ML20236A521

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Summary of 870917 Meeting W/Util in Bethesda,Md Re Generic Ltr 87-09, Sections 3.0 & 4.0 of STS on Applicability of Limiting Conditions for Operation & Surveillance Requirements. W/O List of Attendees
ML20236A521
Person / Time
Site: Harris, Brunswick, 05000000
Issue date: 10/20/1987
From: Buckley B
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
GL-87-09, GL-87-9, NUDOCS 8710220333
Download: ML20236A521 (4)


Text

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UNITED STATES g NUCLEAR REGULATORY COMMISSION

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5 y :,p WASHINGTON, D. C. 20555

,,,,. OCT 2 01997 DOCKET NOS: 50-325/324 & 50-400 LICENSEE: Carolina Power & Light Company FACILITY: Shearon Harris, Unit 1

SUBJECT:

SUMMARY

OF MEETING HELD ON SEPTEMBER 17, 1987 RELATlHG TO GENERIC J LETTER 87-09 A meeting was held with representatives of the Carolina Power & Light Company (CP&L) in Bethesda, MD. on September 17, 1987 to discuss Generic Letter 87-09,

" Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the applicability of Limiting Conditions for Operation and Surveillance Requirements" I dated June 4,1987, as it relates to the Shearon Harris Unit 1 and the Brunswick ,

Units 1 & 2 nuclear power plants. A list of attendees is attached.

CP&L expressed concern about the potential for misinterpretation of the sentence l underlined below, for ease of reference, and which appears on page B 3/4.0-1 of enclosure 3 to Generic Letter 87-09. l

" Specification 3.0.1

...It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system (s) or component (s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable."

The concern expressed is that it could prohibit CP&L from going voluntarily into a Limiting Condition for Operation (LCO) in certain justifiable instances. An example of such an instance would be if a small leak developed in a pump seal which in itself would not render the pump inoperable but had the potential for rendering the pump inoperable at a future date. CP&L would like the option of voluntarily entering a LC0 by isolating the pump and making the required repairs without being cited'for such action. The NRC staff noted that the underlined section of the Bases for Specification 3.0.1, noted above, would not apply to the example cited by CP&L since it is not a case in which redundant systems would be out of service. The staff noted that in addition to the two basic types of action requirements that are noted in the second paragraph of the Bases for S 3 edification 3.0.1, a third type would define time limits for directly placing tie plant in a shutdown condition. It was noted that the sentence in question, underlined above, that was a concern to CP&L was intended to apply to this type of shutdown action requirement. The staff noted that a similar sentence is included in the Bases for Specification 3.0.3. In both cases the point of clarification is that the last echelon of defense should not be removed from service such that this would invoke a prompt shutdown action requirement, in lieu of other alterna-tives that would not result in redundant systems being out of service simultaneously.

8710220333 DR 871020 ADOCM 05000324 PDR

O CP&L asked for a clarification of when a missed surveillance is reported under the LER RULE. The staff stated that if a missed surveillance is not performed within the allowance for extending the surveillance interval as provided by Specification 4.0.2, it would be reportable. This is consistent with the clarification of the LER Rule that is provided in NUREG-1022, Supplement #1.

CP&L asked if there was any significance between the words " failure to meet" and the words " noncompliance with" which _is currently in Specification 4.0.3 of Generic letter 87-09. The staff stated they both mean the same and that it does not impose any new requirement.

[SI Bart C. Buckley, Senior Project Manager Project Directorate II-1 Division of Reactor Projects I/II cc: See next page DISTRIBUTION:

See attached list PM:PD21 R D pf:'DRPR BBuckley/sh EAdensam

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  • ~ Mr. E. E. Utley Carolina Power & Light Company Shearon-Harris cc:

Thomas A. Baxter, Esq. .

Ms. Carol Love Shaw, Pittman, Potts & Trowbridge. 100 Park Drive 2300 N Street, NW P.O. Box-12276 Washington, DC 20037 Research Triangle Park, NC 27709 Mr. D. E. Hollar. Regional Administrator, Region II Associate General Counsel U.S. Nuclear Regulatory Comission Carolina Power & Light Company 101 Marietta Street

.P.O. Box 1551 Suite 2900 Raleigh, North Carolina 27602 . Atlanta, Georgia 30303 Resident Inspector / Harris NPS Mr. J. L. Willis c/o U.S. Nuclear Regulatory Commission Plant General Manager Route 1, Box 315B Harris Nuclear Plant New Hill.. North Carolina 27562 P.O. Box 165 New Hill North Carolina 27562 l

Mr. R. A. Watson Mr. Dayne H. Brown, Chief i Vice President Radiation Protection Section Harris Nuclear Plant Division of Facility Services P.O. Box 165 N.C. Department of Human Resources '

New Hill, North Carolina 27562 701 Barbour Drive Raleigh, North Carolina 27603-2008 i

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B..-Buckley E. Sylvester T. Dunning'.

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-E. Jordan.

-J.-Partlow

- .NRC Participants ACRS.. (10) -

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