ML18011A875

Application for Amend to License NPF-63,revising Portions of Section 3/4.9, Refueling Operations to Be Consistent W/ NUREG-1431 & Relocating Applicable Sections Per Commission Final Policy Statement

ML18011A875
Person / Time
Site:	Harris
Issue date:	04/05/1995
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18011A877	List: ML18011A875 ML18011A878
References
RTR-NUREG-1431 HNP-95-024, HNP-95-24, HO-950078, NUDOCS 9504110048
Download: ML18011A875 (12)

Text

P R.IC) RIDS PROCESSING)

H.IWY'CELERATED REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9504110048 DOC.DATE: 95/04/05 NOTARIZED: YES DOCKET g FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,W.R. Carolina Power & Light Co.

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

SUMECT: Application for amend.to License NPF-63,revising portions of Section 3/4.9, "Refueling Operations" to be consistent w/

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NUREG-1431 & relocating applicable sections per Commission Final Policy Statement.

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

R NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 LE,N 1 1 INTERNAL: ACRS 6 ENTER 0 1 1 NMSS/DWM/LLDP 2 2 N DRCH C 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL NOAC 1 1 NRC PDR 1 1 C

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT TI IE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 18

Carolina Power & Light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant APR'- 5'1995 Letter Number: HO-950078 SERIAL: HNP-95-024 10 CFR 50.90 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 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 (TS) for the Shearon Harris Nuclear Power Plant (SHNPP). The proposed amendment will revise various portions of Section 3/4.9, "Refueling Operations" to be consistent with NUREG-1431, the new Standard Technical Specifications for Westinghouse Plants and will relocate applicable sections per the Commission's Final Policy Statement for relocation of current Technical Specifications. provides a detailed description of the proposed change and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. 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 needs to be prepared in connection with the issuance of the amendment. provides page change instructions for incorporating the proposed revision. provides the proposed Technical Specification page.

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.

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'.QVu'V ADOCK eaoe05 05000400 State Road 1134 New Hill NC Tel 919 362-2502 Fax 919 362-2095 oo(

Document Control Desk HNP-95-024 I Page 2 CP&L requests approval of the proposed amendment by August 14, 1995. In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be issued such that implementation will occur within 60 days of issuance of the amendment.

Please refer any questions regarding this submittal to Mr. D. C. McCarthy at (919) 362-2100.

Sincerely, W. R. Robinson Vice President Harris Nuclear Plant MV

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Environmental Considerations

4. Page Change Instructions

5. Technical Specification Pages 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 officers, employees, contractors, and agents of Carolina Power & Light Company.

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c: Mr. Dayne H. Brown Mr. S. D. Ebneter t"I Q Mr. N. B. Le >l/BLA .

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ENCLOSURE TO SERIAL: HNP-95-024 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS Backgraiind The Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132), dated July 22, 1993, provides specific criteria for the content of Technical Specifications (TS). The Final Policy Statement specifically recognizes that:

"The purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval."

The Final Policy Statement references NUREG-1431, "Standard Technical Specifications, Westinghouse Plants" and encourages licensees to implement a program to upgrade their TSs consistent with the purpose stated above. In addition, the Commission has also indicated a willingness to entertain requests to adopt portions of the improved Standard Technical Specifications (STS) as line-item improvements.

The Final Policy Statement further describes four criteria to delineate those constraints on design and operation of nuclear power plants that are derived from the plant safety analysis report or probabilistic safety assessment (PSA) information and that belong in TS in accordance with 10 CFR 50.36 and the puipose of TS stated above. Therefore, limiting conditions for operations (LCOs) which do not meet any of these four criteria may be proposed for removal from the TS and relocated to licensee-controlled documents such as an appropriate Plant Operating Manual Procedure.

TS 3/4.9, "Refueling Operations," provides operability and surveillance requirements for plant systems and activities associated with refueling the reactor vessel while in Mode-6 or with the vessel defueled, and also to ensure safe and proper storage of new and spent fuel in the Fuel Handling Building. The proposed amendment willrevise specification 3/4.9 to be consistent with NUREG-1431 and willprovide additional scheduling flexibilityfor refueling and testing activities during refueling outages.

RmposekZhange The proposed amendment revises TS requirement 3/4.9 as follows:

Limiting Condition for Operation (LCO) 3.9.1.a will be changed by deleting the generic 2000 ppm boron and ~ requirements. The corresponding wording from NUREG-1431 will be adopted which requiies the boron concentration to be maintained within the limit specified in the

ENCLOSURE TO SERIAL: HNP-95-024 Core Operating Limits Report (COLR). This is based on the fact that the current TS limits may not be bounding as higher fuel uranium enrichment levels are utilized in the future. The COLR will reflect cycle specific reactor core analysis results and their subsequent limits. Revising the wording as proposed in NUREG-1431 will ensure application of appropriate cycle specific core limits; and will eliminate the possible future use of a non-conservative "generic" value. This change will also result in the appropriate revisions to Action Statement "a" and Surveillance Requirements 4.9.1.1 and 4.9.1.2, to consistently apply the NUTMEG-1431 wording which utilizes the COLR's cycle specific analysis results and corresponding limits.

Surveillance Requirements 4.9.2.b and 4.9.2.c will be deleted. These specifications currently require that operability of the Source Range Neutron Flux Monitors be demonstrated by the performance of an Analog Channel Operational Test within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of core alterations and then at least once per 7 days thereafter. To ensure continued demonstration of source range neutron flux detector operability without the Analog Channel Operational Test, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check (SR 4.9.2.a) will still be performed and a new requirement to perform a Channel Calibration once per 18 months will be added. This change will also add more stringent requirements for determining boron concentration (an analysis within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, versus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) and to immediately initiate actions to restore a source range monitor to operable status in the event that both monitors are inoperable. In addition to providing extra scheduling flexibility for refueling and testing activities during refueling outages, the proposed revision would eliminate problems that have occurred during past performances of the Analog Channel Operational Test.

These problems involved the inability to accurately verify monitor operability when background levels were very low, due to having no fuel or neutron sources in the reactor vessel. The proposed revision is consistent with NUTMEG-1431 requirements and is based upon the continuation of reasonable testing to demonstrate proper operation of the source range neutron flux detectors contained herein.

Specification 3/4.9.4 will be revised by adding the words "or equivalent" to LCO 3.9.4.c.1 and deleting the words "within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and..." from surveillance requirement 4.9.4. The resulting sections will read as follows: 3.9.4.c.1 - "closed by a manual or automatic isolation valve, blind flange, or equivalent, or.. ~" and 4.9.4 - "Each of the above required containment building penetrations shall be determined to be either in its closed/isolated condition or capable of being closed by OPERABLE automatic normal containment purge and containment pre-entry purge makeup and exhaust isolationvalves at least once per 7 days during CORE ALT'ERATIONS or movement of irradiated fuel in the containment building by:..." The change to LCO 3.9.4.c. 1 simply clarifies the intent of the specification by allowing an equivalent means of isolation to be used. The elimination of the "within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />" requirement from surveillance 4.9.4 will result in extra scheduling flexibilityduring refueling outages by allowing operations personnel to begin the containment penetration verification testing in advance of the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> period prior to beginning core alterations. The administrative controls currently contained in operations surveillance test procedures will continue to be applied to adequately track the status of containment penetrations. These changes are consistent with the NUREG-1431 requirements.

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ENCLOSURE TO SERIAL: HNP-95-024 The APPLICABILITYstatement for specification 3.9.10 will be revised to adopt the guidance of NUREG-1431, which clearly excludes control rod drive shaft latching and unlatching operations

&om the scope of the specification. The revised APPLICABILITYstatement will read as follows:

"MODE 6, during movement of irradiated fuel assemblies within containment, or during CORE ALTERATIONS, except during latching and unlatching of control rod drive shafts...." The requirement to maintain the refueling cavity water level at least 23 feet above the top of the reactor vessel flange during core alterations is based on having sufficient water necessary to retain the total iodine fission activity resulting from a fuel handling accident involving a dropped fuel assembly. During control rod drive shaft latching and unlatching, fuel assemblies can not be lifted from the reactor core due to the fact that the upper internals are still in place and due to the weight of the assembly combined with the force of the fuel assembly hold down springs. Therefore, a dropped fuel assembly accident scenario is not possible during this operation.

To provide consistency and additional clarification, the CORE ALTERATION definition contained in NUREG-1431 will also be adopted and will replace definition 1.9 'in the DEFINITIONS section. The slight wording difference in this definition will be reflected in the associated ACTION statement for specification 3.9.10.

Surveillance Requirement 4.9.10 will be revised to delete the requirement for determining the refueling cavity water level within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the start of fuel assembly movement. This change is consistent with the requirements of NUREG-1431 and is based upon the analysis contained therein, which states that a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is considered adequate in view of the large volume of water and the normal procedural control of valve positions, which make significant unplanned level changes unlikely.

Specifications 3/4.9.3 "Decay Time," 3/4.9.5 "Communications," 3/4.9.6 "Refueling Machine,"

and 3/4.9.7 "Crane Travel - Fuel Handling Building" do not meet any of the Commission's screening criteria for retention and will therefore be relocated from TS. This is consistent, with NUREG-1431 and with the commission's Final Policy Statement for relocation of current Technical Specifications. The requirements governing Decay Time, Communications, the Refueling Machine, and Crane Travel in the Fuel Handling Building will be incorporated into and implemented by an appropriate Plant Operating Manual (POM) Procedure. The administrative controls and procedural adherence requirements associated with the POM will ensure that the intent of the original TS is satisfied.

The corresponding "Bases" sections were revised to reflect the above described changes and relocations from TS.

CQI1Glllslons The proposed changes to TS 3/4.9 "Refueling Operations" will revise the specification to be more consistent with NUREG-1431 and will provide additional scheduling flexibilityfor testing and refueling activities during refueling outages. The relocation of sections 3/4.9.3, 3/4.9.5, 3/4.9.6, and 3/4.9.7 Aom TS is based on the guidance of NtBKG-1431 and the commission's Final Policy Statement for relocation of current Technical Specifications. The proposed changes will not decrease the level of assurance that refueling activities are performed safely and in accordance with applicable governing documents.

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ENCLOSURE TO SERIAL: HNP-95-024 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS The Commission has provided standards in 10 CFR 50.92 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 Ec 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:

RraposecLChange Technical Specification 3/4.9, Refueling Operations, will be revised to be more consistent with the requirements of NIjEEG-1431, the New Standard Technical Specifications for Westinghouse Plants and will relocate applicable sections from TS that do not meet the commissions screening criteria for retention.

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.

The proposed changes will have no significant impact on the safety, reliability, or operation of fuel handling equipment or activities. These changes will simplify the Technical Specifications and implement the recommendations of the Commission's Final Policy Statement on Technical Specification Improvements based upon the assumptions and analyses contained in the bases of NUREG-1431. Those elements that involve relocations to plant procedures are administrative in nature and do not involve any modifications to plant equipment or operation. Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

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ENCLOSURE TO SERIAL: HNP-95-024 The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not introduce any new equipment or require existing equipment to operate to perform a function different from that previously evaluated in the Final Safety Analysis Report or Technical Specifications. The changes are consistent with the new Standard Technical Specifications and assumptions contained in NUREG-1431 and in the Commission's Final Policy Statement on Technical Specification Improvements. Therefore, the proposed changes would not increase the possibility of a new or different type of accident from any accident previously evaluated.

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

The proposed changes do not affect any of the parameters which relate to the margin of safety as described in the Based of the Technical Specifications or the Final Safety Analysis Report.

Accordingly, NRC Acceptance Limits are not affected by these changes. For those specifications being relocated to other plant documents, these changes are purely administrative. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

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ENCLOSURE TO SERIAL: HNP-95-024 ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS 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 an increase in individual or cumulative occupational radiation exposure. Carolina Power & 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:

Technical Specification 3/4.9, Refueling Operations, will be revised to be more consistent with the requirements of NUTMEG-1431, the New Standard Technical Specifications for Westinghouse Plants and will relocate applicable sections from TS that do not meet the commissions screening criteria for retention.

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

I. 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.

The proposed amendment does not introduce any new equipment, nor does it require existing 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.

ENCLOSURE TO SERIAL: HNP-95-024 The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

This change is administrative in nature and will revise the specification to be more consistent with NUEEG-1431 and willprovide additional scheduling flexibilityfor testing and refueling activities during refueling outages. The proposed changes will not decrease the level of assurance that refueling activities are performed safely and in accordance with applicable governing documents, nor will they decrease the testing or inspection requirements for systems and components associated with refueling activities. The amendment will have no affect on either individual or cumulative occupational radiation exposure.

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ENCLOSURE TO SERIAL: HNP-95-024 ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT REFUELING OPERATIONS Inserted>a e XV 1-2 1-2 3/4 9-1 3/4 9-1 3/4 9-3 3/4 9-3 3/4 9-4 3/4 9-4 3/4 9-5 3/4 9-5 3/4 9-6 3/4 9-6 3/4 9-7 3/4 9-7 3/4 9-8 3/4 9-8 3/4 9-12 3/4 9-12 B 3/4 9-1 B 3/4 9-1 E4-1