ML18017A851

Application for Amend to License NPF-63,revising TS 3/4.9.4 & Associated Bases to Allow Penetrations Which Provide Direct Access from Containment Atmosphere to Outside Atmosphere to Remain Open During Refueling Operations

ML18017A851
Person / Time
Site:	Harris
Issue date:	08/26/1999
From:	Scarola J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18017A852	List: ML18017A851 ML18017A853
References
HNP-99-111, NUDOCS 9908310234
Download: ML18017A851 (12)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

A'CCESSION NBR:9908310234 DOC.DATE: 99/08/26 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTJ$ . NA$2E AUTHOR AFFILIATION SCAROLA,J. Carolina Power 8c Light Co.

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

SUBJECT:

Application for amend to license NPF-63,revising TS 3/4.9.4

& associated Bases to allow penetrations which provide direct access from containment atmosphere to outside atmosphere to remain open during refueling operations.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution I ENCL J SIZE:

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

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SC 1 1 INTERNAL: ACRS 1 1 FILE CENTER Ol 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 NUDOCS-ABSTRACT 1 1 OGC/RP 1 0 EXTERNAL: NOAC 1 1 NRC PDR D

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NOTE TO ALL "RZDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM D IS TRIBUTION LISTS OR REDUC E THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUM CUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 10

Carolina Power & Light Company James Scarola PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant SERIAL: HNP-99-111 10CFR50.90 AUG 2 6 1999 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 TECHMCAL SPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power &

Light Company (CP&L) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment revises TS 3/4.9.4, "Containment Building Penetrations" and associated Bases. Specifically, Harris Nuclear Plant (HNP) proposes to revise TS 3/4.9.4 to allow penetrations which provide direct access from the containment atmosphere to the outside atmosphere to remain open during refueling operations provided certain administrative controls are met. provides a description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the CP&L'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.

In accordance with 10 CFR 50.91(b), CP&L is providing the State of North Carolina with a copy of the proposed license amendment.

CP&L 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.

HNP requests approval of this submittal by February 1, 2000 to allow implementation prior to HNP Refueling Outage 9.

yQt,. t 99'083 i 0234 'st'st0826 PDR p

ADGCK 05000400 PDR +D 5413 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095

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't Please refer any questions regarding this submittal to Mr. J. H. Eads at (919) 362-2646.

Sincerely, dtn,ngA James Scarola 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 James Scarola, 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 ignlmatte@,are employees, contractors, and agents of Carolina Power dt Light Company.

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Notary peal)

My commission expires:

Mr. J. B. Brady, NRC Sr. Resident Inspector Mr. Mel Fry, Acting Director, N.C. DEHNR Mr. R. J. Laufer, NRC Project Manager Mr. L. A. Reyes, NRC Regional Administrator

ENCLOSURE 1 TO SERIAL: HNP-99-111 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS BASIS FOR CHANGE RE VEST

~Back round The Harris Nuclear Plant (HNP) Technical Specifications (TS) currently require that each containment building penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either closed by a manual or automatic isolation valve, blind flange or equivalent, or be capable of being closed by operable automatic normal containment purge and containment pre-entry purge makeup and exhaust valves (TS 3.9.4.c).

Containment barriers are provided for nuclear power plants as the final barrier of the defense-in-depth concept to protect against the uncontrolled release of radioactivity to the environs. The containment function, in combination with other fission product barriers and accident mitigation systems, limits the radiological dose consequences of design-basis transients and accidents to less than the regulatory limits defined by 10 CFR 100. The acceptance criteria of Standard Review Plan (SRP) Section 15.7.4, paragraph II.5, allow a containment to be open to the environment during fuel handling for ventilation to minimize worker radiation exposure and for if worker habitability. However, fuel handling operations are conducted with containment open, capability for prompt detection and automatic isolation is to be provided.

The NRC has issued license amendments at other nuclear power plants that allow penetrations to be open during fuel movement and core alterations. The NRC has determined this practice to be acceptable contingent upon the licensee demonstrating, through analysis, that the licensing basis is not changed (Letter to D. C. Cook, dated July 12, 1995). HNP has revised the Fuel Handling Accident Analysis to demonstrate that a containment penetration may remain open for 20 minutes following a Fuel Handling Accident without exceeding the Standard Review Plan dose limits at the Exclusion Area Boundary and the Low Population Zone boundary. The NRC has issued license amendments at the following plants allowing penetrations to be breached during fuel movement and core alterations:

1. D. C. Cook (July 12, 1995)

2. WolfCreek (July 11, 1997)

3. Arkansas Nuclear One Units 1 and 2 (April 16, 1999)

The current practice of operating the Personnel Air Lock (PAL) doors during core alterations could contribute to premature door system failures. Changes to closure requirements could reduce PAL door cycling and increase PAL door reliability. Additionally, should a fuel handling accident occur during fuel movement or core alterations, personnel could be evacuated from containment more quickly ifthe PAL door was open thus minimizing occupational exposure.

Pro osed Chan e Harris Nuclear Plant (HNP) proposes to modify TS 3/4.9.4 and associated Bases to allow administrative controls to provide for containment closure in lieu of isolated penetrations or automatic isolation capability.

Basis HNP proposes to modify TS 3/4.9.4 to allow administrative controls (manual actions) to provide for containment closure in lieu of isolated penetrations or automatic isolation capability. HNP has reevaluated the Fuel Handling Accident Analysis - inside containment (FHAA-IC) to assume containment is not isolated until twenty minutes aAer occurrence of a Fuel Handling Accident inside containment. For the purpose of evaluating administrative controls to meet containment closure requirements, HNP considered the following:

~ Acceptability of manual personnel actions to initiate'containment closure, and

~ Acceptability, from the standpoint of incremental dose increase, of the additional time delay in closing the containment.

Acce tabilit of manual ersonnel actions to initiate containment closure Current plant procedure OMP-003, "Outage Risk Assessment", provides administrative requirements for containment penetrations that are breached in Mode 5 and Mode 6 (when core alterations or fuel movement is not in progress). These administrative controls were written in response to NRC Generic Letter 88-17, dated January 3, 1989 and include the following:

~ Containment penetrations that are breached in Mode 5 or Mode 6 shall be tracked by the Operations unit.

~ Material should be available to allow closure of any breached penetration.

~ A breached penetration shall be capable of being closed within four hours or prior to core boiling (whichever is more restrictive) should a loss of decay heat removal occur.

~ If closure is to be obtained &om inside containment, consideration should be given to possible containment conditions.

~ Personnel responsible for containment closure should be trained and understand their roles in obtaining closure.

~ Methods for evacuating containment and alerting personnel of adverse conditions within containment should be established.

HNP proposes the following administrative controls for penetrations that are breached during fuel movement in containment or core alterations (these administrative controls are in addition to the existing administrative controls required by HNP procedures). HNP proposes to place these administrative controls in TS 3/4.9.4 Bases and plant procedure OMP-003. Future changes to these administrative controls would be in accordance with 10 CFR 50.59. Additionally, plant procedure, Abnormal Operating Procedure 13 "Fuel Handling Accident" (AOP-13), will be revised to direct closure of breached penetrations should a fuel handling accident in containment occur. HNP TS currently requires 23 feet of water above the Reactor Vessel flange, therefore an additional administrative control for water level during fuel movement is not necessary.

The proposed change to allow a penetration to be open under administrative controls does not include the purge and exhaust penetrations.

Proposed Administrative Controls

~ The breached penetration shall be capable of being closed within twenty minutes aAer a fuel handling accident in containment.

~ An individual or individuals shall be designated and available at all times, capable of closing the breached penetration, and able to communicate directly with the Control Room.

~ The breached penetrations shall not be obstructed unless capability for rapid removal of obstructions is provided (such as quick disconnects for hoses).

~ For AirLocks, at least one door must be capable of being closed and secured.

As currently specified in HNP plant procedure OMP-003, the person responsible for containment closure should be trained and understand their roles in obtaining closure. Expected breached penetrations during fuel movement in containment or core alterations would include the PAL and test, vent, and drain valves in use for performance of local leak rate testing. Penetrations other than the PAL or that could be isolated using an installed valve could require temporary closure devices, such as covers or blind flanges. All penetrations would require an evaluation to demonstrate closure capability within 20 minutes and adequacy of the closure device.

A PAL door takes approximately ten minutes to close manually which is well below the 20 minutes assumed in the analysis. The time to close a PAL door was determined using previous operating experience by qualified door operators. A valve would normally be used to close other anticipated breached penetrations which would be expected to take less time than closing a PAL dooi'.

Acce tabilit from thestand ointofincrementaldoseincrease oftheadditionaltimedela in closin the containment HNP revised the Fuel Handling Accident Analysis (FHAA) assuming the containment was breached for 20 minutes. Other assumptions used in the FHAA include:

~ A fuel handling accident in the Reactor Containment Building (RCB) involves damage to a single fuel assembly with the subsequent release of 100% of the gap activity in the assembly.

~ A water depth of 22 feet over the dropped assembly was used to calculate how much activity was released from the assembly to the RCB.

~ Containment Ventilation Isolation will occur within 20 seconds which is less than the time it takes for the activity to reach the Inner Containment Ventilation Isolation Valves. Therefore, no release occurs through the Containment Ventilation pathway.

~ Manual action (in addition to the automatic isolation of Containment Ventilation) for any breached penetration will occur within 20 minutes aAer a Fuel Handling Accident.

~ Driving force for established flow rates out of the RCB during the Fuel Handling Accident aAer isolation of Containment Ventilation is 0.45 inwc.

~ This analysis used assumptions in Regulatory Guide 1.25 for basic assumptions as gap activity, breathing rate, release duration, and other applicable factors for performing the analysis.

~ Other penetrations which provide direct access from the RCB to atmospheres other than the Reactor Auxiliary Building shall be limited to 706 square inches. Plant procedure OMP-003 willbe revised to control this assumption.

~ X/g at the BAB is assumed to be 6.17B-04s/m'. X/Q at the LPZ is assumed to be 1.40B-04 s/m .

The following table summarizes the impact of the revised Fuel Handling Accident Analysis for dose at'the Exclusion Area Boundary gAB) and Low Population Zone (LPZ) boundary.

Location Current EAB Current LPZ Revised EAB Revised LPZ Standard Dose (rem) Dose (rem) Dose (rem) Dose (rem) Review Plan limit Total Whole 0.680 0.150 0.681 0.155 Bod Total Th oid 29 51.7 11.7 75 The revised FHAA demonstrates that EAB and LPZ dose remain well below the Standard Review Plan limits while assuming the RCB remains breached for 20 minutes following a Fuel Handling Accident in the RCB. Additionally, doses to the Control Room staff remained bounded by the Loss of Coolant Accident (LOCA).

As part of this change, HNP is clarifying the term equivalent isolation methods in the TS 3/4.9.4 Bases section. This clarification is taken from the NUREG-1431, Revision 1 dated April 1995 (B3.9.4).

Conclusion HNP proposes to change TS 3/4.9.4 to allow Containment penetrations to be open during fuel movement and core alterations. HNP proposes administrative controls to ensure containment closure is accomplished within 20 minutes following a Fuel Handling Accident in the RCB. HNP has revised the FHAA to demonstrate dose consequences remain well below the dose requirements in the Standard Review Plan for a Fuel Handling Accident (assuming containment closure within 20 minutes following a Fuel Handling Accident in the RCB).

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ENCLOSURE 2 TO SERIAL: HNP-99-111 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS 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 8c 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 modify TS 3/4.9.4 and associated Bases to allow administrative controls to provide for containment closure in lieu of isolated penetrations or automatic isolation capability.

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.

Containment is not an accident initiating system as described in the Final Safety Analysis Report. This change is applicable only in Mode 6 during Core Alterations or movement of irradiated fuel (which occurs when the unit is shutdown). The proposed change will not modify equipment used for fuel movement or core alterations within the HNP Containment Building. Administrative controls will be used to isolate containment in the event of a fuel handling accident. The consequences of a Fuel Handling Accident inside containment will increase as a result of this change. However, the proposed administrative controls will require closure of containment prior to exceeding standard review plan dose limits due to a radiological release &om a design basis fuel handling accident.

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 change provides for administrative controls and operating restrictions for air lock doors consistent with previous guidance authorized by the Commission for

similar nuclear power plants. Containment is not an accident initiating system as

'described in the Final Safety Analysis Report. Fuel Handling Accidents have been previously analyzed for the Harris Nuclear Plant.

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

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

Administrative controls willbe used to isolate containment in the event of a fuel handling accident. The proposed administrative controls will require closure of containment prior to exceeding standard review plan dose limits due to a radiological release &om a design basis fuel handling accident.

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

E2-2

ENCLOSURE 3 TO SERIAL: HNP-99-111 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS 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 2 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 modify TS 3/4.9.4 and associated Bases to allow administrative controls to provide for containment closure in lieu of isolated penetrations or automatic isolation capability.

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.

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.

There are no new types of releases as a result of this change. Radiological effluent will increase as a result of this change. However, effluent dose will remain below limits specified by the Standard Review Plan. Therefore, 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.

The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

Allowing penetrations to be breached, such as the Personnel Air lock, could significantly reduce personnel exposure in the event of a fuel handling accident by expediting evacuation of the Containment Building. HNP will evaluate the radiological exposure prior to stationing personnel at a breached penetration for the purpose of administrative controls. Therefore, the proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

ENCLOSURE 4 TO SERIAL: HNP-99-111 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS PAGE CHANGE INSTRUCTIONS Removed Pa e 3/4 9-5 3/4 9-5 B 3/4 9-1 B 3/4 9-1 E4-1

ENCLOSURE 5 TO SERIAL: HNP-99-111 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATION 3/4.9.4 CONTAINMENTBUILDINGPENETRATIONS TECHNICAL SPECIFICATION PAGES E5-1