ML18012A498

Application for Amend to License NPF-63,adding New Entry 3.0.5 to 3/4.0 Applicability.New 3.0.5 Provides Specific Guidance for Returning Equipment to Svc for Sole Purpose of Performing Testing to Demonstrate Operability

ML18012A498
Person / Time
Site:	Harris
Issue date:	02/06/1997
From:	ROBINSON W R CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18012A499	List: ML18012A498 ML18012A501
References
HNP-97-026, HNP-97-26, NUDOCS 9702100428
Download: ML18012A498 (15)

Text

ACCESSION'BR:

FACTL:50-400 AUTH.NAME ROBINSONFW.R.

RECIP.NAME CATEGORY 1 REGULATC INFORMATION DISTRIBUTION TEM (RIDE)9702100428 DOC.DATE: 97/02/06 NOTARIZED:

YES Shearon Harris Nuclear Power Plant, Unit.1, Carolina AUTHOR AFFILIATION j arolina Power&Light Co.RECIPIENT AFFILIATION DOCKET N 05000400

SUBJECT:

Application for amend to license NPF-63,adding new entry 3.0.5 to 3/4.0 APPLICABILITY.

New 3.0.5 provides specific guidance for returning equipment to svc for sole purpose of performing testing to demonstrated OPERABILITY.

DISTRIBUTION CODE: AOOZD COPIES RECEIVED:LTR ENCL+SIZE:/Z TITLE: OR Submittal:

General Distribution NOTES:Application for permit renewal filed.C'E 05000400 Q RECIPIENT'ID CODE/NAME PD2-1 LA LE,N COPIES LTTR ENCL 1 1 1 1 RECIPIENT ID CODE/NAME PD2-1 PD COPIES LTTR ENCL 1'0'NTERNAL:

ACRS NRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS2 1 1 1 1 1 1+rE CONTE 1~CB 1 NRR/DSSA/SPLB 1 NUDOCS-ABSTRACT 0 1 1 1 1 1 1 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL 13 Carolina Power&Light Company PO Box 165 New Hill NC 27562 William R.Robinson Vice President Harris Nuclear Plant SERIAL: HNP-97-026 10 CFR 50.90 FEB 6$97 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 EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY-REVISION

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power&Light Company (CP&L)hereby requests a revision to the Technical Specifications (TS)for the I-Iarris Nuclear Plant (HNP).The requested change will add a new entry 3.0.5 to 3/4.0 APPLICABILITY.

The new 3.0.5 provides specific guidance for returning equipment to service under administrative control for the sole purpose of performing testing to demonstrate OPERABILITY.

This revised submittal replaces the original submittal (HNP-97-009 dated January 29, 1997).This revision transmits three pages of Enclosure 5 which were omitted in the original submittal.

It also provides additional clarification of the need for the wording changes in the new Specification 3.0.5 and associated Bases.Enclosure 1 provides a detailed 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 9702%00428 97020b PDR ADGCK 05000400 p PDR State Road1134 NewHill NC Tel 919362-2502 Fax 919362-2095 Document Control Desk HNP-97-026

/Page 2 Enclosure 3 provides an environmental evaluation demonstrating 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. provides the proposed Technical Specification pages.In accordance with 10 CFR 50.91(b), CPAL is providing the State of North Carolina with a copy of the proposed license amendment.

CPEcL requests approval of the proposed amendment by March 15, 1997 to support the next HNP refueling outage, currently scheduled to begin in April 1997.In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be implemented within 30 days of issuance of the amendment.

Please refer any questions regarding this submittal to Ms.D.B.Alexander at (919)362-3190.Sincerely, 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 of his information, knowledge and belief;and the sources of his information are employees, contractors, and agents of Carolina Power 0 Light Company.My commission expires:Notary+Seal) leggy~gOZARV C ii'C gxa~A g Ch Uoi.~C<i~l CO ti)tclli<~

t l Document Control Desk HNP-97-026

/Page 4 bc: Ms.D.B.Alexander 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 (PEEcRAS File)Mr.R.D.Martin Mr.W.S.Orser Mr.G.A.Rolfson Mr.R.S.Stancil Mr.D.L.Tibbitts Mr.M.A.Turkal (BNP)Mr.T.D.Walt Nuclear Records File: HI/A-2D File: H-X-0511 Document Control Desk HNP-97-026

/Page 3 Mr.J.B.Brady, NRC Senior Resident Inspector Mr.Dayne H.Brown, N.C.DEHNR Mr.L.A.Reyes, NRC Regional Administrator Mr.N.B.Le, NRC Project Manager ENCLOSURE TO SERIAL: HNP-97-009 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY Action statements within the Technical Specifications provide guidance for compensatory actions and other restrictions to be taken when the requirements of an LCO cannot be met.When equipment has been out of service it is necessary to demonstrate that it can perform its required function before it can be returned to an OPERABLE condition.

Most testing can be done prior to returning the equipment to service, but in some cases it is necessary to return equipment to a functional status in order to demonstrate an activity required for OPERABILITY.

A particular example for HNP is Specification 3.3.3.1, RADIATION MONITORING FOR PLANT OPERATIONS.

Items l.b and l.c of Table 3.3-6 deal with containment airborne radioactivity monitors during normal and pre-entry purge operation.

Each of these items has an ACTION statement which requires the associated purge valves to be maintained closed in the event the radiation monitor is inoperable.

In order to return the radiation monitor to OPERABLE status it is necessary to demonstrate that the associated purge valves will be automatically closed if a trip setpoint is reached on the monitor.However the only way this test can be performed is by opening the associated valves to observe their closing as a result of the radiation monitor signal, and the valves cannot be opened because of the ACTION statement in force due to the INOPERABLE radiation monitor.This creates a situation in which it can become logically impossible to place the radiation monitor into an OPERABLE condition.

The requested change clarifies that it is permissible to open a purge valve in order to observe its closure by the functional radiation monitor to declare the system OPERABLE.It should be noted that this change would not permit a pre-entry purge valve to be opened in Modes 1, 2, 3, or 4 because that system is not permitted to be OPERABLE in those MODES and therefore the testing would not be valid.Carolina Power&Light Company therefore proposes a new general applicability specification 3.0.5 and associated bases which provide specific guidance on the ability to operate a component under administrative control if necessary to complete a test to demonstrate OPERABILITY.

Page El-l

C ENCLOSURE TO SERIAL: HNP-97-009 This change has no impact on plant equipment or its operation.

This administrative change clarifies that testing necessary to declare equipment OPERABLE may be completed under administrative control.The exception may be used only for a specific purpose and only on equipment that the licensee believes has been repaired or is otherwise capable of carrying out its Technical Specification function.The need for a specific statement of this exception has been recognized by both the industry and the NRC staff and an essentially identical statement is incorporated into the current Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Rev.1 as LCO 3.0.5.The proposed HNP change has minor editorial changes from the wording of NUREG-1431 to reflect the differences in wording of 3.0.1 and 3.0.2 of the current HNP Technical Specifications and LCO 3.0.1 and 3.0.2 of the NUREG.In NUREG-1431, LCO 3.0.1 simply references LCO 3.0.2 for instances of noncompliance and does not mention ACTION statements.

LCO 3.0.5 represents an exception to meeting the Required Actions as presented in a given specification, and since LCO 3.0.2 is the specification which directs compliance with the ACTION requirements, it is the only one to which exception must be taken.The current HNP Technical Specification 3.0.1 contains the phrase"...upon failure to meet the Limiting Condition for Operation, the associated ACTION requirements shall be met".The current HNP Technical Specification

3.0.2 states

"Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and the associated ACTION requirements are not met within the specified time intervals." Therefore, since both of these specifications discuss compliance with ACTION statements, the proposed 3.0.5 states that it is an exception to both 3.0.1 and 3.0.2.p The requested change revises the Technical Specifications to provide specific guidance that components may be operated under administrative control in order to demonstrate OPERABILITY.

The change is functionally identical to the guidance provided on this issue in the current Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Rev.1.Page E1-2 ENCLOSURE TO SERIAL: HNP-97-009 ENCLOSURE2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY 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: Carolina Power&Light Company proposes to add a new general applicability specification 3.0.5 and associated bases which provide specific guidance on the ability to operate a component under administrative control if necessary to complete testing to demonstrate OPERABILITY.

This change clarification 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.

The proposed change does not affect the operation or design of the plant in any way.Operation of plant equipment under this change will not differ in any way from its normal operational mode.The normal operation of plant equipment is not a precursor to any accident.The purpose of tests performed using this change are to demonstrate that Page E2-1 ENCLOSURE TO SERIAL: HNP-97-009 required automatic actions are carried out.Equipment will be operated under administrative control for only a short period of time.Personnel will be immediately available to take appropriate manual action if it should be required.Therefore operation of equipment under this change is not expected to increase the probability or consequences of an accident previously evaluated.

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

The proposed testing allowance does 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 changes do 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.Equipment will be operated under administrative control for only a short period of time.Personnel will be immediately available to take appropriate manual action if it should be required.The purpose of the testing is to restore required equipment to an OPERABLE state which increases the automatic protection available and reduces the reliance on the compensatory measures provided by ACTION statements.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.Page E2-2 ENCLOSURE TO SERIAL: HNP-97-009 ENCLOSURE3 SHEARON HARMS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY 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&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: Carolina Power&Light Company proposes to add a new general applicability specification 3.0.5 and associated bases which provide specific guidance on the ability to operate a component under administrative control if necessary to complete testing to demonstrate OPERABILITY.

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 significant increase in the amounts of any effluents that may be released offsite.Page E3-1 I

ENCLOSURE TO SERIAL: HNP-97-009 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 can not 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.Page E3-2 ENCLOSURE4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY ve 3/4 0-1 B 3/4 0-2 B 3/4 0-2a 3/4 0-1 B 3/4 0-2 B 3/4 0-2a and B 3/4 0-2b