ML11208B449
| ML11208B449 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/21/2011 |
| From: | Morris J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MD9752, TAC MD9753 | |
| Download: ML11208B449 (17) | |
Text
Duke JAMES R.
MORRIS OhEnergy Vice President Duke Energy Corporation Catawba Nuclear Station 4800 Concord Road York, SC 29745 803-701-4251 803-701-3221 fax July 21, 2011 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Duke Energy Carolinas, LLC (Duke Energy)
Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Technical Specifications (TS) Sections:
3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation 3.5.4, Refueling Water Storage Tank (RWST) 3.6.6, Containment Spray System License Amendment Request to Delete Superseded TS Requirements Following Implementation of the Emergency Core Cooling System (ECCS) Water Management Initiative
References:
- 1. Letters from Duke Energy to NRC, License Amendment Request for Emergency Core Cooling System (ECCS) Water Management Initiative, dated September 2, 2008, June 18, 2009, July 8, 2009, August 13, 2009, September 8, 2009, November 10, 2009, and March 8, 2010
- 2. Letter from NRC to Duke Energy, Catawba Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Technical Specification Changes to Allow Manual Operation of the CSS (TAC Nos. MD9752 and MD9753), June 28, 2010
- 3. Letter from NRC to Duke Energy, Catawba Nuclear Station, Units 1 and 2, Correction Letter for License Amendment Nos. 257 and 252, Regarding Technical Specification Changes to Allow Manual Operation of the Containment Spray System (TAC Nos. MD9752 and MD9753), August 4, 2010 The Reference 1 letters 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 NRC approved this amendment request via the Reference 2 and Reference 3 letters.
The original submittal of September 2, 2008 contained the following regulatory commitment:
www.duke-energy.cor
U.S. Nuclear Regulatory Commission Page 2 July 21, 2011 "Within 180 days of the implementation of the associated modifications for the final unit, Catawba will submit a follow-up administrative license amendment request to delete the superseded TS and Bases requirements."
The ECCS Water Management modifications have now been implemented for both Catawba units. The Unit 2 modifications were implemented during the End of Cycle 17 Refueling Outage in the Fall of 2010 and the Unit 1 modifications were implemented during the End of Cycle 19 Refueling Outage in the Spring of 2011. Accordingly, per the above commitment, Duke Energy is submitting this amendment request to delete the superseded TS requirements. As indicated in the September 2, 2008 original submittal, following NRC approval of the ECCS Water Management amendment request, for ease of operator use, two complete versions of each corresponding TS Bases section were physically utilized. One version was applicable to the pre-modification plant configuration and one version was applicable to the post-modification plant configuration. This reflected the fact that the modifications were implemented on a staggered basis for each unit during refueling outages. Following implementation of the modifications on the final unit, Duke Energy simply deleted the pre-modification TS Bases sections. Therefore, it is not necessary to include any TS Bases changes in this submittal.
Since no technical changes are being proposed to the affected TS sections, this amendment request is considered administrative in nature. The Enclosure to this letter contains all of the information necessary to support this amendment request. Because this amendment request is administrative, no technical evaluation is necessary. The Attachment to this letter contains the marked-up TS pages. Reprinted TS pages will be provided to the NRC prior to issuance of the amendment.
In accordance with Duke Energy administrative procedures, this administrative amendment request has been exempted from review by the full Catawba Plant Operations Review Committee.
Pursuant to 10 CFR 50.91, a copy of this proposed amendment is being sent to the designated official of the State of South Carolina.
There are no regulatory commitments contained in this amendment request submittal.
If you have any questions or require additional information, please contact L.J. Rudy at (803) 701-3084.
Very truly yours, James R. Morris LJR/s Enclosure/Attachment
U.S. Nuclear Regulatory Commission Page 3 July 21, 2011 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.
Jame6
. Morris, Vice President Subscribed and sworn to me:
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Date Notary blic My commission expires:
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Date SEAL
U.S. Nuclear Regulatory Commission Page 4 July 21, 2011 xc (with Enclosure/Attachment):
V.M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G.A. Hutto, III Senior Resident Inspector (CNS)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.H. Thompson (addressee only)
NRC Project Manager (CNS)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-G9A 11555 Rockville Pike Rockville, MD 20852-2738 S.E. Jenkins Manager Radioactive and Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201
ENCLOSURE DESCRIPTION, PROPOSED CHANGE, REGULATORY EVALUATION, AND ENVIRONMENTAL CONSIDERATION 1
Subject:
License Amendment Request to Delete Superseded TS Requirements Following Implementation of the Emergency Core Cooling System (ECCS) Water Management Initiative
- 1.
DESCRIPTION
- 2.
PROPOSED CHANGE
- 3.
REGULATORY EVALUATION 3.1 Applicable Regulatory Requirements/Criteria 3.2 Precedent 3.3 No Significant Hazards Consideration 3.4 Conclusions
- 4.
ENVIRONMENTAL CONSIDERATION 2
- 1.
DESCRIPTION The Reference 1 letters cited in the cover letter to this amendment request submittal 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 NRC approved this amendment request via the Reference 2 and Reference 3 letters cited in the cover letter to this amendment request submittal.
The original submittal of September 2, 2008 contained the following regulatory commitment:
"Within 180 days of the implementation of the associated modifications for the final unit, Catawba will submit a follow-up administrative license amendment request to delete the superseded TS and Bases requirements."
The ECCS Water Management modifications have now been implemented for both Catawba units. The Unit 2 modifications were implemented during the End of Cycle 17 Refueling Outage in the Fall of 2010 and the Unit 1 modifications were implemented during the End of Cycle 19 Refueling Outage in the Spring of 2011. Accordingly, per the above commitment, Duke Energy is submitting this amendment request to delete the superseded TS requirements. As indicated in the September 2, 2008 original submittal, following NRC approval of the ECCS Water Management amendment request, for ease of operator use, two complete versions of each corresponding TS Bases section were physically utilized. One version was applicable to the pre-modification plant configuration and one version was applicable to the post-modification plant configuration. This reflected the fact that the modifications were implemented on a staggered basis for each unit during refueling outages. Following implementation of the modifications on the final unit, Duke Energy simply deleted the pre-modification TS Bases sections. Therefore, it is not necessary to include any TS Bases changes in this submittal.
Since no technical changes are being proposed to the affected TS sections, this amendment request submittal is considered administrative in nature.
3
- 2.
PROPOSED CHANGE TS 3.3.2 is annotated to delete Function 2 (Containment Spray) in its entirety, along with the footnote marked with an asterisk. The Containment Spray System is no longer an ESFAS actuated system following implementation of the ECCS Water Management modifications.
" TS 3.3.2, Function 7 (Automatic Switchover to Containment Sump) is annotated to reflect the post-modification Allowable Value of 91.9 inches and the post-modification Nominal Trip Setpoint of 95 inches. The footnote marked with an asterisk is also deleted.
TS 3.5.4, SR 3.5.4.2 is annotated to reflect the post-modification borated water volume of 377,537 gallons. The footnote marked with an asterisk is also deleted.
TS 3.6.6, SR 3.6.6.1 is annotated to delete reference to automatic valves in the Containment Spray System. There are no automatic valves in the system in its post-modification configuration. The footnote marked with an asterisk is also deleted.
TS 3.6.6, SR 3.6.6.3 and SR 3.6.6.4 are annotated to delete these requirements which are no longer applicable. There are no automatic valves in the system in its post-modification configuration and the pumps do not receive an automatic start signal in the post-modification configuration. The footnote marked with an asterisk is also deleted.
TS 3.6.6, SR 3.6.6.5 and SR 3.6.6.6 are annotated to reflect the fact that following implementation of the ECCS Water Management modifications, spray pump starting and spray pump discharge valve opening are manual functions.
This is accomplished by deleting the footnote marked with a double asterisk.
4
- 3.
REGULATORY EVALUATION 3.1 Applicable Regulatory Requirements/Criteria As this amendment request submittal is purely administrative in nature in that it proposes to delete superseded TS requirements, this discussion is not applicable.
3.2 Precedent There have been previous precedents for deleting superseded TS requirements at Catawba. The most recent submittal was made on September 16, 2010 and was supplemented on March 31, 2011, and proposed to delete superseded TS requirements associated with modifying the actuation logic for ESFAS Function 5.b.(5) (Turbine Trip and Feedwater Isolation, Doghouse Water Level - High High). This amendment request submittal was approved by the NRC on June 13, 2011 (Amendment Numbers 264/260 for Units 1/2, respectively).
3.3 No Significant Hazards Consideration The proposed amendment requests the removal of superseded requirements associated with the following Technical Specifications (TS):
3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation 3.5.4, Refueling Water Storage Tank (RWST) 3.6.6, Containment Spray System The requirements became superseded upon implementation of the Emergency Core Cooling System (ECCS) Water Management modifications on both Catawba units. Therefore, this amendment request is administrative in nature.
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 delete superseded TS requirements following the implementation of NRC approved modifications. As such, they do not adversely affect accident initiators or precursors nor do they 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, it can be concluded that the probability or consequences of any accident previously evaluated will not be affected.
5
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
This amendment request will not impact the accident analyses. The proposed changes delete superseded TS requirements following the implementation of NRC approved modifications. As such, they will not alter the requirements of any of the subject SSCs or their function during accident conditions. No new or different accidents will result from the proposed changes. 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 analyses.
The proposed changes are consistent with the safety analyses assumptions. In review of the discussion above, it can be concluded that these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes delete superseded TS requirements following the implementation of NRC approved modifications. As such, they do not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. The safety analyses 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 shut down the plant and to maintain the plant in a safe shutdown condition. In review of the discussion above, it can be concluded that the proposed changes will not involve a significant reduction in a margin of safety.
3.4 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
6
- 4.
ENVIRONMENTAL CONSIDERATION Duke Energy has determined that the proposed amendment does not change requirements with respect to the installation or use of a facility component located within the restricted area, as defined by 10 CFR 20. Neither does it represent a change to an inspection or surveillance requirement. Duke Energy has evaluated the proposed amendment and has determined that it does not involve: (1) a significant hazards consideration, (2) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposures. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
7
ATTACHMENT MARKED-UP TS PAGES 8
ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 1 of 5)
Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT
- 1.
Safety Injection 0()
- a.
Manual Initiation
- b.
Automatic Actuation Logic and Actuation Relays
- c.
Containment Pressure - High
- d.
Pressurizer Pressure - Low 1,2,3,4 1,2,3.4 2
2 trains B
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 NA NA NA NA 1,2,3 3
s 1.4 psig 1.2 psig Zt 1839 psig 1845 psig 4
D SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 2.
3 Containment Isolation(b)
- a.
Phase A Isolation (1) Manual Initiation (2) Automatic Actuation Logic and Actuation Relays (3) Safety Injection 1,2,3,4 1,2,3,4 2
B SR 3.3.2.8 C
SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 NA NA NA NA 2 trains Refer to Function 1 (Safety Injection) for all initiation functions and requirements.
(continued)
Thereq/rements of this Function re not applicable for ent into the applicable MODE/following implementatio' of the modifications associ ed with ECCS Water Ma agement on the respecti uniLt (a) Above the P-11 (Pressurizer Pressure) Interlock.
(b) The requirements of this Function are not applicable to Containment Purge Ventilation System and Hydrogen Purge System components, since the system containment isolation valves are sealed closed in MODES 1, 2, 3, and 4.
Catawba Units 1 and 2 3.3.2-13 Amendment Nos.
I
ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 5)
Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT
- 7. Automatic Switchover to Containment Sump
- a.
Automatic 1,2,3,4 2 trains C
SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3.2.6 n
Relays3
- b.
Refueling Water 1,2,3,4 4
N SR 3.3.2.1 46f11 Storage Tank SR 3.3.2.7(ax")
in in e
(RWST) Level -
SR 3.3.2. 9 (eX0)
Low SR 3.3.2.10 Coincident with Refer to Function I (Safety Injection) for all initiation functions and requirements.
Safety Injection
- 8. ESFAS Interlocks
- a.
Reactor Trip, P-4 1,2,3 1 per train, F
SR 3.3.2.8 NA NA 2 trains
- b.
Pressurizer 1.2,3 3
> 1944 and 1955 psig Pressure, P-11 SR 3.3.2.9
< 1966 psig
- c.
T,,
- Low Low, 1,2,3 1 per loop 0
->550oF 553OF P-12 SR 3.3.2.9
- 9. Containment Pressure Control System
- a.
Start Permissive 1,2.3,4 4 per train P
<1.0 psid 0.9 psid SR 3.3.2.7 SR 3.3.2.9
- b.
Termination 1,2,3.4 4 per train P
SR 3.3.2.1 k 0.25 psid 0.35 psld SR 3.3.2.7 SR 3.3.2.9
- 10. Nuclear Service 1,2,3,4 3 per pit 0,R SR 3.3.2.1
> El. 555.4 ft El. 557.5 ft Water Suction SR 3.3.2.9 Transfer - Low Pit SR 3.3.2.11 Level SR 3.3.2.12
( Foliowin,4 implementation of the modi cations associated with ECCS
'ater Management on the respcive unit, the Allowablý 4 alue for this Fuction shall be> 91.9 inches $nd the Nominal Trip Setpoint fo/this Function shall be 95 inchs.
/'
(a) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.
(b) The instrument channel setpolnt shall be reset to a value that Is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and the as-left tolerances are specified in the UFSAR.
Catawba Units I and 2 3.3.2-17 Amendment Nos.
RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 Verify RWST borated water temperature is > 70°F and In accordance with
< 1000 F.
the Surveillance Frequency Control Program SR 3.5.4.2 Verify RST borated water volume is>6 In accordance with gallons..
the Surveillance Frequency Control Program SR 3.5.4.3 Verify RWST boron concentration is within the limits In accordance with specified in the COLR.
the Surveillance Frequency Control Program
- Follow g implementation the modifications as ociated with ECCS W~ter Managemen on the r pective unit, the R ST borated water vol me for this SR shall e > 377,537 gall ns.
Catawba Units 1 and 2 3.5.4-2 Amendment Nos. @O D
Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One containment spray A.1 Restore containment spray 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 SR 3.6.6.1 Verify each containment spray manua ower operatedo In accordance with andutom ic* alve in the flow path that is not locked, the Surveillance sealed, or otherwise secured in position is in the correct Frequency Control position.
Program (continued)
C/atollowbg implementation of2he modifications as3ciated with ECCSlter Management ono)
I,._ the re}*pective unit, there w/llbe no automatic vt}les in the Containmeplt Spray Systi Catawba Units 1 and 2 3.6.6-1 Amendment Nos.
Containment Spray System 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.6.2 Verify each containment spray pump's developed head at In accordance with the flow test point is greater than or equal to the required the Inservice developed head.
Testing Program SR 3.6.6.3 V/erify e ch automatic cont inment spray v ve in the fo I path that is not locked, se led, or otherwis* secured in 6
Z! o*,,
' positi n, actuates toithe *orrect position 9han actual or v-*,~ ~~~im uated actuation sig Il.*
/j SR 3.6.6.4 (Verify eac containment s ~ray pump starts utomat~cly
~onan ac al or simulated ctuation signal.f the urveillan Inac rdance t
the urveillane Fr quencyC ntrol Pgram SR 3.6.6.5 Verify that each spray pump is de-energized and In accordance with prevented from starting upon receipt of a terminate signal the Surveillance and is allowed to manualIstart upon receipt of a start Frequency Control permissive from the Containment Pressure Control Program System (CPCS).
SR 3.6.6.6 Verify that each spray pump discharge valve closes or is In accordance with prevented from opening upon recWpt of a terminate the Surveillance signal and is allowed to manuall)6,/pen upon receipt of Frequency Control a start permissive from the Containment Pressure Program Control System (CPCS).
SR 3.6.6.7 Verify each spray nozzle is unobstructed.
Following activities which could result in nozzle blockage Following implementation of tt e modifications ssociated with EC S Water Manage ent on the res p~ctive unit, the requir ments of SR 3.6.3 and SR 3.6.6./4 shall no longer e
L applica,e.
Followinglmplementation o the modificatior associated with ECOS Water Man aement on the resp ctive unit, spray nImp starting an( spray pump dischj rge valve openinn are I
\\manual unctions.
Catawba Units 1 and 2 3.6.6-2 Amendment Nos. (& B