ML18019A635
| ML18019A635 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/28/1986 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NLS-86-046, NLS-86-46, NUDOCS 8603140112 | |
| Download: ML18019A635 (5) | |
Text
REQULAT FORMATION DISTRIBUTION M (RIDS)
ACCESSION NBR: 8603140112 DOC. DATE: 86/02/28 NOTARIZED:
NO DOCKET 0 F*CIL:50-400 Shearon Harris Nuclear Power Planti Unit 1> Carolina 05000400 AUTH. NANE AUTHOR AFFILIATION ZINNERMANpS. R.
Cal olina Power Zc Light Co.
RECIP. NANE RECIPIENT AFFILIATION DENTONp H. R.
Office of Nuclear Reactor Regulationi~rector (post 851125
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SUBJECT:
Forwards draft Rev 0 to PLP-10&i "Tech Spec Equipment List Program" for review. Listed Tech Spec Sections
- 3. 6. 3i
- 3. 7. 10. 2i 3. 7. 10. 3i 3. 8. 4.
1 Cc 3. 8. 4. 2 proposed f.or deletion due to lengthiness.
DISTRIBUTION CODE:
B001D COPIES RECEIVED: LTR ENCQ SIZE:
TITLE: Licensing Submittal:
PSAR/FSAR Amdts 0 Related C rrespondence NOTES:
RECIPIENT ID CODE/NANE PWR-A *DTS PWR-A EB PWR-A FOB BUCKLEY'S B 01 PWR-A RSB INTERNAL: ADN/LFMB IE FILE IE/DGAVT/GAB 21 NRR PWR-A ADTS NRR ROE> M. L NRR/DHFT/NTB RGN2 EXTERNAL: 24X DMB/DSS (ANDTS)
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1 TOTAL NUNBER OF COPIES REQUIRED; LTTR 33 ENCL 27
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CNK Carolina Power & Light Company FEB 2 8>986 SERIAL: NLS-86-006 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. l - DOCKET NO.50-000 TECHNICALSPECIFICATION EQUIPMENT LIST PROGRAM
Dear Mr. Denton:
Carolina Power 2 Light Company (CPRL) submits the Technical Specification Equipment List Program (TSELP) for the Shearon Harris Nuclear Power Plant (SHNPP).
CPi!cL proposes to delete the following lengthy and detailed lists from the SHNPP Technical Specifications (TS):
I) 2)
3) q)
5)
Containment Isolation Valves (TS 3.6.3)
Preaction and Multicycle Sprinkler Systems (TS 3.7. l0.2)
Fire Hose Stations (TS 3.7.10.3)
Containment Penetration Overcurrent Protection Devices (TS 3.8A.I)
Motor-Operated Valve Thermal Overload Protection (TS 3.8.0.2)
Historically, the NRC has required these lists to be maintained as tables in the TS,
- however, CPRL proposes to maintain them in the TSELP.
The TSELP would be referenced by the individual TS and would be administratively controlled in a manner similar to the Process Control Program and Off-Site Dose Calculation Manual. A copy of the draft TSELP is provided as Attachment I and the proposed Administrative Control TS is provided as Attachment 2.
This alternative proposal would be beneficial to both the NRC and CPitrL, in that having these lists in the TS has an overall detrimental effect on the TS due to the complications they create in the plant modification process.
By maintaining these lists independent of the TS, but still fulfillingthe regulatory requirements, the lists may be maintained more current and accurate with respect to the actual plant configuration without delays typically encountered with Operating License/TS amendments.
Furthermore, this proposal would not have any adverse affect on the NRC inspection and enforcement activities regarding this equipment.
The TSELP provides the detailed lists for use by various plant and NRC inspection personnel in a controlled document.
Administrative controls, over and above those normally required for procedure review, will govern changes to the TSELP.
The TSELP and associated procedures and documentation are available for inspection and audit by NRC personnel.
8603140fi2 860228 PDR ADOCK 05000400 A
PDR 411 Fayettevitte Street o P. O. Box 1551 o Raleigh. N. C. 27602
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"~" Mr. H. R. Denton NLS-86-006 Page 2
An example of the problems created by having lengthy lists in the TS is the snubber specification, which has been revised to delete the lengthy listing of snubbers.
In the late 1970's the staff required a TS for snubbers.
This TS included a detailed list of snubbers by system and location and was often ten to twenty pages in length.
Problems developed almost immediately as plant modifications were implemented.
Due to the length of time required to process a TS amendment, questions quickly arose about how to handle both snubbers removed and added by modifications.
In recognition of the many problems created by the snubber list in the TS, the NRC implemented several variations of simplifying the TS and reducing the level of detail required.
The current snubber TS in Revision 5 to the Westinghouse Standard TS (NUREG-0052) does not require a detailed list.
The TSELP recognizes the lessons learned from the snubber TS and applies them to other tables in the SHNPP TS.
This proposal is consistent with current industry and NRC efforts for TS improvement.
Approval of this proposal will not impede later implementation of more comprehensive TS improvements.
CPRL requests that the NRC review the attached draft TSELP and approve the concept of removing the requested lists from the SHNPP TS.
A final approved version of the TSELP will be submitted to the NRC prior to the issuance of an operating license.
CPRL is willing to meet with you as soon as possible to discuss this matter further. If you have any further questions, please contact Mr. Gregg A. Sinders at 919-836-8I68.
Yours very truly, SRZ/GAS/ljs (3307GAS)
Attachment S.. Zim erman nager Nuclear Licensing Section CC:
Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. 3. Nelson Grace (NRC-RII)
Mr. Travis Payne (KUDZU)
Mr. Daniel F. Read (CHANGE/ELP)
Mr. V. Benaroya (NRC)
Mr. R. A. Benedict (NRC)
Mr. E. 3. Butcher, 3r. (NRC)
Mr. T. M. Novak (NRC)
Wake County Public Library Mr. Wells Eddleman Mr. 3ohn D. Runkle Dr. Richard D. Wilson Mr. G. O. Bright (ASLB)
Dr. 3. H. Carpenter (ASLB)
Mr. 3. L. Kelley (ASLB)
Mr. H. A..Cole Mr. L. S. Rubenstein (NRC)
Mr. M. 3.-Virgilio(NRC)