Text

Application for Amend to License NPF-63,implementing Selected Improvements Described in GL 93-05
	ML18017A925
Person / Time
Site:	Harris
Issue date:	10/21/1999
From:	Scarola J; CAROLINA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18017A926	List: ML18017A925; ML18017A927;
References
	GL-93-05, HNP-99-149, NUDOCS 9910280145
	Download: ML18017A925 (12)
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ACCESSION NBR:9910280145 DOC.DATE: 99/10/21 NOTARIZED: YES DOCKET FACXL.:50-400Shearo~ Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.AAA'KP.':"y ~ ,AUTHOR AFFILIATION SCAROLA,Z. Carolina Powex & Light Co.

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

SUBJECT:

Application for amend to license NPF-63,implementing

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selected improvements described in GL 93-05. C X

DTSTRTBUTTON CODE: A001D COPTES RECEIVED:LTR

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TITLE: OR Submittal: General Distribution T

NOTES:Application for permit renewal filed. 05000400 E

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NRR/DSSA/SPLB 1 NRRT/DSSA/'SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/RP 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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Carolina Pawer & Light Company James Scarola PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant OCT 21 1999 SERIAL: HNP-99-149 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 PROPOSED IMPLEMENTATIONOF NRC GENERIC LETTER 93-05

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 implements selected improvements described in NRC Generic Letter 93-05, dated September 27, 1993. 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.

eva0280145 <~~<<2< I'I PDR ADQCK 05000400 p PDR 5d13 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095

Please refer any questions regarding this submittal to Mr. J. H. Eads at (919) 362-2646.

Sincerely, 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, knowledg'e and belief, and the sources of his information are employees, contractors, and agents of Carolina Power & Light Company.

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

ENCLOSURE 1 TO SERIAL: HNP-99-149 SHEARON HARMS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PROPOSED IMPLEMENTATIONOF NRC GENERIC LETTER 93-05 BASIS FOR CHANGE RE UEST

~Back round On September 27, 1993, the NRC issued Generic Letter (GL) 93-05, "Line-Item Technical" Specifications To Reduce Surveillance Requirements For Testing During Power Operation.

The GL 93-05 was written as part of the NRC Technical Specification Improvement Program (TSIP) which was reported in NUREG-1366, "Improvements To Technical Specifications Surveillance Requirements," December 1992.

In performing NUREG-1366, the staff found that, while the majority of testing at power was important, safety can be improved, equipment degradation can be decreased, and an unnecessary burden on personnel resources eliminated by reducing the amount of testing that the TS require during power operation. The staff prepared GL 93-05 to assist licensees in preparing a license amendment request to implement these recommendations as line-item TS improvements. The staff encouraged licensees to propose TS changes that are consistent with the guidance in GL 93-05.

d Ch Harris Nuclear Plant (HNP) proposes to modify selected Technical Specifications (TS) to be consistent with guidance in NRC Generic Letter 93-05, dated September 27, 1993.

Specifically, HNP proposes to modify the following TS to be consistent with GL 93-05:

1. TS 4.1.3.1.2 - Change the frequency of the control rod movement test to quarterly.

2. TS 4.6.4.1 - Change the frequency of the Hydrogen Monitor analog channel operational test to quarterly.

3. TS 4.3.3.1 (Table 4.3-3) - Change the Radiation Digital Channel Operational Test to quarterly.

4. TS 4.4.6.2.2.b. - Change the time for remaining in cold shutdown without leak testing the Reactor Coolant System Pressure Isolation Valves to 7 days.

5. TS 4.4.3.2 - Change the testing of the capacity of pressurizer heaters to once per 18 months.

6. TS 4.6.4.2.a. - Change the Hydrogen Recombiner functional test to once per 18 months.

7. TS 4.7.1.2.1.a - Change frequency of testing Auxiliary Feedwater Pumps to quarterly.

Basis The following proposed changes to Technical'Specifications are compatible with plant operating experience and are consistent with the guidance in NRC GL 93-05.

TS 4.1.3.1.2- Chan e the fre uenc of the PWR control rod movement test to uarterl Surveillance Requirement 4.1.3.1.2 is a test performed to determine if the control rods are immovable. The control rods may be immovable either because of an electrical problem in the control rod drive circuitry or because the control rod is mechanically stuck. The concern with this test is that it causes reactor trips or dropped rods. NUREG-1366, dated December 1992, described a review of plant trip data from 1986 through July 1988 that found three reactor trips that occurred during fuel rod motion testing. NUREG-1366 also states that most stuck rods are discovered during plant startup during initial pulling of the rods or during rod drop testing.

The control rod system at HNP has a successful operational record as demonstrated by previous successful control rod movement tests. In addition, adequate control rod performance has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

Therefore, HNP proposes to change the frequency of the control rod movement test to quarterly in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.6.4.1 - Chan e the fre uenc of the anglo channel o erational test to uarterl for H dro enMonitorin Hydrogen monitors axe used to monitor hydrogen concentration in containment following a loss-of-coolant accident (LOCA) and are designed to be consistent with Regulatory Guide 1.2, "Control 'of Combustible Gas Concentrations in Containment following a LOCA." These monitors are used only aAer a LOCA to tell the operator when to initiate the hydrogen recombiners. The hydrogen recombiners are not required for a period of hours to days after a large break LOCA.

The Hydrogen Monitoring system at HNP has a successful operational record as demonstrated by previous successful analog channel operational tests. In addition, adequate Hydrogen Monitoring performance has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

The staff recommended, in NUREG 1366, that the Hydrogen Monitoring Channel Operational test be revised to a quarterly requirement in part because the Hydrogen Monitors serve as an indicating function and are only required after an accident in which the core is damaged.

Therefore, HNP proposes to change the frequency of the analog channel operational test to quarterly in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.3.3.1 Table 4.3 Chan e the Radiation Monitor Di ital Channel 0 erational Test to

~uarterl .

HNP radiation monitors in TS 4.3.3.1 (Table 4.3-3) are digital microprocessor controlled components. The current monthly Digital Channel Operational Test consists of reducing the alarm setpoint to less than the current reading and verifying that the alarm and/or trip function occurs. The monitors are digital. Therefore, the setpoint cannot drift.

The TS Radiation Monitoring system at HNP has a successful operational record as demonstrated by previous successful calibration and analog channel operational tests. In addition, adequate Radiation Monitoring performance has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance

rule, (a)(1) list due to operational history.

Therefore, HNP proposes to change the Radiation Monitor Digital Channel Operational Test to quarterly in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.4.6.2.2.b. - Chan e the time for remainin in cold shutdown without leak testin the Reactor Coolant S stem Pressure Isolation Valves to 7 da s.

HNP TS currently require that the reactor coolant system (RCS) pressure isolation valves (PIV),

specified in Table 3.4-1, be demonstrated operable by verifying leakage to be within limits prior to entering Mode 2 whenever the plant has been in cold shutdown for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or more and if leakage testing has not been performed in the previous 9 months.

The NRC, in NUREG-1366, stated that in the judgement of the NRC staff, making the conduct of this surveillance contingent upon being shut down 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or more has a potential for causing problems resulting from a hurried recovery. The staff stated that extending the surveillance test interval associated with this surveillance does not alter the associated risk.

The TS RCS PIV at HNP have a successful operational record as demonstrated by previous successful leakage tests. In addition, adequate RCS PIV performance has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

Therefore, HNP proposes to change the time for remaining in cold shutdown without leak testing the Reactor Coolant System Pressure Isolation Valves to 7 days in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.4.3.2- Chan e the testin of the ca acit of ressurizer heaters to once er18 months.

Pressurizer heaters at HNP are normally used in modes 1-4. The backup heaters ( groups "A"and "B") are used during normal operation (not dedicated safety-related pressurizer heaters) and are credited with meeting the requirements of TS 4.4.3.2. Indication of electrical current (amps) for pressurizer heaters is provided on the main control board for groups "A" and "B". Operators can monitor pressurizer heater performance for groups "A"and "B" during routine operation.

The TS pressurizer heaters at HNP have a successful operational record as demonstrated by previous successful capacity tests. In addition, adequate performance of TS pressurizer heaters has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

The staff determined, in NUREG-1366, that the operator should be aware of the status of both proportional and backup pressurizer heaters during normal operation and that 92 days appears too frequent for capacity tests. The staff recommended performing the capacity test once during each refueling interval.

Therefore, HNP proposes to change the testing of the capacity of pressurizer heaters to once per 18 months in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.6.4.2.a. - Chan e the H dro en Recombiner functional test to once er 18 months.

The hydrogen recombiner system removes the hydrogen gases that accumulate in the containment atmosphere following a design-basis LOCA. NUREG-1366 described a search of industry LERs performed by the staff to determine the reliability of hydrogen recombiners. As a result of the study, the NRC staff concluded that hydrogen recombiners were highly reliable.

HNP has two hydrogen recombiners and a containment hydrogen purge system. NUREG-1366 recommended that, because of the redundancy and the high reliability of the system, the surveillance test interval of the functional test be changed to once each refueling interval.

The hydrogen recombiner system at HNP has a successful operational record as demonstrated by previous successful functional tests. In addition, adequate performance of the hydrogen recombiner system has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

Therefore, HNP proposes to change the Hydrogen Recombiner functional test to once per 18 months in accordance with the guidance of GL 93-05 and NUREG-1366.

TS 4.7.1.2.1.a - Chan e fre uenc of testin Auxilia Feedwater Pum s to uarterl NUREG-1366 discussed two studies (EPRI report NP-4264 and NUREG/CR-4597) in which it was determined that a significant cause of failures of Auxiliary Feedwater Pumps (AFWP) is testing the pump by recirculating flow through a minimum flow line which is not adequately sized. Although an increase in recirculating line size would reduce failure of AFWP during testing, adequate flow might not be available to the steam generators during an accident.

Increasing the recirculation line would require isolation of the recirculation flow path during an accident. This could require a complicated interlock which would close valves on the recirculation line when an actual demand signal was present.

NUREG-1366 proposed an alternate method for reducing AFWP failures, due to testing, by reducing the frequency of AFWP testing from monthly to quarterly. The NRC determined, in NUREG-1366, that reducing the 1requency of testing AFWP may increase the overall availability by reducing failures and equipment degradation. Testing AFWP on a quarterly staggered test basis would still provide for monthly system testing. Furthermore, requiring quarterly AFWP testing would provide for consistency between TS and the ASME Code which also requires class 2 pumps (such as AFWP) to be tested quarterly.

The Auxiliary Feedwater Pumps at HNP have a successful operational record as demonstrated by previous successful functional tests. Additionally, adequate performance of the AFWP has been demonstrated by the applicable components not currently (as of September 20, 1999) being on the 10CFR50.65, maintenance rule, (a)(1) list.

Therefore, HNP proposes to change frequency of testing Auxiliary Feedwater Pumps to quarterly in accordance with the guidance of GL 93-05 and NUREG-1366.

==

Conclusion:==

The proposed license amendment is in accordance with GL 93-05 and is consistent with the guidance in NUREG-1366. The proposed TS changes are compatible with plant operating experience. Modifying the surveillance intervals as specified in this proposed license amendment will significantly reduce the regulatory burden at HNP without compromising plant safety.

ENCLOSURE 2 TO SERIAL: HNP-99-149 SHEARON HARMS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PROPOSED IMPLEMENTATIONOF NRC GENERIC LETTER 93-05 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 & 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 selected Technical Specifications (TS) to be consistent with guidance in NRC Generic Letter (GL) 93-05, dated September 27, 1993.

Specifically, HNP proposes to modify the following TS to be consistent with GL 93-05:

1. TS 4.1.3.1.2 - Change the frequency of the control rod movement test to quarterly.

2. TS 4.6.4.1 - Change the frequency of the Hydrogen Monitor analog channel operational test to quarterly.

3. TS 4.3.3.1 (Table 4.3-3) - Change the Radiation Digital Channel Operational Test to quarterly.

4. TS 4.4.6.2.2.b. - Change the time for remaining in cold shutdown without leak testing the Reactor Coolant System Pressure Isolation Valves to 7 days.

5. TS 4.4.3.2 - Change the testing of the capacity of pressurizer heaters to once per 18 months.

6. TS 4.6.4.2.a. - Change the Hydrogen Recombiner functional test to once per 18 months.

7. TS 4.7.1.2.1.a - Change frequency of testing Auxiliary Feedwater Pumps to quarterly.

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.

There are no systems being modified as a result of this change. Additionally, the way in which equipment is tested is not affected by this change. Reducing surveillance intervals for TS components (such as control rod testing) may reduce the probability of an accident (rod drop accident) by reducing actions that could cause an accident to occur (rod movement).

Therefore, the proposed change does not involve a significant increase in 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.

No system, structure, or component is being modified as a result of this change.

Additionally, there are no changes to the way equipment is operated as a result of this change. Operating parameters are not being modified as a result of this change.

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.

These proposed changes are in accordance with NRC Generic Letter 93-05, dated September 27, 1993 and NUREG-1366, dated December 1992. These changes pertain to testing requirements for TS equipment which help ensure operability requirements are met. This change does not modify the required safety function or operating parameters for equipment described in HNP TS.

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

E2-2

ENCLOSURE 3 TO SERIAL: HNP-99-149 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PROPOSED IMPLEMENTATIONOF NRC GENERIC LETTER 93-05 ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion &om 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 Ec 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: