ML18005A209

Application for Amend to License NPF-63,revising Tech Specs 3.0.4 & 4.0.4 to Allow Entry Into Operational Condition & 4.0.3 to Provide Up to 24 H Delay to Permit Completion of Missed Surveillance,Per Generic Ltr 87-09.Fee Paid

ML18005A209
Person / Time
Site:	Harris
Issue date:	11/09/1987
From:	Eury L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18005A210	List: ML18005A209 ML18005A211
References
GL-87-09, GL-87-9, NLS-87-237, NUDOCS 8711180123
Download: ML18005A209 (12)

Text

REGULA Y INFORMATION DISTRIBUTI SYSTEM (RIDS)

ACCESSION NBR: 8711180123 DOC. DATE: 87/11/09 NOTARIZED:

YES FACIL: 50-400 Shearon Harris Nuclear Poujer Planti Unit ii Carolina AUTH. NAME AUTHOR AFFILIATION EURY> L. M.

Carolina Poujer h Light Co.

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

DOCKET 0 05000400

SUBJECT:

Application for amend to License NPF-63'evising Tech Specs to allow entrg into operational condition per action requirements 5 provide 24 h delay to permit completion of missed surveillance. Fee paid.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED: LTR Q ENCL~

SIZE: 6 +

TITLE:

OR Submittal:

General Distribution NOTES: Ap p 1 icat ion for p ermi t reneuJa 1 fi 1 ed.

05000400 RECIPIENT ID CODE/NAME PD2-i, LA BUCKLEY'S B INTERNAL: ARM/DAF/LFMB NRR/DEST/CEB NRR/DEBT/RSB N

RB REG FIL 01 EXTERNAL:

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CML Carolina Power 8 LightCompany P. O. Box 1551

~ Rafelgh, N. C. 27602 LYNNtN. EURY Senior Vice President Operations Support SERIAL: NLS-87-237 10CFR50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desi(

Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT SECTIONS 3.0 AND 0.0 - GENERIC LETTER 87-09 Gentlemen:

SUMMARY

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

The proposed amendment revises Specifications 3.0.0, 0.0.3, and 0.0.0 and the Bases Sections associated with Sections 3.0 and 0.0.

The proposed amendment is based on the guidance provided in Generic Letter 87-09, issued May 0, 1987.

DISCUSSION On May 0, 1987, the NRC issued Generic Letter 87-09, which addressed three specific problems that have been encountered with the general applicability requirements of the LimitingConditions for Operation (LCOs) and Surveillance Requirements in Sections 3.0 and 0.0 of the Technical Specifications.

To alleviate these problems, the NRC suggested revisions to Specifications 3.0.0, 0.0.3, and 0.0.0.

The Staff also proposed improved Bases for Sections 3.0 and 0.0. The following revisions are based on the Staff's guidance.

Currently, Specification 3.0.0 does not allow entry into an OPERATIONAL CONDITION unless the conditions of the LCOs are met without reliance on provisions contained in the ACTION statements.

This unduly'restricts facility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation.

The proposed revision to Specification 3.0.0 allows entry into an OPERATIONAL CONDITION in accordance with ACTION requirements when conformance to the ACTION requirements permits continued operation of the facility for 'an unlimited period of time. This is consistent with the guidance provided in Generic Letter 87-09.

In order to prevent operator confusion, individual exceptions to.Specification 3.0.0 have been deleted where necessary.

The Company considers these deletions to be administrative in nature.

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Bocument Control Desk NLS-87-237 / Page 2 Specification 0.0.3 states that performance of a Surveillance Requirement within the specified time interval shall constitute compliance with the OPERABILITYrequirements for an LCO and associated ACTION statements.

As such, if a Surveillance Requirement is not met as a result of failure to perform the scheduled surveillance, the LCO would not be met and the associated ACTION requirements must be entered.

If the missed surveillance cannot be successfully performed during the outage time limits specified in the ACTION requirements, a plant shutdown would usually be required.

The above scenario is undesirable since it increases the risk to the plant and public safety for two reasons.

First, the plant would be in a transient state involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested.

This would occur when the system or component is either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance interval was exceeded.

If the surveillance did demonstrate that the system or component was, inoperable, it usually would be preferable to restore it to operable status before making a major change in plant operating conditions.

Second, a shutdown would increase the pressure on the plant staff to expeditiously complete the required surveillance so that the plant could be returned to power operation.

This would further increase the potential for a plant transient when both the shutdown and surveillance activities place a demand on the plant operators.

The proposed revision to Specification 0.0.3 provides a delay of up to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to permit the completion of a missed surveillance when the allowable outage time limitof the ACTION requirements is less than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. It is overly conservative to assume that a system(s) or component(s) is inoperable when a Surveillance Requirement has not been performed.

The 20-hour time limit is consistent with the guidance provided in Generic Letter 87-09.

This limit balances the risks associated with an allowance. for completihg-"

the surveillance against the risks associated with the potential for a plant transient and challenge to safety systems when the alternative is a shutdown to comply with ACTION requirements before the surveillance can be completed.

Specification 0.0.0 prohibits entry into an OPERATIONAL CONDITION unless the Surveillance Requirements associated with the LCOs have been performed within the applicable surveillance interval. This creates a conflict when a mode change is required as a consequence of shutdown ACTION Requirements and the associated Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. The proposed revision clarifies Specification 0.0.0 by adding the phrase:

"This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."

The proposed revision.

to Specification 0.0.3, which permits a delay of up to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> in the applicability of the ACTION requirements, allows sufficient time for the completion of those Surveillance Requirements that become applicable when an exception to Specification 0.0.0 is allowed.

Carolina Power R Light Company also intends to incorporate slightly modified versions of the revised Bases for Specifications 3.0 and 0.0 provided in Generic Letter 87-09.

The Bases for Specification 3.0.1 provided in Generic Letter 87-09 contains the following statements:

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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 wording of this statement is misleading and seems to imply that the removal of technical specification systems and components from service for surveillance testing or investigation of operational problems is unacceptable.

In order to avoid operator confusion, the Company has revised this statement as follows:

It is not intended that the shutdown portion of the ACTION, requirements be used as an operational convenience which permits removal of a redundant system(s) or component(s) from service.

The similar statement in the Bases for Specification 3.0.3 was also modified as described above.

SIGNIFICANTHAZARDS ANALYSIS The Commission has provided standards in IOCFR50.92(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: (I) 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 2 Light Company has reviewed this request and determined that:

1.

The proposed revision to Specification 3.0.0 does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The revision allows entry into an OPERATIONAL CONDITION in accordance with ACTION requirements when conformance to the ACTION requirements permits continued operation of the facility for an unlimited period of time. This operational flexibilityis consistent with that allowed by the existing individual LCOs and their associated ACTION requirements which provide an acceptable level of safety for continued operation.

The proposed revision to Specification 0.0.3 does not involve a significant increase in the probability or consequences of an accident previously.

evaluated.

Providing a delay of up to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to permit the completion of a missed surveillance when the allowable outage time of the ACTION requirements is less than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> reduces the probability of a transient occurring when the affected system or component is either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance interval was exceeded.

As such, the probability and consequences of an accident previously evaluated are actually reduced as a result of the proposed revision.

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Document Control Desk NLS-87-237 / Page 0 The proposed revision to Specification 0.0.0 does not involve a significant increase in the probability or consequences of an accident previously evaluated because it is a clarification to the specification and as such it is administrative in nature.

The revision makes it clear that Specification 0.0.0 does not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements, This is consistent with the existing Specification 3.0.0.

The revisions to the Bases Sections 3.0 and 0.0 and the elimination of specific exemptions to Specification 3.0.0 are administrative in nature and, therefor'e, do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

3.

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because..

there is no physical alteration to any plant system, nor is there a change in the method in which any safety related system performs its function. The proposed revisions result in improved Technical Specifications by removing:

(I) unnecessary restrictions on mode changes and,facility operation; (2) unnecessary shutdowns caused by inadvertently exceeding surveillance intervals; and (3) conflicts within the Technical Specifications themselves.

The revisions to the Bases Sections 3.0 and 0.0 and the elimination of specific exemptions to Specification 3.0.0. are administrative in nature and, therefore, do 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 a margin of safety.

The revision to Specification 3.0.0 allows operational flexibilitywhich is consistent with that allowed by the existing individual LCOs and their associated ACTION requirements which provide an acceptable level of safety for continued operation.

The proposed revision to Specification 0.0.3 reduces the risk to the plant and public safety by providing a delay of up to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to permit the completion of a missed surveillance when the allowable outage time limit of the ACTION requirements is less than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

This reduces the probability of a transient occurring when the affected system or component is either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance interval was exceeded.

The revision to Specification 0.0.0 is a clarification to the specification and as such is administrative in nature.

The revision makes it clear that Specification 0.0.0 does not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.

This is consistent with the existing Specification 3.0.0.

These revisions result in improved Technical Specifications and, therefore, increase the margin of safety.

The revisions to the Bases Sections 3.0 and 0.0 and the elimination of specific exemptions to Specification 3.0.0 are administrative in nature and, therefore, do not involve a significant reduction in a margin of safety.

Based on the above reasoning, Carolina Power 4 Light Company has determined that the proposed amendment does not involve a significant hazards consideration.

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Bocument Control Desk NLS-87-237 / Page 5

ADMINISTRATIVEINFORMATION The revised SHNPP Technical Specification and Bases pages are provided in Enclosures 1

and 2. The Company has evaluated this request in accordance with the provisions of 10CFR170.12 and determined that a license amendment application fee is required.

A check for $ 150 is enclosed in payment of this fee.

Please refer any questions regarding this matter to Mr. Sherwood R. Zimmerman at (919) 836-6202.

Yours very truly, L. W. Eury LWE/MAT/mss (5322AWS)

Enclosures Ccs Mr. D. H. Brown Mr. B. C. Buckley Dr. 3. Nelson Grace Mr. G. F. Maxwell L. W. Eury, having been first duly sworn, did depose and say-that thesinformation 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 R Light Company.

My commission expires:

///Q.7/cPP Notary Seal

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