ML032731650

Request for Additional Information Regarding Reactor Vessel Pressure-Temperature Limits in TS

ML032731650
Person / Time
Site:	Catawba
Issue date:	09/30/2003
From:	Martin R NRC/NRR/DLPM/LPD2
To:	Jamil D Duke Energy Corp
Martin R, NRR/DLPM, 415-1493
References
TAC MB8106, TAC MB8107, TAC MB8109, TAC MB8110
Download: ML032731650 (8)

Text

September 30, 2003 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745

SUBJECT:

CATAWBA NUCLEAR STATION, UNITS 1 AND 2 RE: REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB8106, MB8107, MB8109 AND MB8110)

Dear Mr. Jamil:

By letter dated March 20, 2003, you submitted an application for amendment of the Technical Specifications (TS) for the Catawba Nuclear Station (Catawba), Units 1 and 2, to revise the reactor vessel pressure-temperature (P-T) limits in the Catawba TS. The U. S. Nuclear Regulatory Commission technical staff has reviewed the application and has determined that additional information is required, as identified in the Enclosure.

We discussed these issues with your staff on September 24, 2003. Your staff indicated that you would attempt to provide your response by October 20, 2003.

Please contact me at (301) 415-1493, if you have any other questions on these issues.

Sincerely,

/RA/

Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414

Enclosure:

As stated cc w/encl: See next page

September 30, 2003 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745

SUBJECT:

CATAWBA NUCLEAR STATION, UNITS 1 AND 2 RE: REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB8106, MB8107, MB8109 AND MB8110)

By letter dated March 20, 2003, you submitted an application for amendment of the Technical Specifications (TS) for the Catawba Nuclear Station (Catawba), Units 1 and 2, to revise the reactor vessel pressure-temperature (P-T) limits in the Catawba TS. The U. S. Nuclear Regulatory Commission technical staff has reviewed the application and has determined that additional information is required, as identified in the Enclosure.

We discussed these issues with your staff on September 24, 2003. Your staff indicated that you would attempt to provide your response by October 20, 2003.

Please contact me at (301) 415-1493, if you have any other questions on these issues.

Sincerely,

/RA/

Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC OGC CHawes KDesai PDII-1 R/F ACRS RMartin JNakoski LPlisco, RII RHaag, RII ADAMS Accession: ML032731650 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME RMartin CHawes JNakoski DATE 09/27 /03 09/25/03 09/25 /03 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal dated March 20, 2003, regarding proposed changes to the low temperature overpressure (LTOP)

Technical Specifications (TS). The NRC staff has identified the following information that is needed to enable the continuation of its review.

1. The Surveillance Requirement (SR) 3.4.12.3 NOTE is proposed to state Only required to be performed when complying with Required Action G.2. The proposed format is not correct. SRs verify that the limiting condition for operation (LCO) is being met and do not refer to required actions. Since LCO 3.4.12.d for the reactor coolant system (RCS) vent is proposed to be deleted, the proposed revision to the SR 3.4.12.3 NOTE is not acceptable and needs to be revised.

2. NUREG-1431, Standard Technical Specifications (STS) for Westinghouse Plants, has two surveillance requirements that relate to LCO 3.4.12.b (two residual heat removal suction relief valves) that have the following requirements:

SR 3.4.12.4 Verify [residual heat removal] RHR suction valve is open for each required RHR suction relief valve. Frequency is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SR 3.4.12.7 Verify associated RHR suction isolation valve is locked open with operator power removed for each required RHR suction relief valve.

Frequency is 31 days.

In its submittal dated March 20, 2003, the licensee proposed to add the following surveillance requirement to the Catawba TS:

SR 3.4.12.7 Verify both associated RHR suction isolation valves are open with operator power removed for each required RHR suction relief valve.

Frequency is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Given that the licensee is proposing to operate with a maximum of two pumps injecting into the RCS during MODES 4 and below, the licensee should either adopt STS SR 3.4.12.4 or explain why it is not necessary to verify that LCO 3.4.12.b is being met. In addition, the licensee should address why the RHR suction isolation valves are not locked open as described in STS 3.4.12.7.

3. Page 2-3 of Attachment 2, Description of Proposed Changes and Technical Justification, of the licensees submittal describes the RHR system. Specifically, the licensees submittal states that The two inlet isolation valves in each subsystem are separately and independently interlocked with pressure signals to prevent their being opened whenever the RCS pressure is greater than approximately 385 psig. The licensee has proposed a new LCO 3.4.12.b which would state:

Enclosure

Two residual heat removal (RHR) suction relief valves with lift settings $ 417 psig and # 509 psig with an indicated RCS cold leg temperature $ 70EF; or.

The STS bases for LCO 3.4.12.b state that autoclosure interlocks are not permitted to cause the RHR suction isolation valves to close. Since the proposed lift settings for the RHR suction relief valves are at a higher pressure than the RHR interlock described on Page 2-3, it is not clear whether the interlock for the two inlet isolation valves is bypassed or disabled while two RHR suction relief valves are used to meet LCO 3.4.12.b. Provide a more detailed description of the RHR interlock and its interaction, if any, to an LTOP system that is operating in accordance with proposed LCO 3.4.12.b.

4. Page 2-10 of Attachment 2 describes the results of the analyses of the reactor coolant pump (RCPs) operating restrictions for LTOP. Specifically, with the power operated relief valves (PORVs) providing overpressure protection, the number of RCPs is restricted to two RCPs on Unit 1 and one RCP on Unit 2 at RCS temperatures $ 70EF (with instrument uncertainty). With the RHR relief valves providing overpressure protection, the number of RCPs is restricted to four RCPs on Units 1 and 2 at RCS temperature $ 126 EF and 140 EF (with instrument uncertainty), respectively. These values are presented on TS Table 3.4.12-1. However, there is no indication to the reader of TS Table 3.4.12-1 regarding those values that apply to each method of overpressure protection (PORV or RHR relief valves). Revise TS Table 3.4.12-1 appropriately or provide an explanation as to why further clarification of TS Table 3.4.12-1 is not necessary.

Catawba Nuclear Station cc:

Mr. Gary Gilbert North Carolina Electric Membership Regulatory Compliance Manager Corporation Duke Energy Corporation P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident Inspector Ms. Lisa F. Vaughn U.S. Nuclear Regulatory Commission Duke Energy Corporation 4830 Concord Road Mail Code - PB05E York, South Carolina 29745 422 South Church Street P.O. Box 1244 Henry Porter, Assistant Director Charlotte, North Carolina 28201-1244 Division of Waste Management Bureau of Land and Waste Management Anne Cottingham, Esquire Department of Health and Environmental Winston and Strawn Control 1400 L Street, NW 2600 Bull Street Washington, DC 20005 Columbia, South Carolina 29201-1708 North Carolina Municipal Power Mr. C. Jeffrey Thomas Agency Number 1 Manager - Nuclear Regulatory 1427 Meadowwood Boulevard Licensing P. O. Box 29513 Duke Energy Corporation Raleigh, North Carolina 27626 526 South Church Street Charlotte, North Carolina 28201-1006 County Manager of York County York County Courthouse Saluda River Electric York, South Carolina 29745 P. O. Box 929 Laurens, South Carolina 29360 Piedmont Municipal Power Agency 121 Village Drive Mr. Peter R. Harden, IV Greer, South Carolina 29651 VP-Customer Relations and Sales Westinghouse Electric Company Ms. Karen E. Long 6000 Fairview Road Assistant Attorney General 12th Floor North Carolina Department of Justice Charlotte, North Carolina 28210 P. O. Box 629 Raleigh, North Carolina 27602 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713

Catawba Nuclear Station cc:

Mr. T. Richard Puryear Owners Group (NCEMC)

Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Richard M. Fry, Director Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721