ML060730363
| ML060730363 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/28/2006 |
| From: | Stang J Plant Licensing Branch III-2 |
| To: | Jamil D Duke Energy Corp |
| Stang J, NRR/DORL, 415-13456 | |
| References | |
| NUREG-0737, TAC MC8442, TAC MC8443 | |
| Download: ML060730363 (6) | |
Text
March 28, 2006 Mr. Dhiaa Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2, (CATAWBA) REVISION REQUEST TO NUREG-0737, ITEM II.F.1, FOR CONTAINMENT HYDROGEN MONITORS (TAC NOS. MC8442 AND MC8443)
Dear Mr. Jamil:
In your letter dated September 7, 2005, you requested approval from the Nuclear Regulatory Commission (NRC) to revise the time by which hydrogen monitors are required to be in service at Catawba. The guidance provided by Item II.F.1, Attachment 6, in NUREG-0737, Clarification of TMI [Three Mile Island] Action Plan Requirements, specifies that indication and recording of hydrogen concentrations in the containment building shall be functioning within 30 minutes of safety injection.
For plants operating at the time of the TMI accident, Orders were issued to licensees confirming their commitments related to the action plan requirements described in NUREG-0737, including the timing of hydrogen monitoring in Item II.F.1, Attachment 6. An example of such a Confirmatory Order is the one issued on March 18, 1983, to Duke Power Company for Oconee.
For some other plants, the NUREG-0737 items may have been included as conditions in the facility operating licenses. For the most recently licensed plants, the plant designs and operating practices related to some of the NUREG-0737 items, including the timing of hydrogen monitoring, were reviewed during the initial licensing process but specific regulatory requirements were not imposed by Order, license condition, regulation, or other mechanism such as technical specifications. Broader requirements to have the monitoring function were included in the technical specifications before their removal by license amendments. However, specific design features (e.g., the 30-minute criterion for having indication and recording of hydrogen concentration) for the most recently licensed plants may have been captured only in supporting documents such as the Updated Final Safety Analysis Report (UFSAR).
The need for and method of NRC approval for revising the timing to establish monitoring of hydrogen concentrations in containment depends on how that capability was incorporated into the licensing basis for the facility. In the case of Oconee and several other plants, the NRC issued an Order (i.e., the Order dated November 29, 1999, for Oconee) that revised that part of the 1983 Order related to hydrogen monitors. For those plants whose operating license includes a condition related to Item II.F.1, Attachment 6, a license amendment using the process described in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license or construction permit, would be the likely method for
D. Jamil seeking NRC approval. For those plants that were not subject to a post-TMI Order or condition in the operating license, the description of the hydrogen monitoring functions, including the capability of having it available within 30 minutes of safety injection, are likely described in the UFSAR or in procedures as described in the UFSAR. The appropriate change control procedure for these plants includes the process described in 10 CFR 50.59, Changes, tests and experiments. A proposed change to the hydrogen monitoring capability would also require review of emergency planning or emergency response documents using the appropriate regulatory and administrative procedures.
Given that you have not identified an issued Order or license condition that establishes the 30-minute criterion from NUREG-0737, Item II.F.1, Attachment 6, as a regulatory requirement for Catawba, the staff has determined that our review and approval of a proposed change may not be necessary. While NRC approval is required to revise requirements imposed by Order or license condition, NRC review for other plants would be required only if the change exceeds applicable thresholds in regulations such as 10 CFR 50.59 and 50.54(q). If a licensee determines that NRC approval is required under those regulations, application should be submitted in accordance with 10 CFR 50.90, 50.54(q), or other appropriate regulation.
Sincerely,
/RA/
John Stang, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414 cc: See next page
D. Jamil March 28, 2006 seeking NRC approval. For those plants that were not subject to a post-TMI Order or condition in the operating license, the description of the hydrogen monitoring functions, including the capability of having it available within 30 minutes of safety injection, are likely described in the UFSAR or in procedures as described in the UFSAR. The appropriate change control procedure for these plants includes the process described in 10 CFR 50.59, Changes, tests and experiments. A proposed change to the hydrogen monitoring capability would also require review of emergency planning or emergency response documents using the appropriate regulatory and administrative procedures.
Given that you have not identified an issued Order or license condition that establishes the 30-minute criterion from NUREG-0737, Item II.F.1, Attachment 6, as a regulatory requirement for Catawba, the staff has determined that our review and approval of a proposed change may not be necessary. While NRC approval is required to revise requirements imposed by Order or license condition, NRC review for other plants would be required only if the change exceeds applicable thresholds in regulations such as 10 CFR 50.59 and 50.54(q). If a licensee determines that NRC approval is required under those regulations, application should be submitted in accordance with 10 CFR 50.90, 50.54(q), or other appropriate regulation.
Sincerely,
/RA/
John Stang, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414 cc: See next page Distribution Public RidsAcrsAcnwMailCenter LPL2-1 r/f RidsRgn2MailCenter(MErnstes)
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- w/changes Accession Number: ML060730363 NRR-106 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/LPL2-1/BC NAME JStang:ckg MOBrien* EMarinos DATE 3/20/06 3 /21/06 3 /28/06 OFFICIAL RECORD COPY
Catawba Nuclear Station, Units 1 & 2 Page 1 of 2 cc:
Mr. Lee Keller, Manager North Carolina Electric Membership Corp.
Regulatory Compliance P.O. Box 27306 Duke Energy Corporation Raleigh, North Carolina 27611 4800 Concord Road York, South Carolina 29745 Senior Resident Inspector U.S. Nuclear Regulatory Commission Ms. Lisa F. Vaughn 4830 Concord Road Duke Energy Corporation York, South Carolina 29745 526 South Church Street P. O. Box 1006 Mr. Henry Porter, Assistant Director Mail Code = EC07H Division of Waste Management Charlotte, North Carolina 28201-1006 Bureau of Land and Waste Management Dept. of Health and Environmental Control North Carolina Municipal Power 2600 Bull Street Agency Number 1 Columbia, South Carolina 29201-1708 1427 Meadowwood Boulevard P.O. Box 29513 Mr. R.L. Gill, Jr., Manager Raleigh, North Carolina 27626 Nuclear Regulatory Issues and Industry Affairs County Manager of York County Duke Energy Corporation York County Courthouse 526 South Church Street York, South Carolina 29745 Mail Stop EC05P Charlotte, North Carolina 28202 Piedmont Municipal Power Agency 121 Village Drive Saluda River Electric Greer, South Carolina 29651 P.O. Box 929 Laurens, South Carolina 29360 Ms. Karen E. Long Assistant Attorney General Mr. Peter R. Harden, IV, Vice President North Carolina Department of Justice Customer Relations and Sales P.O. Box 629 Westinghouse Electric Company Raleigh, North Carolina 27602 6000 Fairview Road 12th Floor NCEM REP Program Manager Charlotte, North Carolina 28210 4713 Mail Service Center Raleigh, North Carolina 27699-4713 Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745
Catawba Nuclear Station, Units 1 & 2 Page 2 of 2 cc:
Division of Radiation Protection NC Dept. of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Mr. Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006