ML041600607

License Amendment Request to Eliminate Requirements for Hydrogen Recombiners (Technical Specification 3.6.7) & Requirements for Hydrogen Monitors (Technical Specification 3.3.3), Using the CLIIP

ML041600607
Person / Time
Site:	Catawba
Issue date:	05/27/2004
From:	Jamil D Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML041600607 (29)

Text

I % Duke D.M. JAMIL r or Power, Vice President A Duke Energy Company Duke Power Catawba Nuclear Station 4800 Concord Rd. / CNO1 VP York, SC 29745-9635 803 831 4251 803 831 3221 fax May 27, 2004 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

Subject:

Duke Energy Corporation Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 License Amendment Request to Eliminate the Requirements for the Hydrogen Recombiners (Technical Specification 3.6.7) and the Requirements for Hydrogen Monitors (Technical Specification 3.3.3), Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Duke Energy Corporation (Duke) is submitting a license amendment request (LAR) for the Facility Operating Licenses and Technical Specifications (TS) for Catawba Nuclear Station Units 1 and 2. The proposed amendment would eliminate the TS 3.6.7 requirements for the Hydrogen Recombiners and the TS 3.3.3 requirements for Hydrogen Monitors. Conforming changes are also being made to all associated Bases affected by this LAR and these Bases changes are included in this submittal package. This change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Rev. 1 (Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors).

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS and Bases pages marked up to show the proposed change. Attachment 3 containing reprinted AD www. duke-energy. corn

U.S. NRC May 27, 2004 Page 2 pages of the affected TS and Bases pages, will be provided to the NRC upon issuance of the approved amendment.

Implementation of this proposed change to the Catawba Facility Operating Licenses and TS will require revision to the Catawba Updated Final Safety Analysis Report (UFSAR).

Necessary UFSAR changes will be submitted in accordance with 10 CFR 50.71(e).

Since the proposed license amendment is a Consolidated Line Item Improvement Process (CLIIP) item, Duke requests approval by August, 2004, with implementation to occur within 60 days of the receipt of NRC approval.

Duke commits to maintaining a hydrogen monitoring system that is capable of diagnosing beyond design-basis accidents.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, the site-specific changes contained in this proposed amendment have been reviewed and approved by the Catawba Plant Operations Review Committee. This proposed amendment has also been reviewed and approved by the Duke Nuclear Safety Review Board. Pursuant to 10 CFR 50.91, a copy of this amendment request is being sent to the appropriate State of South Carolina official.

Inquiries on this matter should be directed to A. Jones-Young at (803) 831-3051.

Very truly yours D. M. Jamil Site Vice President ATTACHMENTS

U.S. NR C May 27, 2004 Page 3 D. M. Jamil, being duly sworn, affirms that he is the person who subscribed his name to the foregoing statement, and that all matters and facts set forth herein are true and correct to the best of his knowledge.

I4 D. M. Jamil, Si Vice President Subscribed and sworn to me: --D. M. &k Ta e a.4z&i, Notary Public My commission expires: )1 6, BogZ0 SEAL

U.S. NRC May 27. 2004 Page 4 xc (with attachments):

W. D. Travers U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 S. E. Peters NRC Project Manager U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 E. F. Guthrie Senior Resident Inspector U. S. Nuclear Regulatory Commission Catawba Nuclear Site H. J. Porter Division of Radioactive Waste Management South Carolina Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201

I ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 INTRODUCTION

The proposed license amendment eliminates the TS requirements for the Hydrogen Recombiners and the TS requirements for Hydrogen Monitors.

The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Rev. 1 (Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors). The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the Consolidated Line Item Improvement Proces (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

Deleted - TS 3.3.3, Applicability, Note: Reference to Hydrogen Monitors Deleted - TS 3.3.3, Condition F, Note: Reference to Hydrogen Monitors Deleted - TS 3.3.3, Condition G (Inoperable Hydrogen Monitors)

Deleted - SR 3.3.3.2, Channel Calibration for Hydrogen Monitors Deleted - Table 3.3.3-1, Item 8 (Hydrogen Monitors)

Deleted - TS 3.6.7 (Hydrogen Recombiners)

U.S. NR C ATTACHMENT I May 27, 2004 Page 2 (Other TS changes included in this amendment are limited to formatting changes that resulted directly from the deletion of the above requirements related to Hydrogen Recombiners and Hydrogen Monitors.)

As described in the NRC-approved Revision 1 of TSTF-447, the changes to TS requirements result in changes to various TS Bases sections. Proposed changes to the TS Bases are provided in Attachment 2.

3.0 BACKGROUND

The Background for this amendment is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rule making, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this amendment are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rule making, and other related documents.

5.0 TECHNICAL ANALYSIS

Duke has reviewed the safety evaluation published on September 25,2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC Staff's evaluation as well as supporting information for the TSTF. Duke has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Catawba Units 1 and 2, and justify this amendment for incorporation into the Catawba TS.

U.S. NRC ATTACHMENT I May 27, 2004 Page 3

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rule making, and other related documents.

6.1 Verification and Commitments As discussed in the model safety evaluation published in the Federal Register on September 25, 2003 (68 FR 55416),

for this TS improvement, Duke is making the following verifications and regulatory commitments:

1. Duke has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at Catawba Nuclear Station (CNS) and is making a regulatory commitment to maintain that capability. The Hydrogen Monitors will be included in the Selected Licensee Commitments Manual. This regulatory commitment will be implemented within 60 days of issuance of the license amendment.

2. CNS does not have an inerted Containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Duke has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416), as part of the CLIIP. Duke has concluded that the determination is hereby incorporated by reference to satisfy the requirement of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION Duke has reviewed the environmental evaluation included in the model safety evaluation published on September 25, 2003 (68 FR 55416), as part of the CLIIP. Duke has concluded the staff's findings presented in that evaluation are applicable to CNS and the evaluation is hereby incorporated by reference for this amendment.

U.S. NRC ATTACHMENT I May 27, 2004 Page 4 9.0 PRECEDENT This amendment is being made in accordance with the CLIIP.

Duke is not proposing variations or deviations from the TS changes described in TSTF-447, Revision 1, or the staff's model safety evaluation published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

Federal Register Notice: Notice of availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION and BASES CHANGES (MARK-UP)

TABLE OF CONTENTS (continued) 3.4 REACTOR COOLANT SYSTEM (RCS) ........................................... 3.4.1-1 I) 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Umits ............................................ 3.4.1-1 3.4.2 RCS Minimum Temperature for Criticality ....................................... 3.4.2-1 3.4.3 RCS Pressure and Temperature (PIT) Umits ................................. 3.4.3-1 3.4.4 RCS Loops-MODES 1 and 2 ........................................... 3.4.4-1 3.4.5 RCS Loops-MODE 3............................................ 3.4.5-1 3.4.6 RCS Loops-MODE 4............................................ 3.4.6-1 3.4.7 RCS Loops-MODE 5, Loops Filled........................................... 3.4.7-1 3.4.8 RCS Loops -MODE 5, Loops Not Filled ....................................... 3.4.8-1 3.4.9 Pressurizer .............................................. 3.4.9-1 3.4.10 Pressurizer Safety Valves............................................ 3.4.10-1 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) ...................... 3.4.11-1 3.4.12 Low Temperature Overpressure Protection (LTOP) System.........................................................................3.4.12-1 3.4.13 RCS Operational LEAKAGE ........................................... 3.4.13-1 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage ................................. 3.4.14-1 3.4.15 RCS Leakage Detection Instrumentation........................................3.4.15-1 3.4.16 RCS Specific Activity ........................................... 3.4.16-1 3.4.17 RCS Loop-Test Exceptions ........................................... 3.4.17-1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) ............................. 3.5.1-1 3.5.1 Accumulators ........................................... 3.5.1-1 3.5.2 ECCS-Operating ........................................... 3.5.2-1 3.5.3 ECCS-Shutdown ............................................ 3.5.3-1 3.5.4 Refueling Water Storage Tank (RWST) .......................................... 3.5.4-1 3.5.5 Seal Injection Flow.........................................................................3.5.-1 3.6 CONTAINMENT SYSTEMS ................................................... 3.6.1-1 3.6.1 Containment .................................................. 3.6.1-1 3.6.2 Containment Air Locks ................................................... 3.6.2-1 3.6.3 Containment Isolation Valves ................................................... 3.6.3-1 3.6.4 Containment Pressure .................................................. 3.6.4-1 3.6.5 Containment Air Temperature ................................................... 3.6.5-1 3.6.6 Containment Spray System .................................................. 3.6.6-1 3.6.7 o 4ydrogn ......................................... 3.G.7-1 3.6.8 Hydrogen Skimmer System (HSS) ................................................. 3.6.8-1 3.6.9 Hydrogen Ignition System (HIS) .................................................. 3.6.9-1 3.6.10 Annulus Ventilation System (AVS)..................................................3.6.10-1 3.6.11 Air Return System (ARS) ................................................... 3.6.11-1 3.6.12 Ice Bed .................................................. 3.6.12-1 3.6.13 Ice Condenser Doors .................................................. 3.6.13-1 3.6.14 Divider Barrier Integrity .................................................. 3.6.14-1 3.6.15 Containment Recirculation Drains .................................................. 3.6.15-1 3.6.16 Reactor Building .......... 3.6.16-1 3.6.17 Containment Valve Injection Water System (CVIWS) ..................... 3.6.17-1 Catawba Units 1 and 2 ii Amendment Nos. 4-70A6&

TABLE OF CONTENTS B3.4 REACTOR COOLANT SYSTEM (RCS) (continued)

B 3.4.9 Pressurizer ............................................. B 3.4.9-1 B 3.4.10 Pressurizer Safety Valves .................. ........................... B 3.4.10-1 B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) ............ .......... B 3.4.11-1 B 3.4.12 Low Temperature Overpressure Protection (LTOP) System ......... ..B 3.4.12-1 B 3.4.13 RCS Operational LEAKAGE ....................... ...................... B 3.4.13-1 B 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage ....................... .......... B 3.4.14-1 B 3.4.15 RCS Leakage Detection Instrumentation ........................................ B 3.4.15-1 B 3.4.16 RCS Specific Activity ............................................. B 3.4.16-1 B 3.4.17 RCS Loops-Test Exceptions ............................................. B 3.4.17-1 B3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.1 Accumulators ............................................. B 3.5.1-1 B 3.5.2 ECCS-Operating ............................................. B 3.5.2-1 B 3.5.3 ECCS-Shutdown ............................................. B 3.5.3-1 B 3.5.4 Refueling Water Storage Tank (RWST) .......................................... B 3.5.4-1 B 3.5.5 Seal Injection Flow ............................................. B 3.5.5-1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment .B 3.6.1-1 B 3.6.2 Containment Air Locks .B 3.6.2-1 B 3.6.3 Containment Isolation Valves .B 3.6.3-1 B 3.6.4 Containment Pressure .B 3.6.4-1 B 3.6.5 Containment Air Temperature .B 3.6.5-1 B 3.6.6 Containment Spray System .B 3.6.6-1 B 3.6.74(4 s)5dregen Recombiners-.. _.6.7-1 B 3.6.8 Hydrogen Skimmer System (HSS) .B 3.6.8-1 B 3.6.9 Hydrogen Ignition System (HIS) .B 3.6.9-1 B 3.6.10 Annulus Ventilation System (AVS) .B 3.6.10-1 B 3.6.11 Air Return System (ARS) .B 3.6.11-1 B 3.6.12 Ice Bed .B 3.6.12-1 B 3.6.13 Ice Condenser Doors .B 3.6.13-1 B 3.6.14 Divider Barrier Integrity .B 3.6.14-1 B 3.6.15 Containment Recirculation Drains .B 3.6.15-1 B 3.6.16 Reactor Building .B 3.6.16-1 B 3.6.17 Containment Valve Injection Water System (CVIWS) .B 3.6.17-1 B 3.7 PLANT SYSTEMS B 3.7.1 Main Steam Safety Valves (MSSVs) .B 3.7.1-1 B 3.7.2 Main Steam Isolation Valves (MSIVs) .B 3.7.2-1 B 3.7.3 Main Feedwater Isolation Valves (MFIVs), Main Feedwater Control Valves (MFCVs), their Associated Bypass Valves, and the Tempering Valves .B 3.7.3-1 B 3.7.4 Steam Generator Power Operated Relief Valves (SG PORVs) . B 3.7.4-1 B 3.7.5 Auxiliary Feedwater (AFW) System .B 3.7.5-1 B 3.7.6 Condensate Storage System (CSS) .B 3.7.6-1 Catawba Units 1 and 2 ii Revision No.'014

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

The :ydrag " ,;t n e .io~qfdnM03 ACTIONS ElINTACT j I I ~---------

1. LCO 3.0.4 is not applicable.

2. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in Table 3.3.3-1 required channels for the channel.

inoperable.

B. One or more Functions B.1 Restore required channel 30 days with one required to OPERABLE status.

channel inoperable.

C. One or more Functions C.1 Restore required channel 30 days with one required to OPERABLE status.

channel inoperable.

AND Diverse channel OPERABLE.

(continued)

Catawba Units 1 and 2 3.3.3-1 Amendment Nos. Nos

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Initiate action in Immediately associated Completion accordance with Time of Condition B or C Specification 5.6.7.

not met.

E. One or more Functions E.1 Restore required channel 7 days with one required to OPERABLE status.

channel inoperable.

OR AND E.2 Restore diverse channel to 7 days Diverse channel OPERABLE status.

inoperable.

F. NOTE F.1 Restore one channel to 7 days Noto OPERABLE status.

hyd*rogn nfneitcr

-chanels.

One or more Functions with two required channels inoperable.

4Jo4 IJc.4 t404 5tl4 G. Two hydrogen monitor G.1 Rostoro one hydrogen hours channelc inopcrbIc. monitor channel t OPERABLE ctatug.

H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition E, F AND a-not met. A C H.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Catawba Units 1 and 2 3.3.3-2 Amendment Nos. 1931 G6-

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

-NOTE-SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 NOTE This SR is only apple to Hydrogen Monito orzrfzm CIHAINNEL CABLI BRATIOFN' SR 3.3.3.3 --- ---- NOTES--

1. Neutron detectors are excluded from CHANNEL CALIBRATION.

2. CHANNEL CALIBRATION may consist of an electronic calibration of the Containment Area -

High Range Radiation Monitor, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.

Perform CHANNEL CALIBRATION. 18 months Catawba Units 1 and 2 3.3.3-3 Amendment Nos. 47a45.

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation FUNCTION REQUIRED CHANNELS . CONDITIONS

1. Reactor Coolant System (RCS) Hot Leg 2 BD.FH Temperature (Wide Range)

2. RCS Cold Leg Temperature (Wide Range) 2 B,DF,H I

3. RCS Pressure (Wide Range) 2 B,DFH

4. Reactor Vessel Water Level 2 B,DFH

5. Containment Sump Water Level (Wide Range) 2 B,D.F.H

6. Containment Pressure (Wide Range) 2 B,D.F.H

7. Containment Area Radiation (High Range) 1 B.D

8. ld"ragen Monitors B,D,CI" V

9. Pressurizer Level 2 8,DF.H

10. Steam Generator Water Level (Narrow Range) 2 per steam generator BD,FH

11. Core Exit Temperature - Quadrant I BD,FH 2 (a)

12. Core Exit Temperature - Quadrant 2

• BDFH 2 (a)

13. Core Exit Temperature - Quadrant 3 B,DF.H 2 (a)

14. Core Exit Temperature - Quadrant 4 2 (a)

B,DF.H

15. Auxiliary Feedwater Flow I per steam generator C,D,EH

16. RCS Radiation Level I BD

17. RCS Subcooling Margin Monitor 2 B.D,F.H I

18. Steam Line Pressure 2 per steam generator B.DF.H

19. Refueling Water Storage Tank Level 2 B.DF.H

20. Neutron Flux (Wide Range) 2 B,DF.H

21. Steam Generator Water Level (Wide Range) 1 per steam generator C.DEH (a) A channel consists of two core exit thermocouples (CETs).

Catawba Units I and 2 3.3.3-4 Amendment Nos. T1tt/9.

PAM Instrumentation B 3.3.3 BASES LCO (continued)

8. H4ydFeR 1.Acn Ronir6 /VO+ u)5c1 Wyrlrngn IMonitrcs are provided to detect high hydrogen concentrtion conditions that represent a potential for containment broach from a hydrogen oxplosion. This sariable is also imporant in vediing the adeglacy of mitigating actions.

M&wo channels of hydrogen monitors arc rueqired OPERABLE.

9. Pressurizer Level Pressurizer Level is used to determine whether to terminate Si, if still in progress, or to reinitiate SI if it has been stopped.

Knowledge of pressurizer water level is also used to verify the unit conditions necessary to establish natural circulation in the RCS and to verify that the unit is maintained in a safe shutdown condition.

Three channels of pressurizer level are provided. Two channels are required OPERABLE.

10. Steam Generator Water Level (Narrow Range)

SG Water Level is provided to monitor operation of decay heat removal via the SGs. The Category I indication of SG level is the narrow range level instrumentation.

SG Water Level (Narrow Range) is used to:

• identify the faulted SG following a tube rupture;

• verify that the intact SGs are an adequate heat sink for the reactor;

• determine the nature of the accident in progress (e.g., verify an SGTR); and verify unit conditions for termination of Si during secondary unit HELBs outside containment.

Four channels per SG of narrow range water level are provided.

Only two channels are required OPERABLE by the LCO.

Catawba Units 1 and 2 B 3.3.3-8 Revision No. /

PAM Instrumentation B 3.3.3 BASES APPLICABILITY (continued)

The Hydrogen Monitos 2re not required to be OPERABLE in MODE 3.

ACTIONS Note 1 has been added in the ACTIONS to exclude the MODE change restriction of LCO 3.0.4. This exception allows entry into the applicable MODE while relying on the ACTIONS even though the ACTIONS may eventually require unit shutdown. This exception is acceptable due to the passive function of the instruments, the operator's ability to respond to an accident using alternate instruments and methods, and the low probability of an event requiring these instruments. Note 2 has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. When the Required Channels in Table 3.3.3-1 are specified (e.g., on a per steam line, per loop, per SG, etc., basis), then the Condition may be entered separately for each steam line, loop, SG, etc., as appropriate. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to all PAM instrument Functions. Condition A addresses the situation when one or more required channels for one or more Functions are inoperable. The Required Action is to refer to Table 3.3.3-1 and take the appropriate Required Actions for the PAM instrumentation affected. The Completion Times are those from the referenced Conditions and Required Actions.

B.1 Condition B applies when one or more Functions have one required channel that is inoperable. Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.

Catawba Units 1 and 2 B 3.3.3-12 Revision No.1011"'

PAM Instrumentation B 3.3.3 BASES ACTIONS (continued)

F.1 Condition F applies when one or more Functions have two inoperable required channels (i.e., two channels inoperable in the same Function).

Required Action F.1 requires restoring one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all-perfornmance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

Condition F is modified by a Not@ that excludes hydrogen monitor G.1 tMo4 U54rA Condition G applies when two hydrogen monitor channcels arc inoperahle Required Action G 1 requires restoring one hydrogen monitnr rCh~nne I n 02PE9RBI E StauISWithin 72 hoisrc. Thc 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C1ampletinn Timn is rEn<:nnahle hased nn the tow probability that an l accident causing core damage would occur during this timc.

H.1 and H.2 If the Required Action and associated Completion Time of Conditions E, or Fl~o-are not met, the unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion limes are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Catawba Units 1 and 2 B 3.3.3-14 Revision Nook

PAM Instrumentation B 3.3.3 BASES

) SURVEILLANCE A Note has been added to the SR Table to clarify that SR 3.3.3.1 and REQUIREMENTS SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1.

SR 3.3.3.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an

) indication that the channels are OPERABLE.

As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.

The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3.3.3.2 Avow )6eA A.CHANNEL tealIBR-TICN is pedormed every 92 days oR rn th Hydrogen Monitor channels. CHANNEL CGALIBRATION is a conmplet chock of tho instrumont loop, including the 9Rnsor using hydrogen gas mixt'u rs to obtain calibration points at 1 volume percent (uko) and 41'"o hy-drogen. The tt .rioctha;t Mhc cha~nnl Fespends te rmeaSured rmr-mmotor "Afh th r-#-%ey- pne4 pt'g-g- , 'rl,-

f. P based on operating experience associated with these monitors.

Catawba Units 1 and 2 B 3.3.3-15 Revision No./

Hydrogen RcRoombinorc 3.6 CONTAINMENT SYSTEMS 3.6.7 NOege- e neis -g04- LJSeA i tX4 3.67 iwo hIvdroPAn rAoWm"PnIcRA A1 nrA bi PiERAB'LE.

A r"la ml 1

• _-N3*_

'CONDIRON RrIQQU!RrD AJCION COMPlET9ON liME A. One hydrogen reomblner Inoperable.

P-4 -Restore Hydrogen oombinor to OPERABLE ius.

B das I

i. Rcquired Action and B.1 Bc in MODE 3.

mmsoeatod Complotton CATAWBA UNITS 1 AND 2 Amendment Nos.21 3, Pe

Hydrogen Recombinorfi URnVEILLANCE REQUl fMCNTC SURVEILLANCE FREQUENCY SR 3.6.7.1 Perform a system functional test for each hydrogen 1A months.

recombipe 1 -

SR 3.6.7.2 Visually examine each hydrogen recombiner enclosure 48mrthst P

an6d erify thereis no evidence of a enothal conditions.

SRI 3.6-73 Perform a resistance to ground tetfoah heater -1B-oths-Catawba Units 1 and 2 Amendment Nos. 44GA-65

Hydrogen Recombinore W} 5.6-.7-B 3.6 CONTAINMENT SYSTEMS B 3.6.7 Hyod.mg Rt:.uaisz; A/0 (/se 4e BASES BACKGKGROUND The function of the hydrogen recombiners is to eliminate the potential breach of containment due to a hydrogen oxygen reaction.

Per 10 CFR 50.14, Standards for Combustible Gas Control Systems in Light--Water--Cooled Reactors' (Ref 1). and GDfC 411. 'Containment reduce.Ihe hydroan concentrntion in the containment following S-of-mn*ant aerridant (I ()CA) The reromhiners accomplish this by rpmmhininp hydrogen nd nrygan to fonrm water vapor The uapo-remains in uotainmpnt thusi eliminating any discharge to the environment The hvdrogen reaomhiners are manually initiated since flammably limits would not be reached until several days after a Design a2sis Accident (DRA)

Two I 00% capiac independent hydrogen recombiner systems are prod~ded Fs cosss ~ of controls located oi otside containment in an aroa-not exposed to the Post-Loss of Coolant Accident environment, a-power stipply and a rernmhiner Recombination is accomplished by heating a hydrogen air mirtw Ires ehoP 15 0F. The resulting water vapor and discharge gases are cooled prior to discharge from the rzcombiner.

A single recomhiner i- caable of maintaining the hydrogncoettin in containment helow the 4 0 volume percent (v9o) flammability limit. Two rernmhinprac srp provi1ded to meet the requirement for redundancy and Andepenrine-nm Fseh rmomhinar is powered from a separate Engineered Safety Feat' ires bi is. and is proxxide d with 2a sepaprate power panel! and-APPI 'CAR' E The hydrogen recomhiners providefor the capabilit' of controlling SAFETY ANALYSES the bulk hydrogen concentration in containment to loss than the lower flammable concentration of 4.0 vg0 following a DBA. This control would prevent a rnntainment Widp hydrogen hurn thus ensuoring the presseirs and temperatj ore aaasgmed in the analyses are not exceeded The limiting OBA relative to hydrogen generation is a I QCA Catawba Units 1 and 2

H4ydrogen Rccombiner-BA6ES-APPLICABLE SAFETY ANALYSES (continued)

Hydrogen may accumulate in conta-inment foilowing a LOCA as a rcsult o-o a A metal steam reaction hetween the zirconium fuel rod cladding-and the reactr mnIant

'h Radiolytic decomposition of water in tho Reactor Coolant Sy~teff (RCr.R) and the iontainment sump; cHydrogen in the RCS at the time of the I CA (i e , hydroget dissolved in the reactor coolant and hydrogen gas in the e -vapor rPac ); r-

d. Corrosion of metals exposed to containment spray and Emergenc(Y Cors Cooling Systom solution .

lo etall late the potential for hydrogen accumulation in montainmont following a LOCA, the hydrogen generation as a function of time follomdag thp inhitiatinn nf thp aCnidpnt ic raIlrmanted Conservative assUmprie!

recommended by Reforence 3 are used to maximize thc amount of hydrG9oen c.c. .. '

Based on the conssrvativ@ assumptions used to calculatc the hydrogen

.rnnn-ntratinn verSo'S time after a IOCA, the hydrogen concentration infrrn~cs at different rates depending on the region of the containment being measured. The initiation of the Air Retl lrn ,ystemand Hydrogen Skimmer System alon vith the hydrogen reombiners will mn^;t;rn the

.hyldrogen ontmtion in the primay cnntsinmont helnw flsmmshjlty The hydrogen recombiners are designed such that, with the conservatively calculated hydrogen generation rates, a singic recmbincr scahle of limiting the peak hydrogen concentration in containment to cese than 1.0 ;z (zf. 3).

Th hydrgen recombiners satisf' Criteron 3 of 10 CER 50 R .

LCO T*fV hydr-egen Fembiners must be OPERABLE T*is. *hi ccu operation of at least one hydrogen recombiner in the ovent of a worst zcaea iinAgauiIur.

actilv Catawba Units 1 and 2 Elexiszion-Wo-(L

Hydrogon Recombinorc

.,BASES-

)

LCO (continucd) flp 'tyn withmtI~t~hdoe eomie nue httcp APPLIL^BILITY In MODES; 1 and 2trwe hydton Fanbe intod from otod-tnRtrol tho hydr~nn mnnp-ntratinn within ontdainrmnt below its fiammability limit of

1. foloing H~o a LOCA, assl ming a worst case single f~LIU=r.

in MODES 3 and 4, both the hydrogen production rate and the total hydrngan prmcdirgi after P I QV.A wotild h4 IPSC: than thAt ftlu, Iated for iho fPA IOA Also, becalse of the limited time in these MODES, the 4nrhmhility nf mnrequiring itriPnt the hydrogen recombiners is low.

lhbrcfore the hydrogen recombiners rar not required in MODE 2 or A.

In MODES 5 and 6. the probabilit' and consequences of a ~OCA are low, di e to the prsr nd temperature limitationrs in thoco MODES.

T"ierfore. hydrogen grncohiesamrn nnt rnqirnd in these MOMPS.

-ACTIONS Al With one containment hydrogon rocombincr inoperablc, thc inoperablc recombiner must bo rostorod to OPERABLE status within 30 days. In

-thi~q conefion. the remaining RPERABI F: hydrogen recombinor ic

%adeqlate to pedorm the hydrogen control funmctiojn HowevrF, the overafll r~IinhilitV ak re4ij ief beaue snge failure in the- O1PERABLE recombiner could result in reduced hydrogen control capability. The 30 day CGmpletion T-imei b2aged on the availability of the ohrhdoe rcombiner the small probabilfty of a LOC occurring (that wrou ld generate an amount of hydrogen that exceeds ths flammability limit), and t-h amount of time waailable after a1 OCA (sho-ld one oc-cur) fo operator action to prevent hydrogen accmi 1ation from exceeding the Required Action A.1 has beon modified by a Note that statoc the prnvion f I-CO 3 0 4 are not applicable As a.resuft, 2a AODE chang-e is aloloed waer one recombhr is inoperable This allowance jC haceHr an tho availability of the other hydrogen recombiner, the small probability of a LOCA occurring (that would generate an amou'nt of hydrogen that Catawba Units 1 and 2 B 3.G.7-3 Re

.Hydrogen Rccombiners BASES-ACTIONS (eentinued)I aoxceeda the flammability limit), and the amoaunt of time a'iailable after sa accumulation from exceeding the flammability limit.

If the inoporable hydrogen rcoombincr(s) cannet bc re3tered to GOPERABLE status vithin thc required Complctien Timc, the plant must be brought to a MODE in which the LCO does not apply. To achicvc this status, the plant must be brought to at least MODE 3 within 6 hourS. Thc CGmpletien Time ef 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based o pean eperiPP, to reach MODE 3 from full power conditions in an orderly mannerI mandtho ut challenging plant syctemc.

SURVEILLANCE SR 3.6.7.1 ReQUIREMENTfS Performance of a system functional test for each hydrogen recombiner ens'e ores the recombiners are operational and can attain and custain the temperatu 'enecessary for hydrogen recombination In particular, this SR utmrifiocq that the rminimi tm heater sheath temperat' re increases to

- 700 0F in - 90 minutes. After reaching 7Q00F, the power is increased to maxim; lm power for approximately 2 min 'tes and to ba

-"6OkW Industry operating experience has Ghown that thcr oAa- t zsua-11 tomonnt pae th eSrveillane whnpefrmda the 18 mo~nthFs requncy Cherforo. the Freq'ency m' conch Wed to he acceptablo lrom a reliabilit; etandpeint.

This SR nurcs there are no physical problems that could affet recombiner oporation. Sinco the recombinor; arc mcchanieally passive, they arc not Subjct to mcehanieal failur. Tha only xrdihlp ffilurur involves hose wirinog ?r ststuinal nnetienc dtpn f trialtc.

A kisual inspection iS sufficient to determine abnormral conditions that could caus0 cuch failures. The 18 month Frequency for this SR was developed considoring the incidence of hydrcgen r cm9bincrS failing the SR in the past isclw.

Catawba Units 1 and 2 -3.6.7-4 R e

I ; a Hydrogon Rocombincrs

).~'BASES-_

SURl'^ElLLANGE RElEUIREMENTS (eentinued)

SR_ _3.6.7

'his SR requ~irs porformance ofo vasistance to ground tost for. oAch hieater phase to ensure that there are no detectable grounds in any hbeter phase This SR should beoporformod following SR 3.6.7.1. This is accemplished by vcrifying that thc resist to ground for any heater phase as 2 10,000 ohms.

The 18 month Frequency for this Suivoillanco was developed-eensidering-the- inc-didence of hydrogen rocombincrs failing thc SR in4he~pst is 13w.

REFERIENGE& 1. 1rv T R .44.

o. 10 GFR 50, Appendix A, GDG 41.

3. UFSAR Soction 6.2.

.4. 10 CFR 50.36. Tochnical Specifications. (c(2)()ii.

o 7 g:

Catawba Units 1 and 2 r. Revisiqk Or

- X HSS B 3.6.8 BASES APPUCABILITY (continued)

In MODE 3 or 4, both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the DBA LOCA. Also, because of the limited time in these MODES, the probability of an accident requiring the HSS is low. Therefore, the HSS is not required in MODE 3 or 4.

In MODES 5 and 6, the probability and consequences of a LOCA or steam line break (SLB) are reduced due to the pressure and temperature limitations in these MODES. Therefore, the HSS is not required in these MODES.

ACTIONS A.1 With one HSS train inoperable, the inoperable train must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE HSS train is adequate to perform the hydrogen mixing function. However, the overall reliability is reduced because a single failure in the OPERABLE train could result in reduced hydrogen mixing capability. The 30 day Completion Time is based on the availability of the other HSS train, the small probability of a LOCA or SLB occurring (that would generate an amount of hydrogen that exceeds the flammability limit), the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit, and the availability of the bydF99911 M nw 2nd hydrogen ignitors.

r1=0mb Required Action A.1 has been modified by a Note that states the provisions of LCO 3.0.4 are not applicable. As a result, a MODE change is allowed when one HSS train is inoperable. This allowance is based on the availability of the other HSS train, the small probability of a LOCA or SLB occurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit.

B.1 If an inoperable HSS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant Catawba Units 1 and 2 B 3.6.8-3 Revision No.,'/

- -. *HIS B 3.6.9 BASES BACKGROUND (continued)

When the HIS is initiated, the ignitor elements are energized and heat up to a surface temperature 2 1700 0 F*. At this temperature, they ignite the hydrogen gas that is present in the airspace in the vicinity of the ignitor.

The HIS depends on the dispersed location of the ignitors so that local pockets of hydrogen at increased concentrations would bum before reaching a hydrogen concentration significantly higher than the lower flammability limit. Hydrogen ignition in the vicinity of the ignitors is assumed to occur when the local hydrogen concentration reaches 8.5 volume percent (v/o) and results in 100% of the hydrogen present being consumed.

APPLICABLE The HIS causes hydrogen in containment to burn in a controlled SAFETY ANALYSES manner as it accumulates following a degraded core accident (Ref. 3).

Burning occurs at the lower flammability concentration, where the resulting temperatures and pressures are relatively benign. Without the system, hydrogen could build up to higher concentrations that could result in a violent reaction if ignited by a random ignition source after such a buildup.

The hydrogen ignitors are not included for mitigation of a Design Basis Accident (DBA) because an amount of hydrogen equivalent to that generated from the reaction of 750/%of the fuel cladding with water is far in excess of the hydrogen calculated for the limiting DBA loss of coolant accident (LOCA). Us hydrogen concentration resulting from a D can eA

-b maintained less than the flammability limit using the hydrogen "omobinem. The hydrogen ignitors,4 eweioeF, have been shown by probabilistic risk analysis to be a significant contributor to limiting the severity of accident sequences that are commonly found to dominate risk for units with ice condenser containments. As such, the hydrogen ignitors satisfy Criterion 4 of 10 CFR 50.36 (Ref. 4).

LCO Two HIS trains must be OPERABLE with power from two independent, safety related power supplies.

For this unit, an OPERABLE HIS train consists of 34 (Unit 1) or 33* (Unit

2) of 35 ignitors energized on the train.

• During Unit 2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected ignitor replacement, each train's ignitor located beneath the reactor vessel missile shield may be inoperable without impacting the OPERABILITY of its respective train.

Catawba Units 1 and 2 B 3.6.9-2 Revision No.,>/