ML092590042

Technical Specifications (TS) And/Or Bases Sections: 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation 3.3.3, Post Accident Monitoring (Pam)

ML092590042
Person / Time
Site:	Catawba
Issue date:	09/08/2009
From:	Morris J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML092590042 (10)

Text

Duke WEnergy Carolinas JAMES R. MORRIS, VICE PRESIDENT Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road / CN01 VP York, SC 29745 803-701-4251 803-701-3221 fax September 8, 2009 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.

20555

Subject:

Duke Energy Carolinas, LLC (Duke)

Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Technical Specifications (TS) and/or Bases Sections:

3.3.2, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation 3.3.3, Post Accident Monitoring (PAM)

Instrumentation 3.5.4, Refueling Water Storage Tank (RWST) 3.6.6, Containment Spray System License Amendment Request for Emergency Core Cooling System (ECCS)

Water Management Initiative

References:

Letters from Duke to NRC, same subject, dated September 2,

2008, June 18, 2009, July 8,

2009, and

• August 13, 2009 The September 2, 2008 reference letter requested a license amendment pursuant to 10 CFR 50.90 to revise the Unit 1 and Unit 2 TS and associated Bases to allow manual operation of the Containment Spray System and to revise the upper and lower limits on the RWST.

The June 18, 2009, July 8,

2009, and August 13, 2009 reference letters responded to three sets of Requests for Additional Information (RAIs) and supplemented the September 2, 2008 original submittal.

On August 26, 2009, the NRC electronically transmitted an additional RAI.

The purpose of this letter is to formally respond to this RAI.

In addition, this letter transmits one additional proposed TS change that was inadvertently omitted from the original and followup submittals.

The attachment to this letter contains our RAI response.

The format of the response is to restate the RAI question, followed Acro I www. duke-energy. com

U.S. Nuclear Regulatory Commission Page 2 September 8, 2009 by our response.

The attachment also includes the additional proposed TS change.

There are no regulatory commitments contained in this letter or its attachment.

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

If you have any questions or require additional information, please contact L.J. Rudy at (803) 701-3084.

Very truly yours, JR orris LJR/s Attachment

U.S. Nuclear Regulatory Commission Page 3 September 8, 2009 James R. Morris 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.

James orris, Vice President Subscribed and sworn to me:

e/a

/aDate My~commission expires:

1//jol Y I

Date SEAL.

U.S. Nuclear Regulatory Commission Page 4 September 8, 2009 xc (with attachment):

L.A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85

Atlanta, GA 30303 G.A. Hutto, III Senior Resident Inspector U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.H. Thompson (addressee only)

Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 8 G9A Rockville, MD 20852-2738 S.E. Jenkins Section Manager Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

U.S. Nuclear Regulatory Commission Page 5 September 8, 2009 bxc (with attachment):

R.D.

Hart L.J. Rudy M.E.

Patrick R.L. Gill, Jr.

Document Control File 801.01 RGC Date File ELL NCMPA-I NCEMC PMPA

Attachment Response to NRC Request for Additional Information Attachment Page 1

On August 26, 2009, the NRC electronically transmitted the following RAI:

1. During the review of the Catawba ECCS Water Management

LAR, Section 3.2.3, a questi on arose as to how to verify that the thermal expansion was unrestrained for train A and B of the ECCS and that such piping was free standing.

To confirm this, the staff would like to see a clear and unequivocal statement along these lines, as well as to look (or by reference to look) at P&IDs or other such diagrams showing the piping configuration and verifying the statements above.

Duke Response:

The thermal expansion is unrestrained only in the short segment (approximately 19") of piping inboard of the steel containment vessel.

This piping has no associated pipe supports and thus thermal expansion is unrestrained and causes no significant stress in this short segment of piping.

For piping outside containment, the increased temperatures produce additional thermal expansion stresses due to the restraint of free end displacement caused by piping supports, equipment anchorage, etc.

In both regions of piping (i.e.,

inside and outside containment),

for both trains and for both units at Catawba, the piping has been analyzed and qualified for the increased temperature of 200'F in the calculations referenced below.

CNC-1206.02-82-2020, Problem NDE, Revision 39, Unit 1 CNC-2206.02-82-2007, Problem NDE, Revision 34, Unit 2 Refer to the figure on the next page for a visual description of representative piping.

In addition to the above RAI response, Duke is proposing the following additional TS change concerning Surveillance Requirement (SR) 3.6.6.1 to delete reference to automatic valves in this SR.

Similar to the change previously proposed concerning SR 3.6.6.3 in the June 18, 2009 letter, there will no longer be any automatic.valves in the Containment Spray System following the implementation of the ECCS Water Management modifications.

This change was inadvertently omitted from the original and followup submittals.

(Note also that an obsolete footnote is being deleted on this affected TS page.)

Attachment Page 2

BILL OF MATERIALS S D rb DESCRIPTION T CODE NO.

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REVISIOHE OWG.NO CN-1491-NI.00-112

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 APPLICABILITY:

Two containment spray trains shall be OPERABLEL MODES 1, 2, 3, and 4.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One containment spray A.1 Restore containment spray 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />sd train inoperable, train to OPERABLE status.

B.

Required Action and B.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 not met.

AND B.2 Be in MODE 5.

84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I

SR 3.6.6.1 Verify each containment spray manual, power operated, and automati valve in the flow path that is not locked, sealed, or otherwise secured in position is In the correct position.

31 days (continued)

Containment Spray System B 3.6.6 BASES ACTIONS A.1 With one containment spray train inoperable, the affected train must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The components in this degraded condition are capable of. providing 100% of the heat removal after an accident. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period.

B.1 and B.2 If the affected containment spray 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 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 to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an ordely manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

SURVEILLANCE REQUIREMENTS SR 3.6.6.1 Verifying the correct alignment of manualopower operated(

autor-at-ic valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it-involves verification, through a system walkdown or computer status indication, that those valves outside containment and capable of potentially being mispositioned, are in the correct position.

SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head Catawba Units 1 and 2 B 3.6.6-5 Revision No-0