ML18022A808

Application for Amend to License NPF-63,revising Tech Specs to Support Cycle 4 Reload,Specifically,Relocating Certain Numerical Values for Several cycle-specific Core Operating Limits

ML18022A808
Person / Time
Site:	Harris
Issue date:	09/19/1990
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18009A665	List: ML18009A664 ML18022A808
References
NLS-90-187, NUDOCS 9009210258
Download: ML18022A808 (18)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRXBUTION SYSTEM (RIDS)

ACCESSION NBR:9009210258 DOC.DATE: 90/09/19 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit I, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION CUTTER,A.B. Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Application for amend to License NPF-63,revising Tech Specs to support Cycle 4 reload.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL TXTLE: OR Submittal: General Distribution S

NOTES:Application for permit renewal filed. 05000400

/

RECIPIENT COPIES RECXPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 D BECKER,D 2 2 D

INTERNAL: ACRS 6 6 NRR/DET/ECMB 9H 1 1 NRR/DOEA/OTS B1 1 1 1 NRR/DST 8E2 1 1 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 OC LFMB 1 0 OGC/HDS1 1 0 EG - E 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

A D

D NOTE TO ALL "RIDS" RECIPIENTS:

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 21

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Carolina Power & Light Company SERIAL: NLS-90-187 10CFR50.90 SEP 19 1990 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 CYCLE 4 RELOAD SUBMITTAL Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications for the Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP).

This proposed amendment revises numerous Technical Specifications in support of refueling and operations for SHNPP Cycle 4. Specifically, the proposed amendment relocates certain numerical values for several cycle-specific core operating limits and restrictions from the SHNPP Technical Specifications to the existing SHNPP Core Operating Limits Report (COLR). These cycle-specific parameters include: the Moderator Temperature Coefficient, the Heat Flux Hot Channel Factor, the Normalized Axial Peaking Factor, and the Enthalpy Rise Hot Channel Factor. In addition, the proposed amendment also makes several administrative changes which clarify the definition and use of the term F>H, Enthalpy Rise Hot Channel Factor, and provide word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications and relocated to other plant documents.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes. Enclosure 2 is a summary listing of Technical Specification pages being changed.

Enclosure 3 details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 4 is 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 impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

Enclosure 5 provides the proposed marked up Technical Specification pages.

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Document Control Desk NLS-90-187 / Page 2 Enclosure 6 contains a sample version of the revised Core Operating Limits Report using Cycle 3 information.

Carolina Power & Light Company requests approval of the proposed amendment by March 2, 1991 in order to support the upcoming SHNPP refueling outage currently scheduled to begin in March 1991. Ve request that this amendment be effective on the date of issuance with implementation within 60 days of issuance. Please refer any questions regarding this submittal to Mr. John Eads at (919) 546-4165.

Yours very truly, A. B Cutter Vice President Director - Special Nuclear Projects JHE/ecc (814HNP)

Enclosures:

1. Basis for Change Request

2. Summary of Technical Specification Changes

3. 10CFR50.92 Evaluation

4. Environmental Evaluation

5. Technical Specification Pages

6. Sample Core Operating Limits Report

'cc: Mr. R. A. Becker .

Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. J. E. Tedrow A. B Cutter, 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 officers, employees, contractors, and agents of Carolina Power & Light Company.

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ENCLOSURE 1

' SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 4 RELOAD SUBMITTAL BASIS FOR CHANGE RE UEST

~Back round NRC Generic Letter 88-16, dated October 4, 1988, was issued to encourage licensees to prepare changes to Technical Specifications related to cycle-

.specific parameters. These Technical Specification changes will relocate cycle-specific parameter limits from Technical Specifications to the Core Operating Limits Report (COLR). Presently the parameter limits in the Shearon Harris Nuclear Power Plant (SHNPP) Technical Specifications are calculated using NRC-approved methodologies. These limits are evaluated for every reload cycle and may be revised periodically as appropriate to reflect changes to cycle-specific variables. This is an administrative burden on both the NRC and Carolina Power

& Light Company (CP&L). The use of the COLR for SHNPP was previously approved by the NRC in Amendment 15, dated October 18, 1989. The purpose of this amendment request is to allow the relocations of additional cycle-specific parameters to the existing COLR.

The generic letter provided guidance for relocation of certain cycle-dependent core operating limits from the SHNPP Technical Specifications. This would allow changes to the values of core operating limits without prior approval (i.e.,

license amendment) by the NRC, so long as an NRC-approved methodology for the parameter limit calculation is followed. Instead, the future SHNPP core reloads and other revisions would involve a safety review in accordance with the requirements of 10 CFR 50.59.

Currently, for each additional parameter limit proposed for inclusion in the COLR, CP&L utilizes the associated methodologies identified in the revised Administrative Controls Section of this license amendment request for calculation of these parameter limits during SHNPP core reload design and when any other revisions are made.

Pro osed Chan e The Technical Specification changes proposed in this submittal concern the relocation of numerical values for several cycle-specific core operating limits and restrictions from the SHNPP Technical Specifications to the existing COLR.

The impacted individual specifications will be amended to reflect the relocation of the numerical values for cycle-specific limits/restrictions to the COLR. In addition, administrative changes are included which clarify the definition and use of the term F<H and provide word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications and relocated to other plant documents. A summary listing of Technical Specification pages being changed is included as Enclosure 2.

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Changes to individual specifications to remove specific numerical values will reference the COLR as the source of the values and specify that operation of the plant is subject to and must be maintained within the criteria established therein. Relocation of numerical values for the following cycle-specific core operating limits/restrictions is proposed:

Affected Affected S ecifications Limit Restriction 3/4.1.1.3 Moderator Temperature Coefficient basis'/4.2.2 Heat Flux Hot Channel Factor Fo(Z) basi,s 3/4 '.2 Normalized Axial Peaking Factor K(Z) basis 3/4.2.3 Enthalpy Rise Hot Channel Factor F><

basis These changes are consistent with the requirements of 10 CFR 50.36 and with the NRC staff's proposed policy for improving Technical Specifications, delineated in SECY-86-10, "Recommendations for Improving TS." These changes are also considered improvements per NRC stated policy for improving Technical Specifications (52 FR 3788, February 6, 1987).

Safet Evaluation The current Technical Specification method of controlling reactor physics parameters to assure conformance to 10 CFR 50.36 (which requires the lowest functional performance levels acceptable for continued safe operation) is to specify the values determined to be within the acceptance criteria using an NRC-approved calculation methodology. As previously discussed, the methodologies for calculating these parameter limits have been reviewed and approved by the NRC and are consistent with the applicable limits in the Final Safety Analysis Report (FSAR).

The removal of cycle dependent variables from the Technical Specifications has no impact upon function, or plant operations will be altered as a result change. Since the applicable FSAR limits will be maintained

'f plant operation or safety. No safety-related equipment, safety this proposed and the Technical Specifications will continue to require operation within the core operational limits calculated by these NRC-approved methodologies, this proposed change is administrative in nature. Appropriate actions to be taken if limits are violated will also remain in the Technical Specifications. This proposed change will control the cycle-specific parameters within the acceptance criteria and assure conformance to 10 CFR 50.36 by using the approved methodology instead of specifying Technical Specification values. The COLR will document the specific parameter limits resulting from CP&L's calculations, including mid-cycle or other revisions to parameter values. Therefore, the proposed change is in conformance with the requirements of 10 CFR 50.36.

Any changes to the COLR will be made in accordance with the provisions of 10 CFR 50.59. From cycle to cycle, the COLR will be revised such that the appropriate core operating limits for the applicable cycle will apply.

Technical Specifications will not be changed.

ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 4 RELOAD SUBMITTAL

SUMMARY

OF TECHNICAL SPECIFICATION TS CHANGES

~Pa e ~Chan e Figure 3.2-2 is deleted in the index.

1-2 Reference to Table 3.6-1 is not applicable since this table was relocated to PLP-106; reference to the TS alone is sufficient since it refers to PLP-106.

B2-la The F>< limits at RATED THERMAL POWER of 1.62 and 1.65 and the Power Factor Multiplier for F>H are being relocated to COLR.

3/4 1-4, 1-5 MTC is relocated to the COLR, although the limiting positive MTC is retained as a bound on the COLR. The surveillance limits of 4.1.1.3.b are also relocated to the COLR.

3/4 1-14 Reference to the COLR in the action of 3.1.3.1 is revised to direct the reader to the applicable TS 3.1.3.6 which provides the limits and refers to the COLR.

3/4 1-20, 1-21 Administrative changes to capitalize COLR as a defined term, and to identify the COLR in the action and surveillances, consistent with other TS.

3/4 1-22 Add title of deleted figure and refer the reader to its new location in the COLR, PLP-106.

3/4 2-1 Administrative changes to capitalize COLR as a defined term, and make references to the COLR in the actions consistent. An additional change in action b deletes "applicable target", to make the words consistent with the LCO, "band about the target AFD".

3/4 2-4 Add title of deleted figure and refer the reader to its new location in the COLR, PLP-106.

3/4 2-5 2.45 limit and K(z) relocated to COLR.

3/4 2-6, 2-7a, Terms in surveillances being relocated to COLR.

2-7b, 2-7c, 2-7d Administrative changes to clarify terms and references to the COLR also included.

3/4 2-8 Figure relocated to COLR.

3/4 2-9 1.62 limit and 1.65 limit being relocated to COLR.

Administrative changes to definition of F>H. Additional administrative change to references to RCS total flowrate made to ensure this term is referred to in a consistent manner in this TS.

3/4 2-10 In action b, the term RCS total flow rate "comparison" is changed to "determination"; the term comparison is a holdover from when the TS allowed trading margin of F>H and RCS flow, so a comparison of the two values to determine if limits were met was required. Since the two parameters are now controlled independently, the RCS flowrate needs to be determined in limits, not compared to F>H. In SR 4.2.3.3, the term "indicated" is deleted for consistency with the LCO and with part b of the SR, which is not monitoring "indicated" flow.

3/4 3-1, 3-9, 3-17 Administrative wording changes to clarify reference to 3-37, 4-34, 4-37, the Technical Specification Equipment List Program, 6-14, 6-15, 6-16, plant procedure PLP-106.

7-19, 7-20, 7-24, 8-19, 8-21, 8-39, and 8-40 B 3/4 1-2 Bases changes to support MTC relocation.

B 3/4 2-1 Bases changes to support F< and K(z) relocation, and administrative change adding definition of F>H.

B 3/4 2-2, 2-2a Administrative changes to clarify references to the 2-4, and 2-5 COLR.

6-24 References to TS and reports now incorporated into the COLR.

ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 4 RELOAD SUBMITTAL 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 of the facility facility involves no significant hazards consideration if operation 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 consideration. The bases for this determination are as follows:

Pro osed Chan e The Technical Specification changes proposed in this submittal concern the relocation of numerical values for several cycle-specific core operating limits and restrictions from the Shearon Harris Nuclear Power Plant (SHNPP) Technical Specifications to the existing Core Operating Limits Report (COLR). The impacted individual specifications will be amended to reflect the relocation of the numerical values for cycle-specific limits-restrictions to the COLR. In addition, administrative changes are included which clarify the definition and use of the term F>< and provide word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications and relocated to other plant documents.

Changes to individual specifications to remove specific numerical values will reference the COLR as the source of the values and specify that operation of the plant is subj ect to and must be maintained within the cri.teria established therein. Relocation of numerical values for the following cycle-specific core operating limits/restrictions is proposed:

Affected Affected S ecifications Limit Restriction 3/4.1.1 ~ 3 Moderator Temperature Coefficient basis 3/4.2.2 Heat Flux Hot Channel Factor F<(Z) basis 3/4.2.2 Normalized Axial Peaking Factor K(Z) basis 3/4.2.3 Enthalpy Rise Hot Channel Factor F><

basis

These changes are consistent with the requirements of 10 CFR 50.36 and with the NRC staff's proposed policy for improving Technical Specifications, delineated in SECY-86-10, "Recommendations for Improving TS." These changes are also con-sidered improvements per NRC stated policy for improving Technical Specifications (52 FR 3788, February 6, 1987).

Basis The change does not involve a significant hazards consideration for the following reasons:

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The removal of additional cycle-specific core operating limits from the SHNPP Technical Specifications has no influence or impact on the probability or consequences of any accident previously evaluated. The cycle-specific core operating limits, although not in Technical Speci-fications, will be followed in the operation of SHNPP. The proposed amendment still requires exactly the same actions to be taken when or limits are exceeded as is required by current Technical Specifications.

if Each accident analysis addressed in the SHNPP Final Safety Analysis Report (FSAR) will be examined with respect to, changes in cycle-dependent parameters, which are obtained from application of the NRC-approved reload design methodologies, to ensure that the transient evaluation of new reloads are bounded by previously accepted analyses. This examination, which will be performed per requirements of 10 CFR 50.59, ensures that future reloads will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The administrative changes clarifying the definition and use of the term F>< and providing word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications to other plant documents are strictly administrative in nature and as such, do not significantly increase the probability or consequences of an accident previously evaluated.

Thus it is concluded that there is not a significant increase in the probability or consequences of an accident previously evaluated.

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

As stated earlier, the removal of the additional cycle specific variables has no influence or impact, nor does it contribute in any way to the probability or consequences of an accident. No safety-related equipment, safety function, or plant operations will be altered as a result of this proposed change. The cycle specific variable are calculated using the NRC-approved methods and submitted to the NRC to allow the Staff to continue to trend the values of these limits. The Technical Specifications will continue to require operation within the required core operating limits and appropriate actions will be taken when or are exceeded.

if limits

The administrative changes clarifying the definition and use of the term F>< and providing word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications to other plant documents are strictly administrative in nature and as such, do not create the possibility of a new or different type of accident from any accident previously evaluated.

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

3) The proposed amendment does not result in a significant reduction in the margin of safety.

The margin of safety is not affected by the removal of additional cycle-specific core operating limits from the Technical Specifications. The margin of safety presently provided by current Technical Specifications remains unchanged. Appropriate measures exist to control the values of these cycle-specific limits. The proposed amendment continues to require operation within the core limits as obtained from the NRC-approved reload design methodologies and appropriate actions to be taken when or are violated remain unchanged.

if limits The development of the limits for future reloads will continue to conform to those methods described in NRC-approved documentation. In addition, each future reload will involve a 10 CFR 50.59 safety review to assure that operation of the unit within the cycle specific limits will not involve a significant reduction in a margin of safety.

The administrative changes clarifying the definition and use of the term F>< and providing word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications to other plant documents are strictly administrative in nature and as such, do not result in a significant reduction in the margin of safety.

Therefore, the proposed changes are administrative in nature and do not impact the operation of SHNPP in manner that involves a reduction in the margin of safety.

ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT CYCLE 4 RELOAD SUBMITTAL ENVIRONMENTAL CONSIDERATION 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 accordance with the proposed amendment would not:

if operation of the facility in (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; and (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power 6 Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for cate-gorical 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 The Technical Specification changes proposed in this submittal concern the relocation of numerical values for several cycle-specific core operating limits and restrictions from the Shearon Harris Nuclear Power Plant (SHNPP) Technical Specifications to the existing Core Operating Limits Report (COLR). The impacted individual specifications will be amended to reflect the relocation of the numerical values for cycle-specific limits-restrictions to the COLR. In addition, administrative changes are included which clarify the definition and use of the term F>< and provide word enhancements to better enable plant personnel to identify the location of information which has been removed from the Technical Specifications and relocated to other plant documents:

Changes to individual specifications to remove specific numerical values will reference the COLR as the source of the values and specify that operation of the plant is subject to and must be maintained within the criteria established therein. Relocation of numerical values for the following cycle-specific core operating limits/restrictions is proposed:

Affected Affected S ecifications Limit Restrict o 3/4.1.1.3 Moderator Temperature Coefficient basis 3/4.2.2 Heat Flux Hot Channel Factor Fo(Z) basis 3/4.2.2 Normalized Axial Peaking Factor K(Z) basis 3/4.2.3 Enthalpy Rise Hot Channel Factor F><

basis

These changes are consistent with the requirements of 10 CFR 50.36 and with the NRC staff's proposed policy for improving Technical Specifications, delineated in SECY-86-10, "Recommendations for Improving TS." These changes are also con-sidered improvements per NRC stated policy for improving Technical Specifications (52 FR 3788, February 6, 1987).

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

As demonstrated in Enclosure 3, 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 of any effluents that may be released offsite.

The proposed change relocates numerical values for several cycle-specific core operating limits and restrictions from the Technical Specifications to the existing Core Operating Limits Report (COLR) and makes adminis-trative changes clarifying the definition and use of the term F>H and clarifies references to information relocated from the Technical Specifi-cations. The proposed amendment does not introduce any new equipment nor does it require any existing equipment or systems to perform a different type of function than they are currently designed to perform. 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 an increase in individual or cumulative occupational radiation exposure. The proposed change relocates numerical values for several cycle-specific core operating limits and restrictions from the Technical Specifications to the existing COLR and makes administrative changes clarifying the definition and use of the term F>H and clarifies references to information relocated from the Technical Specifications. No additional surveillances or testing results from the amendment. Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.