ML18012A141

Application for Amend to License NPF-63,revising TS 4.3.2 Re ESFAS Instrumentation

ML18012A141
Person / Time
Site:	Harris
Issue date:	02/16/1996
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18012A143	List: ML18012A141 ML18012A144
References
HNP-96-025, HNP-96-25, NUDOCS 9602230360
Download: ML18012A141 (12)

Text

CATEGORY j.REGULATO..

INFORMATION DISTRIBUTION STEM (RIDS)ACCESSI68 NBR:9602230360 DOC.DATE: 96/02/16 NOTARIZED:

YES FACIL':50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION ROBINSON,W.R.

Carolina Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)SUB.3ECT: Application for amend to License NPF-63,request.

TS 4.3.2 re ESFAS instrumentation.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR l ENCL J SIZE: TITLE: OR Submittal:

General Distribution DOCKET 05000400 NOTES:Application for permit renewal filed.05000400 E RECIPIENT ID CODE/NAME PD2-1 LA LE,N INTERNAL: ACRS NRR/DE/EMCB NRR/DSSA/SPLB NUDOCS-ABSTRACT EXTERNAL.'NOAC'I COPIES LTTR ENCL 1 1 1 1 6 6 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD2-1 PD ILE CENTER/'DRCAfH CB NRR/DSSA/SRXB OGC/HDS2 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1"1 1 0 1 1 D U E 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 18 ENCL 17 r

Carolina Power&Light Company PO Box 165 New Hill NC 27562 William R.Robinson Vice President Harris Nuclear Plant SERIAL: HNP-96-025 10 CFR 50.90 FEB 16 1996 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 EXIGENT LICENSE AMENDMENT ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS)INSTRUMENTATION Gentlemen:

In accordance with the provisions of Title 10, Code of Federal Regulations, Parts 2.101, 50.90 and 50.91(a)(6), Carolina Power&Light Company (CP&L)hereby requests an exigent revision to the Tcchnical Specifications (TS)for thc Harris Nuclear Plant (HNP).Technical Specification (TS)4.3.2, Engineered Safety Features Actuation System (ESFAS)Instrumentation, requires that each instrumentation channel and interlock and the automatic actuation logic and relays be demonstrated operable by performance of survcillancc testing specified in TS Table 4.3-2.Table 4.3-2, Item l.a requires that a trip actuating device operational test be performed for Safety Injection manual initiation at'east every 18 months.Also, TS 4.3.2 requires that the response time of each ESFAS function bc demonstrated to be within limits at least once every 18 months.Thc redundant SSPS trains at the Harris Nuclear Plant arc designed to automatically initiate a safety injection on receipt of various input parameters.

HNP operators also have the capability of manually initiating safety injection if the automatic initiation logic fails or in anticipation of an automatic signal.Redundant manual actuation of safety injection is provided on the Main Control Board (MCB)by two switches, one on panel A and onc on panel C.Each switch provides input to both trains (a total of four contacts)of thc Solid State Protection System (SSPS).During systematic review of testing procedures, while both switches were manipulated, CP&L discovered that only thrcc of the four switch contacts have bccn tested in the required 18-month periodicity.

The fourth switch contact (Train B input contact from panel C switch)was last tested on May 2, 1994.Thc 18-month survcillancc for that contact will expire on March 16, 1996.Contact testing cannot be performed at power bccausc of thc risk of causing plant transients.

Testing at power would rcquirc blocking thc manual SI input to both trains from this switch.Because both panel A and C switch contacts feed the same terminal in the SSPS logic cabinet, lifting leads would also cause thc MCB panel A manual switch to bc inoperable.

A plant shutdown to Mode 5 would be required in order to comply with the TS surveillance requirements.

Thcrcforc, CP&L is requesting a one-time cxtcnsion of thc testing interval for this fourth contact by an exigent revision to the HNP Tcchnical Specifications.

9602230360 960216 PDR,, ADQCK OS000400 P~I PDR State Road 1134 New Hill NC Tel 919 362-2502 Fax 919 362-2095 Document Control Desk HNP-96-025

/Page 2 Operational and test history demonstrates that these switch contacts arc inhcrcntly reliable.In the unlikely event that this contact fails, operators still have the ability to actuate either Train A or Train B of thc SSPS with the redundant switch on MCB panel A.10 CFR 50.91(a)(6)(vi) rcquircs that a liccnsec explain the nature of the exigency and why the exigency could not have been avoided.As a part of thc self-assessment program at thc Harris Nuclear Plant, CP&L began a systematic review of TS surveillance procedures associated with the actuation logic for ESF component in the last quarter of 1995.CP&L discovered the testing discrepancy on February 12, 1996.It was unforeseeable when the review began that such a discrepancy would bc discovcrcd within 33 days of the SSPS Train B input from thc MCB panel C switch becoming inoperable, based upon the 18-month surveillance requirement.

Therefore, a license amcndmcnt rcqucst could not bc feasibly submitted to the NRC in time to allow for thc normal notice and review process of 10 CFR 50.91.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 thc Company's determination that the proposed changes do not involve a significant hazards consideration. provides an cnvironmcntal evaluation which dcmonstratcs that the proposed amendment meets the eligibility criteria for categorical exclusion sct forth in 10 CFR 51.22(c)(9).

Thcreforc, pursuant to 10 CFR 51.22(b), no environmental asscssmcnt needs to be prepared in connection with the issuance of the amendment. provides Page Change Instructions. provides thc proposed Technical Specification pages.In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina with a copy of the proposed license amendmcnt.

Please refer any questions regarding this submittal to Mr.T.D.Walt at (919)362-2711.Sincerely, LSR/Isr

Enclosures:

1.Basis for Change Request 2.10 CFR 50.92 Evaluation 3.Environmental Considerations 4.Page Change Instructions 5.Tcchnical Specification Pages Document Control Desk HNP-96-025

/Page 3 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 employccs, contractors, and agents of Carolina Power&Light Company.My commission cxpircs: P-(c-P iysp ss s Mr.Dayne H.Brown/Director, Div.of Radiation Protection (NC)Mr.S.D.Ebneter/NRC Regional Administrator Mr.N.B.Lc/NRR Project Manager Mr.D.J.Roberts/NRC Resident Inspector Notary (S)~gQ5i I ft~~@O~ARF Opet~~CQS oi~illfllflll" I P~~r ENCLOSURE TO SERIAL: HNP-96-025 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR EXIGENT LICENSE AMENDMENT ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS)INSTRUMENTATION BASIS FOR CHANGERE UEST~Back round Technical Specification (TS)4.3.2, Enginecrcd Safety Features Actuation System (ESFAS)Instrumentation, requires that each instrumentation channel and interlock and thc automatic actuation logic and relays be demonstrated operable by pcrformancc of surveillance rcquiremcnts spccificd in TS Table 4.3-2.Table 4.3-2, Item l.a requires that a trip actuating device operational test be performed for Safety Injection manual initiation at least every 18 months.Also, TS 4.3.2 requires that thc response time of each ESFAS function be demonstrated to bc within limits at least once every 18 months.In the 4th Quarter of 1995, Carolina Power&Light Company (CP&L)began a systematic review of TS surveillance procedures for the Reactor Protection System, the Emcrgcncy Diesel Generator Load Sequencer, and the Engineered Safety Features components.

On February 12, 1996, CP&L pcrsonncl discovered that Operations Surveillance Tests (OSTs)for testing manual Safety Injection actuation do not completely test all required switch contacts in the required periodicity.

OSTs 1825 (Safety Injection:

ESF Response Time, Train A)and 1826 (Safety Injection:

ESF Rcsponsc Time, Train B), which arc pcrformcd on staggered 18-month intervals, test the manual initiation of Safety Injection (SI)and the response time of ESFAS components.

In performing OST 1825 (A Train), both A and B Train SSPS inputs from the SI switch on MCB panel A arc verified during the actuation testing, and the SSPS Train A input from the SI switch on MCB panel C is verified during the response time testing.Thc SSPS Train B input from the SI switch on MCB panel C is lifted for this part of the test.Likewise, in performing OST 1826 (B Train), both A and B Train SSPS inputs from the SI switch MCB panel A are tested, and thc SSPS Train B input from the SI switch on MCB panel C is tested.The SSPS Train A input from thc SI switch on MCB panel C is lied for this part of thc test.Therefore, thc A and B Train SSPS inputs from thc SI switch on thc MCB panel C have not bccn tcstcd cvcry 18 months as required by the TS.OST 1825 was last performed on October 5, 1995 and OST 1826 was last performed on May 2, 1994.Accordingly, the B input from the SI switch will become inoperable on March 16, 1996 because thc 18-month survcillancc rcquircment will not bc met.Contact testing cannot bc pcrformcd at power because of the risk of causing plant transients.

Testing at power would rcquirc blocking the manual SI input to both trains from this switch.Because both panel A and C switch contacts feed thc same terminal in thc SSPS logic cabinet, lifting leads would also cause the MCB panel A manual switch to bc inoperable.

Therefore, a plant shutdown to Mode 5 would be required in order to comply with the TS surveillance requirements.

Page El-1 ENCLOSURE TO SERIAL: HNP-96-025 The proposed amendment would annotate with an asterisk the"R" periodicity for the Trip Actuating Device Operational Test for Item l.a (Safety Injection-Manual Initiation) in TS Table 4.3-2.A corresponding note would be added to that TS page to specify that the SSPS Train B input from the MCB panel C SI switch will be tested before reactor startup from Refueling Outage No.7, or when thc plant is in Mode 5 for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, whichever occurs first.This is a one-time change.Basis The redundant SSPS trains at the Harris Nuclear Plant are designed for automatic ESF acuation.Redundant manual switches on the MCB also provide operators with manual ESF actuation if the automatic initiation fails or in anticipation of an automatic signal.Onc switch is on MCB panel A and thc other is on MCB panel C.Each switch provides input to both trains (a total of four contacts)of the Solid State Protection System (SSPS).This proposed one-time license amendment in no way affects thc automatic ESFAS initiation.

This change only pertains to the panel C switch, and specifically, the B Train SSPS contact.Should this switch become inoperable or fail for any reason, operators would use thc redundant switch on panel A.General Design Criterion (GDC)21 (Protection System Reliability and Tcstability) requires that"no single failure results in loss of the protection function." If it is assumed that the SSPS Train B input from MCB panel C is INOPERABLE and a failure of the switch on MCB panel A occurs, thc Train A protection function is still available from the SSPS Train A input from the switch on MCB panel C.Page El-2 ENCLOSURE TO SERIAL: HNP-96-025 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS)INSTRUMENTATION 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 amcndmcnt to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with thc proposed amendmcnt would not: (1)involve a significant increase in the probability or consequences of an accident previously cvaluatcd, (2)create the possibility of a ncw 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 revicwcd this proposed license amendment request and detcrmincd that its adoption would not involve a significant hazards determination.

The bases for this determination arc as follows: Pro osed Chan e The proposed amendment would annotate with an asterisk thc"R" periodicity for the Trip Actuating Device Operational Test for Item l.a (Safety Injection-Manual Initiation) in TS Table 4.3-2.A corresponding note would be added to that TS page to specify that thc SSPS Train B input from thc MCB panel C SI switch will bc tested before reactor startup from Refueling Outage No.7, or when the plant is in Mode 5 for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, whichever occurs first.This is a one-time change.Basis This change docs not involve a significant hazards consideration for thc following reasons: The proposed amendment does not involve a significant increase in thc probability or consequences of an accident previously evaluated.

Thc proposed aincndrncnt docs not involve any design or material changes to thc plant.Thc change does not in any way affect the automatic ESFAS initiation; it only affect onc of the two redundant switches.If one switch fails to function, operators can use the other switch.This change simply requests a onc-time extension for the surveillance interval for onc of two contacts from thc manual Safety Injection switch on Main Control Board panel C.A redundant switch is available with two operable contacts on Main Control Board panel A.The proposed amcndmcnt docs not create the possibility of a ncw or diffcrcnt kind of accident from any accident previously evaluated.

The proposed amendment docs not alter the performance of thc Engineered Safety Features Actuation System.The proposed change does not involve any ncw equipment or modifications to existing plant equipment.

Further, thc change will not affect thc manner in which any safety related systems perform their functions.

Extension of thc surveillance frcqucncy of thc manual SI actuation switch docs not affect or crcatc any ncw accident scenarios.

Thcreforc, thc proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page E2-1 ENCLOSURE TO SERIAL: HNP-96-025 The proposed amendment does not involve a significant reduction in the margin of safety.Thc proposed change does not affect a margin of safety as defined in the Bases to the Technical Specifications.

The automatic ESFAS is not affected by this onc-time tcchnical specification change.The change does not alter the sctpoints for any plant parameters that initiate safety injection, nor does it alter any coincidental logic.Sufficient system functional capability is still available from diverse parameters.

Page E2-2 ENCLOSURE TO SERIAL: HNP-96-025 ENCLOSURE3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO.50-400/LICENSE NO.NPF-63 REQUEST FOR LICENSE AMENDMENT ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS)INSTRUMENTATION ENVIRONMENTAL CONSIDERATIONS 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 asscssmcnt 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 thc types or significant increase in the amounts of any cfflucnts that may be rclcascd offsitc;(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 mccts the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no cnvironmcntal impact statement or environmental assessmcnt needs to be prepared in connection with the issuance of the amendment.

Thc basis for this determination follows: Pro osed Chan c The proposed amendment would annotate with an asterisk the"R" periodicity for thc Trip Actuating Device Operational Test for Item l.a (Safety Injection-Manual Initiation) in TS Table 4.3-2.A corresponding note would be added to that TS page to specify that thc SSPS Train B input from thc MCB panel C SI switch will bc tested before reactor startup from Refueling Outage No.7, or when the plant is in Mode 5 for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, whichever occurs first.This is a onc-time change.Basis The change meets the eligibility criteria for categorical exclusion sct forth in 10 CFR 51.22(c)(9) for the following reasons: As demonstrated in Enclosure 2, the proposed amendmcnt docs not involve a significant hazards consideration.

The proposed amendment docs not result in a significant change in the types or significant incrcasc in the amounts of any efflucnts that may be released offsitc.The proposed change does not involve any ncw equipment, or require existing systems to perform a different type of function than they arc currently designed to perform.The change docs not introduce any ncw cffluents or increase thc quantity of existing efflucnts.

As such, thc change can not affect thc types or amounts of any cffluents that may be released offsite.Page E3-I ENCLOSURE TO SERIAL: HNP-96-025 The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.The proposed change will not result in any physical plant changes or new survcillanccs.

Extending the survcillancc interval for a switch contact can have no impact on radiation exposure.Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.Page E3-2