The specific content of the administrative controls section of the TS is, therefore, that information the Commission deems essential for safe operation of the facility that is not already covered by other regulations.

Accordingly, the staff has determined that requirements that are not specifically required under

10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from administrative controls.

The proposed amendment would relocate intact the review and audit function specified in existing TS Section 6.5 to the HNP Quality Assurance Program Description (QAPD) ~

Additionally, HNP proposes to relocate TS 6.8.2 and TS 6.8.3 intact to the QAPD as these sections relate to TS Section 6.5.1 (Safety and Technical Reviews). Future changes to review and audit requirements in the QAPD will be processed in accordance with 10 CFR 50.54(a). NRC AL 95-06 states "The technical specification requirements related to review and audit requirements may be relocated to the quality assurance plan." The Review and Audit section (TS Section 6.5) in HNP TS contains:

~ Safety and Technical Reviews (TS Section 6.5.1)

~ Plant Nuclear Safety Committee (TS Section 6.5.2)

~ Nuclear Assessment Section Independent Review Program (TS Section 6.5.3)

~ Nuclear Assessment Section Assessment Program (TS Section 6.5.4)

~ Outside Agency Inspection and Audit Program (TS Section 6.5.5)

TS Sections 6.8.2 and 6.8.3 describe requirements associated with the procedure review process at HNP. NRC AL 95-06 states that procedure review process requirements may be relocated to the quality assurance plan. HNP proposes to relocate procedure revision process requirements from TS 6.8.2 and TS 6.8.3 intact to the QAPD. Future changes to the relocated procedure review requirements would be processed in accordance with 10 CFR 50.54(a).

TS Sections 6.10 describes requirements associated with record retention. NRC AL 95-06 states that TS requirements associated with records and record retention can be relocated to the quality assurance plan provided that subsequent changes are in accordance with 10 CFR 50.54(a). HNP proposes to relocate record retention requirements from TS 6.10 intact to the QAPD. Future changes to record retention requirements willbe processed in accordance with 10 CFR 50.54(a).

These changes are consistent with NUREG-1431, Revision 1 and in accordance with the guidance specified in NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," issued on December 12, 1995.

ENCLOSURE 2 TO SERIAL: HNP-99-092 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATIONS 6.5,6.8, AND 6.10 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 & 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 to relocate HNP Technical Specifications (TS) Section 6.5, "REVIEW AND AUDIT", TS Section 6.8.2, and Section 6.8.3, and TS 6.10 "RECORD RETENTION intact from HNP TS to the Quality Assurance Program Description currently located in HNP Final Safety Analysis Report Section 17.3. Future changes with the associated relocated TS willbe processed in accordance with 10 CFR 50.54(a).

Basis This change does not involve a significant hazards consideration for the following reasons:

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

This TS change relocates administrative requirements from HNP TS to the Quality Assurance Program Description (QAPD). The proposed amendment will not introduce any new equipment or require existing equipment to function different from that previously evaluated in the Final Safety Analysis Report (FSAR) or TS.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment will not introduce any new equipment or require existing equipment to function different from that previously evaluated in the Final Safety Analysis Report (FSAR) or TS. The changes are consistent with NUREG-1431, Revision 1 and the Commission's Final Policy Statement on Technical Specification improvements. The proposed amendment will not create any new accident scenarios,

because the change does not introduce any new single failures, adverse equipment or material interactions, or release paths.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment does not involve a significant reduction in the margin of safety.

This TS change relocates administrative requirements from HNP TS to the Quality Assurance Program Description (QAPD). The QAPD will be revised to include the requirements associated with this proposed change. NRC Administrative Letter 95-06 states that administrative requirements for review and audit and the independent safety engineering group may be relocated from TS to the quality assurance program. HNP proposes relocating the associated requirements from TS to the QAPD intact. Future changes to these requirements will be processed in accordance with 10 CFR 50.54(a).

This proposed TS change is administrative in nature and does not alter NRC acceptance limits with respect to accident mitigation or accident analysis.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

E2-2

ENCLOSURE 3 TO SERIAL: HNP-99-092 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATIONS 6.5,6.8, AND 6.10 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 if operation 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 k 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 Harris Nuclear Plant (HNP) proposes to relocate HNP Technical Specifications (TS) Section 6.5, "REVIEW AND AUDIT", TS Section 6.8.2, and Section 6.8.3, and TS 6.10 "RECORD RETENTION intact from HNP TS to the Quality Assurance Program Description currently located in HNP Final Safety Analysis Report Section 17.3. Future changes with the associated relocated TS willbe processed in accordance with 10 CFR 50.54(a).

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.

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 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 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.

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 surveillance which would require additional personnel entry into radiation controlled areas.

Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

ENCLOSURE 4 TO SERIAL: HNP-99-092 SHEARON HARMS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATIONS 6.5,6.8, AND 6.10 PAGE CHANGE INSTRUCTIONS REMOVE PAGE INSERT PAGE XV111 XV111 X1X X1X 6-7 6-7 6-8 6-9 6-10 6-11 6-12 6-13 6-14 6-17 6-17 6-24c 6-24c 6-25 6-26 6-26 6-27 6-27