ML062290245

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Supplement to License Amendment Request for McGuire and Catawba Technical Specification 3.4.15, RCS Leakage Detection Instrumentation
ML062290245
Person / Time
Site: Mcguire, Catawba, McGuire  Duke Energy icon.png
Issue date: 08/08/2006
From: Jamil D
Duke Energy Carolinas, Duke Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML062290245 (10)


Text

D.M. JAMIL Duke Vice President T

MrEnergye Catawba Nuclear Station 4800 Concord Rd. / CNO1 VP York, SC 29745-9635 803 831 4251 803 831 3221 fax August 8, 2006 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555-0001

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke)

McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos.

50-413 and 50-414 Supplement to a License Amendment Request for McGuire and Catawba Technical Specification 3.4.15, RCS Leakage Detection Instrumentation.

Reference:

Letter from Duke Energy Corporation to the

NRC, Dated July 27, 2005 Letter from Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC to the NRC, dated May 4, 2006 In response to a telecon between the NRC and Duke on August 2, 2006, enclosed are revised portions of License Amendment Request (LAR) Attachments la and lb for Required Action C and Bases.

These Attachments replace the corresponding sections from the referenced May 4, 2006 LAR submittal.

The two changes from the May 4, 2006 submittal are:

1. A new Required Action C.2 is inserted to state "During Modes 2, 3,

and 4, restore inoperable containment ventilation unit condensate drain tank level monitor to OPERABLE status," with a corresponding Completion Time of 30 days. Additionally, the Required Actions for Condition C are renumbered to conform to formatting requirements.

2. A discussion of Action C.2 is included in the Bases.

www.duke-energy.com ADOI

U.S. Nuclear Regulatory Commission Page 2 August 8, 2006 The additional changes to TS 3.4.15 are described in the May 4, 2006 letter.

The May 4, 2006 submittal proposed revising the containment atmosphere particulate radioactivity monitor applicability to Mode 1 only.

This change is based on improved fuel integrity and reduced reactor coolant system (RCS) radioactivity levels that results in the radiation monitors being less effective in detecting leakage below Mode 1 conditions.

In Mode 1, water activation products build into equilibrium rapidly within the RCS, and provide a significant source term for detection of system leakage.

The previous conclusions of the No Significant Hazards Consideration and Environmental Analysis as stated in the May 4, 2006 submittal are not affected by this response.

The changes to the Updated Final Safety Analysis Report will be incorporated in the next available UFSAR update following the approval of the license amendment request. The change to the UFSAR will be made in accordance with 10CFR50.71.

Pursuant to 10 CFR 50.91, a copy of this letter is being sent to the designated official of the State of North Carolina and the designated official of the State of South Carolina.

This letter and attachments do not contain any new NRC commitments.

Inquiries on this matter should be directed to G.K.

Strickland at (803) 831-3585 or J.S. Warren at (704) 875-5171.

Very truly yours, D.M.

Jamil

U.S. Nuclear Regulatory Commission Page 3 August 8, 2006 xc (with attachment):

W.D. Travers U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, GA 30303 E.F. Guthrie Senior Resident Inspector (CNS)

U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.B. Brady Senior Resident Inspector (MNS)

U.S. Nuclear Regulatory Commission McGuire Nuclear Station J.F. Stang (addressee only)

NRC Project Manager (MNS and CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 H4A 11555 Rockville Pike Rockville, MD 20852-2738 H.J. Porter Assistant Director Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 B.O. Hall Section Chief Radiation Protection Section 1645 Main Service Center
Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission Page 4 August 8, 2006 D.M. Jamil affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

D.M. Jamil, Vice President Date Subscribed and sworn to me:

Notary Publ b/

My commission expires:

D7/ -Ate

/

SEAL

Attachment la McGuire Units 1 and 2 Proposed Technical Specifications and Bases (Mark-up)

McGuire revised TS 3.4.15 Condition C C.

Containment ventilation unit condensate drain tank level monitor inoperable.

C.1.1

-NOTE-Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation Perform SR 3.4.13.1.

OR C. 1.2 Analyze grab samples of the containment atmosphere.

OR C. 1.3 Perform SR 3.4.15.1.

AND C.2 During Modes 2, 3, and 4, restore inoperable containment ventilation unit condensate drain tank level monitor to OPERABLE status.

Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 30 days

McGuire revised Bases for TS 3.4.15 Condition C C.1.1, C.1.2, C.1.3 and C.2 With the CVUCDT level monitor inoperable, alternative action is again required. Either a water inventory balance, in accordance with SR 3.4.13.1; or grab samples obtained and analyzed at a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or SR 3.4.15.1, CHANNEL CHECK, of the containment atmosphere particulate radioactivity monitor at 8-hour intervals, must be performed to provide alternate periodic information. Required Action C.1.1 is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

Provided a water inventory balance is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or grab samples taken and analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or a CHANNEL CHECK of the containment atmosphere particulate radioactivity monitor is performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, reactor operation may continue while awaiting restoration of the CVUCDT level monitor to OPERABLE status.

The 24 and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> intervals provide periodic information that is adequate to detect RCS LEAKAGE.

During Modes 2, 3, and 4, restoration of the CVUCDT level monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the alternative actions required by Actions C.1.1, C.1.2, or C.1.3.

During Modes 2, 3, and 4, the two required leakage detection instrumentation systems are the CVUCDT level monitor and the CFAE sump level monitors. When the CVUCDT level monitor is inoperable, a plant shutdown after 30 days will ensure the plant will not operate with less than two leakage detection systems operable for an extended period of time. During Mode 1, the addition of the third leakage monitoring system from the containment atmosphere particulate radioactivity monitor provides additional leakage detection capability and no longer requires plant shutdown except as described in Condition D.

Attachment lb Catawba Units 1 and 2 Proposed Technical Specifications and Bases (Mark-up)

Catawba revised TS 3.4.15 Condition C C.

Required Containment ventilation unit condensate drain tank level monitor inoperable.

C.1.1

-NOTE -

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation Perform SR 3.4.13.1.

OR C. 1.2 Analyze grab samples of the containment atmosphere.

OR C.1.3 Perform SR 3.4.15.1.

AND C.2 During Modes 2, 3, and 4, restore inoperable containment ventilation unit condensate drain tank level monitor to OPERABLE status.

Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 30 days

Catawba revised Bases for TS 3.4.15 Condition C C.1.1, C.1.2, C.1.3, and C.2 With the CVUCDT level monitor inoperable, alternative action is again required. Either a water inventory balance, in accordance with SR 3.4.13.1; or grab samples obtained and analyzed at a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or SR 3.4.15.1, CHANNEL CHECK, of the containment atmosphere particulate radioactivity monitor at 8-hour intervals, must be performed to provide alternate periodic information. Required Action C.1.1 is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

Provided a water inventory balance is performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or grab samples taken and analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or a CHANNEL CHECK of the containment atmosphere particulate radioactivity monitor is performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, reactor operation may continue while awaiting restoration of the CVUCDT level monitor to OPERABLE status.

The 24 and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> intervals provide periodic information that is adequate to detect RCS LEAKAGE.

During Modes 2, 3, and 4, restoration of the CVUCDT level monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the alternative actions required by Actions C.1.1, C.1.2, or C.1.3.

During Modes 2, 3, and 4, the two required leakage detection instrumentation systems are the CVUCDT level monitor and the CFAE sump level monitors. When the CVUCDT level monitor is inoperable, a plant shutdown after 30 days will ensure the plant will not operate with less than two leakage detection systems operable for an extended period of time. During Mode 1, the addition of the third leakage monitoring system from the containment atmosphere particulate radioactivity monitor provides additional leakage detection capability and no longer requires plant shutdown except as described in Condition D.