ML18005A793

Application for Amend to License NPF-63,changing Tech Spec 3.9.8.2, Refueling Operations-Low Water Level, to Delete RHR Flow Requirements Whenever Water Level Below Reactor Vessel Flange,Per Generic Ltr 88-17

ML18005A793
Person / Time
Site:	Harris
Issue date:	02/22/1989
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18005A795	List: ML18005A793 ML18005A797
References
GL-88-17, NLS-89-018, NLS-89-18, NUDOCS 8902280489
Download: ML18005A793 (11)

Text

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ACCESSION NBR:8902280489 DOC.DATE: 89/02/22 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION MCDUFFIE,M.A. Carolina Power 6 Light Co.

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

SUBJECT:

Application for amend to License NPF-63,changing Tech Spec 3.9.8.2, "Refueling Operations-Low Water Level."

DISTRIBUTION CODE A061D COPIES RECEIVED LTR TITLE:,OR/Licensing Submittal: Loss of Residual Heat ENCL R

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Carolina Power 8 Ught Company P. O. Box1551 ~ Ratetgh, N.C.27502 FEB 2 2 1989 M. A. McDUFFIE Senior Vice President SERIAL: NLS-89-018 Nuclear Generation 10CFR50.90 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 REFUELING OPERATIONS - LOW WATER LEVEL 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.

The proposed change affects Specification 3.9.8.2, Refueling Operations - Low Water Levels Currently, Surveillance Requirement 4.9.8.2 requires that at least one Residual Heat Removal (RHR) loop be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2500 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is in Mode 6 with irradiated fuel in the vessel and" the water level above the'op of the reactor vessel flange is less than 23 feet.

The proposed amendment revises Surveillance Requirement 4.9.8.2 to delete the RHR flow requirement whenever the water level is'elow the reactor vessel flange. The 2500 gpm flow requirement is maintained when the water level is at or above the reactor vessel flange. A change to the associated Bases section is also included for your information.

The proposed amendment is consistent with Generic, Letter 88-17, "Loss of Decay Heat Removal," dated October 17, 1988, which advises licensees to submit changes to those technical specifications that re'strict or limit the safety benefit of the action identified by the generic letter.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 is an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical 89022cl0pSy S~0 PDR ADOCK 05000400 PDC

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Document Control Des NLS-89-018 / Page 2 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 need to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides the proposed Technical Specification pages.

Carolina Power & Light Company requests approval of the proposed amendment by October 11, 1989 in order to support planning for the upcoming SHNPP refueling outage currently scheduled to begin in November 1989. Please refer any questions regarding this submittal to Mr. Mark A. Turkal at (919) 362-2985.

Yours very truly, Qd M. A.

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McDuffie MAM/MAT

Enclosures:

1. Basis for Change Request

2. 10CFR50.92 Evaluation

3. Environmental Evaluation

4. Technical Specification Pages cc: Mr. R. A. Becker Mr. W. H. Bradford Mr. Dayne H. Brown Mr. M. L. Ernst M. A. McDuffie, 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 REFUELING OPERATIONS - LOW WATER LEVEL BASIS FOR CHANGE RE UEST Pro osed Chan e The proposed change affects Specification 3.9.8.2, Refueling Operations - Low Water Level. Currently, Surveillance Requirement 4.9.8.2 requires that at least one Residual Heat Removal (RHR) loop be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2500 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is in Mode 6 with irradiated fuel in the vessel and the water level above the top of the reactor vessel flange is less than 23 feet.

The proposed amendment revises Surveillance Requirement 4.9.8.2 to delete the RHR flow requirement whenever the water level is below the reactor vessel flange. The 2500 gpm flow requirement is maintained when the water level is at or above the reactor vessel flange. The associated Bases section has also been revised to reflect this change.

Basis The existing requirement of Specification 3/4.9.8.2 that at least one RHR loop be in operation ensures that: (1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor vessel below 140 F as required in Mode 6, and (2) sufficient coolant circulation is maintained through the core to minimize the effect of a boron dilution incident and prevent boron stratification. The Mode 6 minimum flow limit of 2500 gpm was established to, alleviate the potential for boron stratification. However, achieving 2500 gpm flow rate at the reduced water levels of mid-loop operation could cause cavitation and eventual damage of the RHR pumps. Boron stratification is only a concern with the large volumes of water present when the refueling cavity is filled. Sufficient mixing exists, even at low RHR flow rates, to preclude boron stratification when the water level is below the reactor vessel flange. Since boron stratification is not a concern at reduced RCS water inventories, the proposed revision eliminates the minimum flow limit when the RCS water level is below the reactor vessel flange. Administrative controls to isolate potential sources of non-borated water from the reactor, established in Technical Specification 3/4.9.1, prevent a boron dilution event while in Mode 6.

The proposed amendment splits the existing surveillance requirement into two separate surveillances ~ The first, Surveillance Requirement 4.9.8.2.1, is applicable when the RCS water level is at or above the reactor vessel flange and maintains the 2500 gpm minimum flow limit.

The second, Surveillance Requirement 4.9.8.2.2, is applicable when the

RCS water level is below the reactor vessel flange and requires that one RHR loop be verified in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This new surveillance requirement is identical to the existing Mode 5 Surveillance Requirement 4.4.1.4.2, the only difference being the plant mode. That is, prior to de-tensioning the reactor vessel head closure bolts with water temperature less than 140 F the plant is in Mode 5. Upon de-tensioning of the bolts, the plant is in Mode 6. There is no change in reactor vessel water level, however, at this point the existing Surveillance Requirement 4.9.8.2 establishes a minimum flow rate of 2500 gpm. This minimum flow requirement is not necessary when the water level is below the reactor vessel flange as demonstrated in the Bases for Specification 3/4.4 ', Reactor Coolant Loops and Coolant Circulation, which states that, in Mode 5, ". . . the operation of one reactor coolant pump or one RHR pump provides adequate flow to ensure mixing and prevent stratification." No Mode 5 minimum flow rate is established in Specification 3/4.4.1. Therefore, as long as the RCS water level is below the reactor vessel flange a minimum flow requirement is not necessary either in Mode 5 or Mode 6. Upon raising the water level above the reactor vessel flange, the proposed Surveillance Requirement 4.9.8.2.1 will be in effect and require a minimum flow rate of 2500 gpm.

The proposed amendment is consistent with Generic Letter 88-17, "Loss of Decay Heat Removal," dated October 17, 1988, which advises licensees to submit changes to those technical specifications that restrict or limit the safety benefit of the action identified by the generic letter.

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ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS - LOW WATER LEVEL 10CFR50 92 EVALUATION The Commission has provided standards in 10CFR50.92(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 consideration. The bases for this determination are as follows:

Pro osed Chan e The proposed change affects Specification 3.9.8.2, Refueling Operations - Low Water Level. Currently, Surveillance Requirement 4.9.8.2 requires that at least one Residual Heat Removal (RHR) loop be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2500 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is in Mode 6 with irradiated fuel in the vessel and the water level above the top of the reactor vessel flange is less than 23 feet.

The proposed amendment revises Surveillance Requirement 4.9.8.2 to delete the RHR flow requirement whenever the water level is below the reactor vessel flange. The 2500 gpm flow requirement is maintained when the water level is at or above the reactor vessel flange. The associated Bases section has also been revised to reflect this change.

Basis The 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. The existing requirement of Specification 3/4.9.8.2 that at least one RHR loop be in operation ensures that: (1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor vessel below 140 F as required in Mode 6, and (2) sufficient coolant circulation is maintained through the core to minimize the effect of a boron dilution incident and prevent boron stratification. The Mode 6 minimum

flow limit of 2500 gpm was established to alleviate the potential for boron stratification under refueling conditions. However, achieving 2500 gpm flow rate at the reduced water levels of mid-loop operation could cause cavitation and eventual damage of the RHR pumps. Boron stratification is only a concern with the large volumes of water present when the refueling cavity is filled.

Sufficient mixing exists, even at low RHR flow rates, to preclude boron stratification when the water level is below the reactor vessel flange. Administrative controls to isolate potential sources of non-borated water from the reactor, established in Technical Specification 3/4.9.1, prevent a boron dilution event while in Mode 6. Since boron stratification is not a concern at reduced RCS water inventories and the possibility for a boron dilution event is precluded by Technical Specification 3/4.9.1, the proposed revision to eliminate the minimum flow limit when the RCS water level is below the reactor vessel flange does not significantly 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 amendment splits the existing surveillance requirement into two separate surveillances. The first, Surveillance Requirement 4.9.8.2.1, is applicable when the RCS water level is at or above the reactor vessel flange and maintains the 2500 gpm minimum flow limit. The second, Surveillance Requirement 4.9.8.2.2, is applicable when the RCS water level is below the reactor vessel flange and requires that one RHR loop be verified in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This new surveillance requirement is identical to the existing Mode 5 Surveillance Requirement 4.4.1.4.2, the only difference being the plant mode. That is, prior to de-tensioning the reactor vessel head closure bolts with water temperature less than 140 F the plant is in Mode 5. Upon de-tensioning of the bolts, the plant is in Mode 6. There is no change in reactor vessel water level, however, at this point the existing Surveillance Requirement 4.9.8.2 establishes a minimum flow rate of 2500 gpm. This minimum flow requirement is not necessary when the water level is below the reactor vessel flange as demonstrated in the Bases for Specification 3/4.4.1, Reactor Coolant Loops and Coolant Circulation, which states that, in Mode 5, ". . . the operation of one reactor coolant pump or one RHR pump provides adequate flow to ensure mixing and prevent stratification." No Mode 5 minimum flow rate is established in Specification 3/4.4.1. Therefore,'as long as the RCS water level is below the reactor vessel flange a minimum flow requirement is not necessary either in Mode 5 or Mode 6. Upon raising the water level above the reactor vessel flange, the proposed Surveillance Requirement 4.9.8.2.1 will be in effect and require a minimum flow rate of 2500 gpm. As such, the proposed amendment will not result in the plant being placed in a condition not currently allowed E2-2

during Mode 5 operation and, therefore, does not create the possibility of a new or different kind of accident.

Eliminating the minimum RHR flow limit of 2500 gpm when the RCS water level is below the reactor vessel flange does not involve a significant reduction in the margin of safety. As stated above, the Mode 6 minimum flow limit of 2500 gpm was established to alleviate the potential for boron stratification under refueling conditions. Boron stratification is only a concern with the large volumes of water present when the refueling cavity is filled.

Sufficient mixing exists, even at low RHR flow rates, to preclude boron stratification when the water level is below the reactor vessel flange. In addition, the proposed amendment does not result in the plant being placed in a condition not currently allowed by the existing Mode 5 Surveillance Requirement 4.4.1.4.2.

Therefore, the proposed amendment does not result in a significant reduction in the margin of safety.

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ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS - LOW WATER LEVEL ENVIRONMENTAL CONSIDERATION 10CFR51.22(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 operation of the facility in accordance with the proposed amendment if 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; 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 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 need to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e The proposed change affects Specification 3.9.8.2, Refueling Operations - Low Water Level. Currently, Surveillance Requirement 4.9.8.2 requires that at least one Residual Heat Removal (RHR) loop be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2500 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is in Mode 6 with irradiated fuel in the vessel and the water level above the top of the reactor vessel flange is less than 23 feet.

The proposed amendment revises Surveillance Requirement 4.9.8.2 to delete the RHR flow requirement whenever the water level is below the reactor vessel flange. The 2500 gpm flow requirement is maintained when the water level is at or above the reactor vessel flange. The associated Bases section has also been revised to reflect this change.

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 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 of any effluents that may be released offsite. The proposed amendment does not

result in the plant being placed in a condition not currently allowed by the existing Mode 5 Surveillance Requirement 4.4.1.4.2.

The Mode 6 minimum flow limit of 2500 gpm was established to alleviate the potential for boron stratification under refueling ~

conditions. Boron stratification is only a concern with the large volumes of water present when the refueling cavity is filled.

Sufficient mixing exists, even at low RHR flow rates, to preclude boron stratification when the water level is below the reactor .

vessel flange. Administrative controls to isolate potential sources of non-borated water from the reactor, established in Technical Specification 3/4.9.1, prevent a boron dilution event while in Mode 6. 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 an increase in individual or cumulative occupational radiation exposure. The method by which the required surveillance performed will not be affected, only the acceptance criteria. Therefore, there will be no change in radiation exposure as a result of the proposed amendment.

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