ML102660031
| ML102660031 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/16/2010 |
| From: | Morris J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML102660031 (17) | |
Text
Duke JAMES R. MORRIS kEnergy Vice President Duke Energy Corporation Catawba Nuclear Station 4800 Concord Road York, SC 29745 10 CFR 50.90 803-701-4251 803-701-3221 fax September 16, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Duke Energy Carolinas, LLC (Duke Energy)
Catawba Nuclear Station (CNS), Units 1 and 2 Renewed Facility Operating License Nos. NPF-35 and NPF-52 Docket Nos. 50-413 and 50-414 Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation" Removal of the Superceded TS and Bases Requirements In accordance with 10 CFR 50.90, Duke Energy proposes to amend Renewed Facility Operating Licenses (FOL) for Catawba Units 1 and 2. This License Amendment Request (LAR) proposes NRC approval for the removal of the superceded TS requirements.
By letter dated June 23, 2008, Duke Energy submitted a LAR to modify the subject TS and Bases to change the logic configuration of TS Table 3.3.2-1, "Engineered Safety Feature Turbine Trip and Feedwater Isolation", Function 5.b.(5), Doghouse Water Level - High High".
By letter dated April 2, 2009 the NRC provided issuance of amendments regarding the revision to change the logic configuration of the subject TS as requested by letter from the licensee dated June 23, 2008.
- Submittal of this administrative license amendment request satisfies the licensee commitment to submit an amendment for removal of the obsolete TS requirements to the NRC within one calendar year following the implementation of the associated modification for the final unit to be met.
In lieu of the standard PORC review, due to the nature of the submittal, this amendment request has received the appropriate management review and approval. provides detailed descriptions of the proposed changes, technical and regulatory evaluations, evaluation of significant hazards consideration pursuant to 10 CFR 50.92, and environmental considerations pursuant to 10 CFR 51.22.
Duke Energy requests the approval of this license amendment within one calendar year of the submittal date.
Aoo~
d co www. duke-energy, com
US Nuclear Regulatory Commission September 16, 2010 Page 2 of 4 Implementation of this proposed amendment to the CNS TS will not impact the CNS Updated Final Safety Analysis Report (UFSAR).
In accordance with 10 CFR 50.91 requirements, a copy of this proposed amendment is being provided to the designated official of the State of South Carolina.
There are no regulatory commitments contained in this submittal. Inquiries regarding this submittal should be directed to Adrienne F. Driver, Catawba Regulatory Compliance at 803-701-3445.
Sincerely, James R. Morris - Evaluation of Proposed Changes - TS and Bases Changes
References:
- 1. Letter, James R. Morris, Duke Energy to NRC, "Proposed Technical Specifications (TS) and Bases Amendment TS and Bases 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation," dated June 23, 2008.
- 2. Letter, John Stang, NRC to James R. Morris, " CATAWBA NUCLEAR STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING REVISION OF THE TECHNICAL SPECIFICATIONS (TSs) TO CHANGE THE LOGIC CONFIGURATION OF TS TABLE 3.3.2-1, "ENGINEERING SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION;" FUNCTION 5.b.(5), "TURBINE TRIP AND FEEDWATER ISOLATION, FEEDWATER ISOLATION, DOGHOUSE WATER LEVEL -HIGH HIGH (TAC NOS. MD9319 AND MD9320)," dated April 2, 2009.
US Nuclear Regulatory Commission September 16, 2010 Page 3 of 4 xc:
L. A. Reyes, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, GA 30303-1257 J. H. Thompson, Project Manager (addressee only)
U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 G. A. Hutto, NRC Senior Resident Inspector Catawba Nuclear Station S. E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201
bxc:
C. J. Thomas - EC05P K. R. Alter - ON03RC K. L. Ashe - MG01 RC R. D. Hart-CN01RC A. F. Driver - CNO1 RC L. J. Rudy-CN01RC T. K. Pasour - CNO1 RC NCMPA-1 PMPA NCEMC CNS Master File-CN04DM (File CN 801.01)
RGC Date File ELL
US Nuclear Regulatory Commission September 16, 2010 Page 4 of 4 Oath or Affirmation 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 R Mrris Vice President, CatawbEa Nucleartation Subscribed and sworn to me:
q-1i-
/,6 Date Notary Publi 01 My Commission Expires:
7-" /4--0k
/ 2-Date SEAL
ENCLOSURE I EVALUATION OF PROPOSED CHANGES
Catawba Nuclear Station Page 1 of 4 Evaluation of Proposed Changes
Subject:
License Amendment Request for Removal of the Superceded Technical Specification (TS) and Bases Requirements
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION
- 3. TECHNICAL EVALUATION
- 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions
- 5. ENVIRONMENTAL CONSIDERATIONS
- 6. REFERENCES ATTACHMENTS: TS and Bases Changes
Catawba Nuclear Station Page 2 of 4
- 1.
SUMMARY
DESCRIPTION This License Amendment Request (LAR) proposes NRC approval for the removal of the superceded Technical Specification (TS) and Bases Requirements for the associated TS 3.3.2, "Engineered Safety, Feature Actuation System (ESFAS) Instrumentation: Submittal of this LAR will satisfy NRC Commitment No. 3 documented in letter to the NRC dated June 23, 2008.
Additionally, deletion of the one-out-of-one (1/1) logic per train per doghouse will update the TS and its associated Bases requirements for Catawba Nuclear Station (CNS) Unit 1 and Unit 2 current design configuration.
- 2.
DETAILED DESCRIPTION The requested changes included in this LAR are administrative changes only and support the required commitment to the NRC to remove the obsolete TS requirements referencing the 1/1 logic per train per doghouse that is no longer relevant to the current CNS Unit 1 and Unit 2 plant designs. All instances referencing the 1/1 logic will be deleted, referencing only the current two-out-of-three (2/3) logic that is presently the current plant design. Upon completion of the modification on the final unit, Duke Energy is submitting this LAR to remove any further reference of the obsolete 1/1 logic design in the TS and Bases requirements for both units.
One additional administrative change has been incorporated within the proposed LAR, but is not associated with the deletion of the obsolete TS requirements associated with the 1/1 logic.
This TS change affects Condition J of TS 3.3.2 and is editorial only. The change has been requested to provide consistency with the standard TS format and to spatially align the Completion Time with the associated Required Action.
- 3.
TECHNICAL EVALUATION A technical evaluation is not necessary to support the submittal of this LAR. This LAR is administrative in nature only. In the absence of any technical material required to support the requested changes, Duke Energy has determined a technical review is not necessary.
- 4.
REGULATORY EVALUATION The proposed amendments request the removal of the superceded TS and Bases Requirements for the associated TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation": Deletion of the 1/1 logic per train per doghouse will update the TS and its associated Bases requirements for CNS Unit 1 and Unit 2 in accordance with the current design configuration.
4.1 Significant Hazards Consideration The proposed changes request the removal of the superceded TS and Bases Requirements for the associated TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation": Deletion of the 1/1 logic per train per doghouse will
Catawba Nuclear Station Page 3 of 4 update the TS and its associated Bases requirements for CNS Unit 1 and Unit 2 current in accordance with the design configuration.. This LAR requests administrative changes only.
Duke Energy has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configurations of the facility. The proposed changes do not alter or prevent the ability of structures, systems and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. In review of the discussion above (Section 4.1 Significant Hazards Consideration) it can be concluded the probability or consequences of any accident previously evaluated are not increased. This LAR requests administrative changes only.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No This revision will not impact the accident analysis. The proposed changes will not alter the requirements of the ESFAS or its function during accident conditions. No new or different accidents result from the changes proposed. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or any changes in methods governing normal plant operation. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analyses assumptions. In review of the discussion above (Section 4.1 Significant Hazards Consideration) it can be concluded that these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. This LAR requests administrative changes only.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by these changes. The proposed changes will not result in plant operation in a configuration outside the design basis. The proposed changes do not adversely affect systems that respond to safely shutdown the plant and to maintain the plant
Catawba Nuclear Station Page 4 of 4 in a safe shutdown condition. In review of the discussion above (Section 4.1 Significant Hazards Consideration) it can be concluded that the proposed changes do not involve a significant reduction in the margin of safety. This LAR requests administrative changes only.
4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
- 5.
Environmental Consideration The submittal of this LAR is administrative in nature only and is exempt from environmental review because this action falls within the categorical exclusion contained in 10 CFR 51.22 (c) (2), for which neither an Environmental Assessment nor an Environmental Impact Statement is required. In addition, the license amendment will not directly affect the actual operation of Catawba Nuclear Station in any way. The proposed administrative changes do not involve an increase in the amounts, or a change in the types, of any radiological effluents that may be allowed to be released off-site, and it does not involve an increase in the amounts, or change in the types, of non-radiological effluents that may be released off-site. Furthermore, there is no increase in the individual or cumulative operational radiation exposure and the proposed amendments have no environmental impact. Accordingly, pursuant to 10 CFR 51.21, 51.32, and 51.35, a finding of no significant environmental impact can be concluded.
ATTACHMENT 1 TS AND BASES CHANGES
ESFAS Instrumentation 3.3.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME J.
One channel inoperable.
J.1
NOTE The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.
Place channel in trip.
OR 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> J.2 Be in MODE 3.
________________________78 hours; K.
One Main Feedwater K.1 Place channel in trip.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Pumps trip channel inoperable.
OR K.2 Be in MODE 3.
7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> (continued)
Catawba Units 1 and 2 3.3.2-5 Amendment Nos.CE
ESFAS Instrumentation 3.3.2 L.
One channel inoperable.
- ---------NOTR)---------
('1. OnKJ applica", e to 2J k._J ic.
/
0rhe inoperable channel may be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing of.
other channels.
Place,channel in trip.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours Catawba Units 1 and 2 3.3.2-6 Amendment Nos. (a
)
ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 4 of 5)
Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS FUNCTION SURVEILLANCE REQUIREMENTS NOMINAL ALLOWABLE TRIP VALUE SETPOINT CONDITIONS (2)
SG Water Level-High High (P-14)
(3) Safety Injection (4)
Tavg-Low coincident with Reactor Trip, P-4 (5)
Doghouse WaterLevel -
High High 4 per SG D
SR 3.3.2.1 SR 3.3.2.2 SR 3-3.2.4 SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.9 SR 3.3.2.10
_< 85.6%
(Unit 1)
< 78.9%
(Unit 2) 83.9%
(Unit 1) 77.1%
(Unit 2)
Refer to Function 1 (Safety Injection) for all initiation functions and requirements. See Item 5.b.(1) for Applicable MODES.
4 J
SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.9
>5611F -
564OF Refer to Function 8.a (Reactor Trip, P-4) for all initiation functions and requirements.
1,2(e) 1 lgi 2f per~
(dogho/se) per doghouse
- 6.
- a.
Automatic Actuation Logic and Actuation Relays
- b.
SG Water Level
- Low Low
- c.
Safety Injection
- d.
- e.
Trip of all Main Feedwater Pumps
- f.
Auxiliary Feedwater Pump Train A and Train B Suction Transfer on Suction Pressure - Low L
(1 logic)
SR 3.3.2.9 SR 3.3.2.12 H
SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 D
SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 5 12 inches above 577 ft floor level 11 inches above 577 ft floor level 1,2,3 1,2,3 2 trains 4 per SG NA
> 9%
(Unit 1)
>_ 35.1%
(Unit 2)
NA 10.7%
(Unit 1) 36.8%
(Unit 2) 3500 V Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
1,2,3 3 per bus 1,2 3 per pump D
SR 3.3.2.3 SR 3.3.2.9 SR 3.3.2.1.0 K
SR 3.3.2.8 SR 3.3.2.10 M
SR 3'3.2.8 SR 3.3.2.10
Ž 3242 V NA NA 1,2,3 3 per train A) Ž_ 9.5 psig A) 10.5
. psig B) Ž 5.2 psig (Unit 1)
> 5.0 psig (Unit 2)
B) 6.2 psig (Unit 1) 6.0 psig (Unit 2)
(continued)
(e)
Except when all MFIVs, MFCVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve.
Catawba Units 1 and 2 3.3.2-15 Amendment Nos.-c
.I
NO CHANGES THIS PAGE.
ESFAS Instrumentation FOR INFORMATION ONLY BS3.3.2 I
B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)
(2)
Feedwater Isolation-Steam Generator Water Level-High High (P-14)
This signal provides protection against excessive feedwater flow. The ESFAS SG water level instruments provide input to the SG Water Level Control System. Therefore, the actuation logic must be able to withstand both an input failure to the control system (which may then require the protection function actuation) and a single failure in the other channels providing the protection function actuation.
Thus, four OPERABLE channels are required to satisfy the requirements with a two-out-of-four logic.
The setpoints are based on percent of narrow range instrument span.
(3)
Feedwater Isolation-Safety Iniection Feedwater Isolation is also initiated by all Functions that initiate SI. The Feedwater Isolation Function requirements for these Functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1.
Instead Function 1, SI, is referenced for all initiating functions and requirements. Item 5.b.(.1) is referenced for the applicable MODES.
(4)
Feedwater Isolation - RCS Ta_,- Low coincident with Reactor Trip (P-4)
This signal provides protection against excessive cooldown, which could subsequently introduce a positive reactivity excursion after a plant trip. There are four channels of RCS T,,, - Low (one per loop),
with a two-out-of-four logic required coincident with a reactor trip signal (P-4) to initiate a feedwater isolation. The P-4 interlock is discussed in Function 8.a.
(5)
Feedwater Isolation - Doghouse Water Level-High This signal initiates a Feedwater Isolation. The signal terminates forward feedwater flow in the event of a postulated pipe break in the main feedwater Catawba Units 1 and 2 B 3.3.2-20 Revision No. 8
ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) piping in the doghouses to prevent flooding safety related equipment essential to the safe shutdown of the plant. Each do house contains two trains of level intu bnain or/l 1/1 logic, thet'evel' i~nstru entation con sts of two level switches (on*
i per tar) in each of the two reactor building buiding doghuses A hi ghh-high level detected byon-uo-to-out-e switches, i neither the inboaf ord or outoad
- oghouse, will i'nitiate a dog houlse isolation.
- oa23,
- e~
~ ~ hj levelntu etto conit o
n i e -e bidon doghoses. A, high-high level detected byon-uof tw-oto
-he switches, i
n either the inboydo ubard o oubar ohouse, will initiate a doghou~se isolation.
o a/
This signal initiates Feedwater Isolation for the specific doghouse where the High-High level is detected and trips both main feedwater pumps thus causing a main turbine trip.
The Feedwater Isolation Function must be OPERABLE in MODES 1 and 2 and also in MODE 3 (except for the functions listed in Table 3.3.2-1). Feedwater Isolation is not required OPERABLE when all MFIVs, MFCVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve. In lower MODES, the MFW System is not in service and this Function is not required to be OPERABLE.
- 6.
Auxiliary Feedwater The AFW System is designed to provide a secondary side heat sink for the reactor in the event that the MFW System is not available. The system has two motor driven pumps and a turbine driven pump, making it available during normal and accident operation. The normal source of water for the AFW System is the condensate storage system (not safety related). A low suction pressure to the AFW pumps will automatically realign the pump suctions to the Nuclear Service Water System (NSWS)(safety related). The AFW System is aligned so that upon a pump start, flow is initiated to the respective SGs immediately.
- a.
Auxiliary Feedwater-Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the Catawba Units 1 and 2 B 3.3.2-21 Revision No.0
ESFAS Instrumentation B 3.3.2 BASES ACTIONS (continued)
L.
andiL.2_
Condition L applies to the Doghouse Water Level - High High.
For a 1/1 gic, the failur/of one channe in either react building doghous results in a Ios of redundan for the functih and possible feedw er isolation (d eending on the iled status of e channel). Th*
requir s the unit be p)ced in MODE within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> For a 2/3 logicA one channel is inoperable, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Therefore, failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-two configuration that satisfies redundancy requirements.
Alternatively, if the inoperable channel is not restored to OPERABLE status or placed in the tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the unit must be placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The allowed Completion Times 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. In MODE 3, this Function is no longer required OPERABLE.
For a 1/1 I gic, Required A tion L.1 is modif d by a Note that lows one channel be bypassed f up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> f r surveillance test*
provided a oth channel is OPEABLE. For a o oicRequired Action I1 is modified by a Note that allows the inoperable channel to be bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing of other channels.
M.1, M.2.1 and M.2.2 Condition M applies to the Auxiliary Feedwater Pumps Suction Transfer on Suction Pressure Low.
If one channel is inoperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to restore the channel to OPERABLE status or to place it in the tripped condition. The failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements.
Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> requires the unit to be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Catawba Units 1 and 2 B 3.3.2-38 Revision. No.(V