HNP-97-036, Application for Amend to License NPF-63,revising TS 3.5.1 to Provide Optional Method of Meeting Surveillance Requirement & to Add New Action Statement Re Boron Concentration
| ML18022B005 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/10/1997 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18022B006 | List: |
| References | |
| HNP-97-036, HNP-97-36, NUDOCS 9703190005 | |
| Download: ML18022B005 (14) | |
Text
CATEGORY 1 REGULAT(%P INFORMATION DISTRISUTIONOSTEM (RIDE)
ACCESSXOQ NB/:9703190005 DOC.DATE: 97/03/10 NOTARIZED: YES FpCXQ~56-4t<0 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.'NAME AUTHOR AFFXLIATXON ROBINSON,W.R.
Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Application for amend to license NPF-63,revising TS 3.5.1 to provide optional method of meeting surveillance requirement to add new Action statement re boron concentration.
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Carolina Power & Light Company PO Box 165 New Hill NC 27562 William R. Rabinson Vice President Harris Nuclear Plant SERIAL: I-INP-97-036 10 CFR 50.90 NQ 10 lS97 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONAND SURVEILLANCEFOR ECCS ACCUMULATORS
Dear Sir or Madam:
In accordance with the Code ofFederal Regulations, Title 10, Part 50.90, Carolina Power &,
Light Company (CPAL) hereby requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The requested change revises Specification 3.5.1, Emergency Core Cooling Systems (ECCS) Accumulators to provide an optional method ofmeeting a surveillance requirement and to add a new Action statement to cover a condition with boron concentration not within limits for one accumulator.
Enclosure 1 provides a detailed description ofthe proposed changes and the basis for the changes. 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. provides an environmental evaluation demonstrating that the proposed amendment meets the eligibilitycriteria 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 ofthis amendment request.
9703i90005 970310 PDR ADQCK 05000400 p
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State Road 113'ew Hill NC Tel 919 362-2502 Fax 919 362-2095 provides page change instructions for incorporating the proposed revisions. provides the proposed Technical Specification pages.
In accordance with 10 CFR 50.91(b), CP&L is providing the State ofNorth Carolina with a copy ofthe proposed license amendment.
Please refer any questions regarding this submittal to Ms. D. B. Alexander at (919) 362-3190.
In order to allow time for procedure revision and orderly incorporation into copies ofthe Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be implemented within 60 days ofissuance ofthe amendment.
Sincerely, Vice President Harris Nuclear Plant CSB/twk
Enclosures:
- 1. Basis for Change Request 2.
10 CFR 50.92 Evaluation
- 3. Environmental Considerations
- 4. Page Change Instructions
- 5. Technical Specification Pages W. R. Robinson, 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 of his information are employees, contractors, and agents ofCarolina Power &Light Company.
My commission expires: g Q -A0 00 Nota',gyral
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'Mr. J. B. Brady, NRC Senior Resident Inspector Mr. M Fry, N.C. DEHNR Mr. L. A. Reyes, NRC Regional Administrator Mr. N. B. Le, NRC Project Manager
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Ms. P. B. Brannan Mr. Charles S. Bohanan Mr. H. Chernoff (RNP)
Mr. G. W. Davis Mr. J. W. Donahue Ms. S. F. Flynn Mr. H. W. Habermeyer, Jr.
Mr. W. J. Hindman Ms. W. C. Langston (PE&RAS File)
Mr. R. D. Martin Mr. W. S. Orser Mr. G. A. Rolfson Mr. D. L. Tibbitts Mr. M. A. Turkal (BNP)
Mr. T. D. Walt Nuclear Records File: HI/A-2D File: H-X-0511
ENCLOSURE 1
SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONAND SURVEILLANCEFOR ECCS ACCUMULATORS BASIS FOR CHANGE RE UEST
~Back round The ECCS accumulators are pressure vessels partially filledwith borated water and pressurized with nitrogen gas. During normal operation each accumulator is isolated from the Reactor Coolant System (RCS) cold legs by two check valves in series.
Should the RCS pressure fall below the accumulator pressure of5S5 to 665 psig, the check valves open and borated water is forced into the RCS. Mechanical operation ofthe swing disc check valve is the only action required to open the injection path from the accumulator to the core via the cold leg.
Surveillance 4.5.1.1.a.1 requires that the contained borated water volume and nitrogen cover pressure ofthe ECCS Accumulators be verified every'12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The current specification requires this verification to be done by observation ofthe absence ofaccumulator alarms and provides no alternative method ofcompliance.
The alarm setpoints are set conservatively with respect to the Technical Specification limits which means that an alarm may be present for an accumulator which meets all limits. No allowance is currently provided for a failed alarm circuit. The requested change allows the observation and recording ofthe actual instrument readings as an acceptable way to meet the surveillance requirements.
In addition to the requested change in acceptable surveillance methods, a new Action c is proposed which defines corrective measures to be taken when an accumulator is out oflimits on dissolved boron concentration.
The new action willpermit a period of72 hours to restore the accumulator to within the boron concentration limits before proceeding to shutdown the unit and reduce the pressure ofthe reactor coolant system to less than 1000 psig. Appropriate changes are proposed for Action a to bypass Action b for boron concentration limitconditions.
Basis The surveillance requirement revision simply recognizes that observation ofthe actual accumulator parameters is an acceptable alternative to a determination that there are no accumulator alarms as a surveillance method. This is acceptable because the accumulator is a static component and rapid changes in values are not expected.
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency willallow for the early detection and correction ofoffnormal trends.
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The purpose ofthe ECCS accumulators is to supply borated water to the RCS when pressure drops below the accumulator nitrogen pressure.
Since current HNP analyses show that the accumulators do not discharge following a large steam line break, the transient in which the accumulators are primarily required is the large break Loss ofCoolant Accident (LOCA). The accumulators are one ofthe three sources for ECCS water to reach the core. The other sources are the two high head Charging Safety Injection pumps and the two low head Residual Heat Removal pumps. Allofthe sources provide borated water, but for a large break LOCA the accumulators are the first ofthe ECCS sources to begin delivering water. In the initial stages of a large break LOCAreactivity control is provided by the voiding in the core and not by borated water. When accumulators do inject, most oftheir water does not enter the core. Analyses assume that water from the accumulators does not begin to reach the core until the "beginning-of core-recovery" (BOCREC). Analyses show that accumulators inject for approximately 20 seconds and ofthis time the time aAer BOCREC is only about 2 to 2.5 seconds, which would deliver approximately 1000 gallons to the core from an accumulator. Atthis time the much larger flowof borated water from the high and low head pumps is being injected into the core at a total flowrate ofapproximately 2500 gallons per minute. It is this total ECCS flowofborated water which supplements the reactivity control which is still primarily provided by system voids during the reflood period.
An additional consideration is that an accumulator which is outside ofthe boron concentration limitis unlikely to be very far from the limit. An accumulator is a static system which typically has very slow changes in conditions, since there are no routine makeups to or discharges from the system except for monthly samples to verify boron concentration.
The worst case is clearly one in which the accumulator has no boron. Even in this case the discussion above demonstrates that one accumulator below the minimum boron concentration limitwillhave no effect on the amount ofECCS water available and an insignificant effect on core subcriticality during reflood.
Boiling ofECCS water in the core willconcentrate boron and the volume ofone accumulator is relatively small (-2%) compared to the volume ofwater available during recirculation flow.
Therefore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is proposed as an acceptable time period to return the boron concentration within limits. This time period is consistent with the allowed out ofservice times for other Engineered Safety Features such as a Charging Safety Injection pump or an Emergency Diesel Generator.
Both ofthese proposed changes to Specification 3.5.1 are identical with the equivalent requirements ofthe Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Rev. 1.
Conclusions The requested change revises Technical Specification 3.5.1 to allow the use ofinstrument Page E1-2
'eadin'gs to meet surveillance 4.5.1.1.a.l, and adds a new Action c to cover a condition in which one accumulator has a boron concentration not within limits. Both ofthese changes to Specification 3.5.1 are identical with the equivalent requirements ofthe Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Rev. 1.
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ENCLOSURE2 SHEARON HARMS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONANDSURVEILLANCEFOR ECCS ACCUMULATORS 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 facilityinvolves no significant hazards consideration ifoperation ofthe facilityin 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 ofsafety.
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
Carolina Power &Light Company proposes to revise Specification 3.5.1, ECCS Accumulators to provide an optional method of meeting surveillance requirements and to add a new Action statement to cover a condition for one accumulator with its boron concentration not within limits.
Basis This change clarification 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 ofan accident previously evaluated.
The accumulators are not initiators ofany event and so the probability ofoccurrence of an event is unaffected by either ofthe proposed changes.
The use ofactual instrumentation readings to comply with the surveillance does not change the function or performance ofthe accumulators and thus does not affect any accident consequences.
The increase in the allowed time to restore the boron concentration to within limits is consistent with allowed out ofservice times for other Emergency Safeguards equipment.
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't willnot have a significant impact on subcriticality during refiood. Therefore, there will be no increase in the consequences ofan accident.
2.
The proposed amendment does not create the possibility ofa new or different kind of accident from any accident previously evaluated.
The proposed changes to the accumulator specification do,not involve any physical alterations or additions to plant equipment or alter the manner in which any safety-related system performs its function. Therefore, the proposed change does not create the possibility ofa new or different kind ofaccident from any accident previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the margin ofsafety.
The proposed change to the surveillance requirement provides an equivalent means of meeting the requirement.
Since there is no change in either the accumulator limits or the surveillance frequency, there is no reduction in safety margin. The new Action c to address returning the boron concentration ofa single accumulator to within limits allows an out ofservice time commensurate with the times allowed for other Engineered Safeguards Features.
The boron concentration ofone accumulator does not have a significant impact on subcriticality during reflood and thus does not involve a reduction in the margin ofsafety.
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ENCLOSURE3 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONAND SURVEILLANCEFOR ECCS ACCUMULATORS ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification oflicensing 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 if operation ofthe facilityin 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 effluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure.
Carolina Power Ec 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 ofthe amendment.
The basis for this determination follows:
Pro osed Chan e
Carolina Power 8'c Light Company proposes to revise Specification 3.5.1, ECCS Accumulators to provide an optional method of meeting surveillance requirements and to add a new Action statement to cover a condition for one accumulator with its boron concentration not within limits.
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.
The proposed amendment does not result in a significant change in the types or significant increase in the amounts ofany effluents that may be released offsite.
The proposed change does not involve any new equipment or require existing systems to perform a different type offunction than they are currently designed to perform. The Page E3-1
change does not introduce any new effluents or increase the quantities ofexisting 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 effect on either individual or cumulative occupational radiation exposure.
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ENCLOSURE4 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONAND SURVEILLANCEFOR ECCS ACCUMULATORS PAGE CHANGE INSTRUCTIONS Removed Pa e
3/4 5-1 B 3/4 5-1 Inserted Pa e
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ENCLOSURE5 SHEARON HARRIS NUCLEARPOWER PLANT NRC DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REVISED ACTIONAND SURVEILLANCEFOR ECCS ACCUMULATORS TECHNICALSPECIFICATION PAGES