ML13032A033

License Amendment Request for Technical Specification (TS) 3.6.14, Divider Barrier Integrity.

ML13032A033
Person / Time
Site:	Catawba, McGuire, Mcguire
Issue date:	01/21/2013
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13032A033 (19)

Text

Duke STEVEN D. CAPPS Vice President Ernergy McGuire Nuclear Station Duke Energy MG01 VP / 12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4805 980-875-4809 fax Steven. Capps@duke-energy.com January 21, 2013 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Document Control Desk

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 License Amendment Request for Technical Specification (TS) 3.6.14, "Divider Barrier Integrity" Pursuant to 10 CFR 50.90, Duke Energy is submitting a License Amendment Request (LAR) to Catawba Facility Operating Licenses NPF-35 and NPF-52 and to McGuire Facility Operating Licenses NPF-9 and NPF-17 and the subject TS. This proposed LAR modifies the divider barrier seal test coupons' tensile strength in TS Surveillance Requirement (TSSR) 3.6.14.4 from

"> 39.7 psi" to "> 39.7 lbs." This change is an administrative change to correct an error where the wrong units were used when Catawba and McGuire converted to Standard Technical Specifications (STS) in 1998 using NUREG-1431, Revision 1.

The enclosure provides Duke Energy's evaluation of the LAR which contains a description of the proposed TS change, the technical analysis, the regulatory evaluation, the determination that this LAR contains No Significant Hazards Considerations, and the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement. provides the current Catawba's and McGuire's TS pages, marked-up to show the proposed changes. Reprinted TS pages will be provided to the NRC upon issuance of the approved amendment. Attachment 2 provides the prior-to-STS and STS TS marked-up pages showing the error.

Duke Energy requests approval of this LAR within one year of submittal. The NRC's standard 30-day implementation grace period will be sufficient to implement this LAR. There are no regulatory commitments contained in this LAR.

In accordance with Duke Energy internal procedures and the Quality Assurance Topical Report, the proposed amendment has been reviewed and approved by the Catawba and McGuire Plant Operations Review Committees.

www. duke-energy.com

U. S. Nuclear Regulatory Commission January 21, 2013 Page 2 Pursuant to 10 CFR 50.91, a copy of this LAR has been forwarded to the appropriate North Carolina and South Carolina state officials.

Please direct any questions you may have in. this matter to P. T. Vu at (980) 875-4302.

Very truly yours, Steven D. Capps Enclosure

U. S. Nuclear Regulatory Commission January 21, 2013 Page 3 xc:

V. M. McCree Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G. A. Hutto, III NRC Senior Resident Inspector Catawba Nuclear Station J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)

NRC Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A 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 W. L. Cox, III Section Chief Division of Environmental Health, Radiation Protection Section North Carolina Department of Environmental and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

U. S. Nuclear Regulatory Commission January 21, 2013 Page 4 Steven D. Capps 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.

Steven D. Capps, President, McGuire Nuclear Station Subscribed and sworn to me: i tD e

/'In02 Date I3~M t

C, Notary Public My commission expires: (1/LA/ '

.40i'1

.,bate" U-,'J

U. S. Nuclear Regulatory Commission Enclosure January 21, 2013 Page 1 of 5 ENCLOSURE EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request to Revise Technical Specification Surveillance Requirement (TSSR) 3.6.14.4 - Divider Barrier Seal Test Coupon Tensile Strength 1.0 CHANGE DESCRIPTION

3.0 REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements/Criteria 3.2 Significant Hazards Consideration 3.3 Conclusions

4.0 ENVIRONMENTAL CONSIDERATION

5.0 PRECEDENT

6.0 REFERENCES

ATTACHMENTS:

1. Current Technical Specification Page Markups

2. Prior-to-STS and STS Technical Specification Page Markups

U. S. Nuclear Regulatory Commission Enclosure January 21, 2013 Page 2 of 5 1.0 CHANGE DESCRIPTION Pursuant to 10 CFR 50.90, Duke Energy is submitting a License Amendment Request (LAR) to Catawba Facility Operating Licenses NPF-35 and NPF-52 and to McGuire Facility Operating Licenses NPF-9 and NPF-17 and Technical Specification (TS) 3.6.14. The proposed LAR revises the Catawba and McGuire TS Surveillance Requirement (SR) 3.6.14.4, Divider Barrier Seal Test Coupon Tensile Strength, to specify that the tensile strength is 39.7 Ibs, a change from the current 39.7 psi. This change is an administrative change to correct an error where the wrong units were used when Catawba and McGuire converted to Standard Technical Specifications (STS) in 1998 using NUREG-1431, Revision 1. STS 3.6.17 was used to create TS 3.6.14.

TSSR 3.6.14.4 currently specifies:

Remove two divider barrier seal test coupons and verify both test coupons' tensile strength is > 39.7 psi.

Proposed TSSR 3.6.14.4 will specify:

Remove two divider barrier seal test coupons and verify both test coupons' tensile strength is > 39.7 lbs.

2.0 TECHNICAL EVALUATION

The divider barrier consists of the operating deck and associated seals, personnel access doors, and equipment hatches that separate the upper and lower containment compartments.

Divider barrier integrity is necessary to minimize bypassing of the ice condenser by the hot steam and air mixture released into the lower compartment during a Design Basis Accident (DBA). This ensures that most of the gases pass through the ice bed, which condenses the steam and limits pressure and temperature during the accident transient. Limiting the pressure and temperature reduces the release of fission product radioactivity from containment to the environment in the event of a DBA.

Conducting periodic physical property tests on divider barrier seal test coupons provides assurance that the seal material has not degraded in the containment environment, including the effects of irradiation with the reactor at power. The required tests include a tensile strength test every 18 months during shutdown.

STS SR 3.6.17.4 requires the removal of two divider barrier seal test coupons and verifies that both test coupons' tensile strength is > [value] psi. The value in brackets is to be replaced with a site-specific value. Catawba's and McGuire's TS related to divider barrier seal test coupon tensile strength prior to conversion to STS specified a tensile strength of > 39.7 lbs for membrane type seals MK1 0 and MKI 1. During conversion to STS in late 1998, Catawba and McGuire changed the tensile strength value in STS SR 3.6.17.4 to 39.7 psi instead of lbs.

The Catawba and McGuire divider barrier seals are manufactured by The Presray Corporation. According to Presray's technical document for recommended rubber seal replacement schedule, the tests on the membrane type coupons shall be done in

U. S. Nuclear Regulatory Commission Enclosure January 21, 2013 Page 3 of 5 accordance with ASTM D751, "Standard Test Methods for Coated Fabrics." According to this technical document, the minimum acceptable tensile strength for membrane seal type MK1 0 and MK1 1 is 39.7 lbs based on hoop stress. ASTM D751 breaking strength test, Procedure B (Cut Strip Test Method) specifies the standard size for the test coupons to be one inch wide strips therefore the allowable tensile strength is in units of lbs instead of psi.

To correct this error, Duke Energy proposes to change the tensile strength value in TSSR 3.6.14.4 to 39.7 lbs from the current 39.7 psi.

3.0 REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements/Criteria:

The divider barrier satisfies Criterion 3 of 10 CFR 50.36 in that it is a structure, system, or component that is part of the primary success path and which functions or-actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. A technical specification limiting condition for operation of a nuclear reactor must be established for the divider barrier.

3.2 Significant Hazards Consideration:

The proposed amendment corrects an error made during conversion to STS in late 1998. The tensile strength value for containment divider barrier seal specimen test stated in TSSR 3.6.14.4 is changed to 39.7 lbs from the current 39.7 psi.

Duke Energy has concluded that operation of Catawba Units 1 & 2 and McGuire Units 1 & 2, in accordance with the proposed change to the Technical Specification does not involve a significant hazards consideration. Duke Energy's conclusion is based on its evaluation, in accordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c) as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Divider barrier integrity is necessary to minimize bypassing of the ice condenser by the hot steam and air mixture released into the lower compartment during a Design Basis Accident (DBA). This ensures that most of the gases pass through the ice bed, which condenses the steam and limits pressure and temperature during the accident transient. Limiting the pressure and temperature reduces the release of fission product radioactivity from containment to the environment in the event of a DBA.

Conducting periodic physical property tests on divider barrier seal test coupons provides assurance that the seal material has not degraded in the containment environment, including the effects of irradiation with the reactor at power. The proposed change to Technical Specification Surveillance Requirement 3.6.14.4 results in the correct tensile

U. S. Nuclear Regulatory Commission Enclosure January 21, 2013 Page 4 of 5 strength units being listed in this surveillance requirement. This is considered an editorial change to the Technical Specifications.

Thus, based on the above, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a change in the operational limits or the design capabilities of the containment or containment systems. The proposed change does not change the function or operation of plant equipment or introduce any new failure mechanisms. The technical evaluation that supports this License Amendment Request included a review of the containment divider barrier seal capability -to which this change is bounded. The proposed change does not introduce any new or different types of failure mechanisms; plant equipment will continue to respond as designed and analyzed.

3. Does the proposed amendment involve a significant reduction in the margin of safety?

Response: No.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The performance of the fuel cladding, the reactor coolant system and the containment system will not be adversely impacted by the proposed change since the ability of the divider barrier to mitigate an analyzed accident has not been adversely impacted by the proposed change.

Thus, it is concluded that the proposed change does not involve a significant reduction in the margin of safety.

3.3

Conclusions:

The proposed change does not involve a change in the operational limits or the design capabilities of the divider barrier. The proposed change does not change the function or operation of plant equipment or introduce any new failure mechanisms. The integrity of the containment and containment systems does not change.

The proposed change to TSSR 3.6.14.4 will result in Catawba and McGuire having the correct tensile strength units for divider barrier seal coupon test. The proposed change does not have any adverse impact on the integrity of the divider barrier or divider barrier seals.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.

U. S. Nuclear Regulatory Commission Enclosure January 21, 2013 Page 5 of 5 Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

5.0 PRECEDENT None.

6.0 REFERENCES

1 McGuire License Amendments 184/166, Full Conversion to Standard Technical Specifications (NUREG-1431, Revision 1), September 30, 1998.

2 Catawba License Amendments 173/165, Full Conversion to Standard Technical Specifications (NUREG-1431, Revision 1), September 30, 1998.

3 ASTM D751 - 00, Standard Test Methods for Coated Fabrics.

4 Presray Corporation Technical Document dated 6/29/79, Recommended Rubber Seal Replacement Schedule for Duke Power Company (Duke Power CNM 1144.28-0016 001, Document Control Date 8/27/90).

5 Westinghouse Standard Technical Specifications (NUREG-1431, Rev. 1.0), 3.6.17 -

Divider Barrier Integrity - Ice Condenser.

ATTACHMENT 1 Current Technical Specification Page Markups

Divider Barrier Integrity 3.6.14 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.14.4 Remove two divider barrier seal test oupons and ye fy In accordance with both test coupons' tensile strength' -> 39.7j;,p'. the Surveillance Frequency Control Program SR 3.6.14.5 Visually inspect > 95% of the divider barrier seal length, In accordance with and verify: the Surveillance Frequency Control

a. Seal and seal mounting bolts are properly Program installed; and

b. Seal material shows no evidence of deterioration due to holes, ruptures, chemical attack, abrasion, radiation damage, or changes in physical appearance.

Catawba Units 1 and 2 3.6.14-3 Amendment Nos.-263;25, -

Divider Barrier Integrity 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify, by visual inspection, all personnel access doors Prior to entering and equipment hatches between upper and lower MODE 4 from containment compartments are closed. MODE 5 SR 3.6.14.2 Verify, by visual inspection, that the seals and sealing Prior to final surfaces of each personnel access door and equipment closure after each hatch have: opening

a. No detrimental misalignments; AND

b. No cracks or defects in the sealing surfaces; and --------NOTE--------

Only required for

c. No apparent deterioration of the seal material, seals made of resilient materials In accordance with the Surveillance Frequency Control Program SR 3.6.14.3 Verify, by visual inspection, each personnel access door After each opening or equipment hatch that has been opened for personnel transit entry is closed.

SR 3.6.14.4 Remove two divider barrier seal test c ons and y ify In accordance with both test coupons' tensile strength is 39.7 e . the Surveillance Frequency Control Program (continued)

McGuire Units 1 and 2 3.6.14-2 Amendment No.'262ý41

ATTACHMENT 2 Prior-to-STS and STS Technical Specification Page Markups

I OI O~f ARREER SfAL ACCVPAL PHYS1CAL PROPERTIES HMIALM TENS ILE Membrane Type Seals Mk 10 39.7 lbs d

• l...

/

CATAWBA- UNIT I 3/4 6-45 Amendment No. 148 3 ,(-3

51e c.LA460Lýeoa,7 41 6.1 CtVIDER BARRIER SEAL ACCEPTABLE PH9YSICAL PROPERTIES TENSILE STRENM~

Membrane Type Seals l4lk10 39.7 lbs Mk 11 39.7 lbs CATAWBA - UNIT 2 3/4 6-45 Amendment No. 142 C- Pq-3 9A-3

Divider Barrier Integrity 4 3a.6.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 .6 . Verify, by visual inspection, all personnel Prior to access doors and equipment hatches between entering MODE 4 upper and lower containment compartments from MODE 5 are closed.

SR 3.6.1.2 Verify, by visual inspection, that the Prior to final seals and sealing surfaces of each closure after personnel access door and equipment hatch each opening have:

AND

a. No detrimental misalignments; ---

NOTE-....

b. No cracks or defects in the sealing Only required surfaces: and for seals made of resilient

c. No apparent deterioration of the seal materials material.

10 years SR 3.6.0.3 Verify, by visual inspection, each After each personnel access door or equipment hatch opening that has been opened for personnel transit entry is closed.

SR 3.6.0.4 Remove two divider barrier seal test klB months coupons and verif30

\ 39.-(G,-7 ( ýb2!u~~

o

ýBothi stpsi .:

couons' tensile

• is strength B~oth copns longati is (continued) 3.6-60 Rev 1. 04/07/95

5ýdec 4 -C10- tze V 1")

4.1 LIMITING CONDITIONf EM~ OPE8TlOM L1W (CO IJ'der 4

APPLICABILM:

Av barr n r ,rsthw NOOES 1, 2, 3, and 4.

IlI be#44 QIWJJ

'I I ACTION:

4rrz,PA1 L ftivider barrier seal inoperable, restore the seal to OPERABLE status SURVEILLANCE RETIRaENT1

• 4z-23 The divider barrier seal shall be determined OPERABLE at .least once per 18 months b: AI 6t s~4.*'4. 4 Removing two divider barrier seal test coupons and verifyIn that

-the physical properties of the test cowapons are 9TE3wrTlFi;F1

~4 ' Visually Inspecting at least 95' of the seal's entire length and:

verify [ the seal and seal ounting bolts ar, properly installed, and (r)E vrifyc the ...s material shows no visual avidenc. of deterioration due to holes, ruptures, chemical atuck.

abrasion. radiation damge, or changes in physical appearances.

K TENSILE TYP SELSSTRERMil 10 .39.7 lbs w NK1139.7 lbs NcGUIIRE - UNIT I 314 6-30 ASaenlt No. 166

• 4e C L7(C4A 0 ~

1 3-6.-' prm n 41 3,& If,9 D IA Lý -- p--TýP.7 -I qw " I.. IIa' ')aS(IýA7=.7w, -- A

~c, 3Z.(IV9E13 to glinder barrer ?AiaW l APPLICAILUIT: NMI1S 1. 2. 3. and 4.

I 40~n Ivider barrier seal inoperable. restore the %"Il to OPERABLE tu

• 31 M The 1 I 43 r seal I be determined OPERABLE at least once per* IS months ai!

knovolm two diveider barrier sea.1 test coqoes aen agiho that

-54~~ the physical properties of the testa

.~ Visually luspectiag at luat 9% of the sal Is entire le and:

Vori YtUl=W the Seal and seal muoting bolts are properly isa~lled, and erifydn3Pt the seal materia stiown-o-visual evideem of Y)d deteiortionduetoboles: rupture, chemical attack, abrasion. radiation damage or cbanges in physical appearances.

10 39.7 lbs S11 39.7 lbs UFjdl - UIT 2 3146-30 Demnmnt No. 146 pLef~ z of 2-

Divider Barrier Integrity SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.0.1 Verify, by visual inspection, all personnel Prior to access doors and equipment hatches between entering MODE 4 upper and lower containment compartments from MOOE 5 are closed.

SR 3.6.0.2 Verify, by visual inspection, that the Prior to final seals and sealing surfaces of each closure after personnel access door and equipment hatch each opening have:

AND

a. No detrimental misalignments;

---

NOTE------

b. No cracks or defects in the sealing Only required surfaces: and for seals made of resilient

c. No apparent deterioration of the seal materials material.

10 years SR 3.6.0.3 Verify, by visual inspection, each After each personnel access door or equipment hatch opening that has been opened for personnel transit entry is closed.

SR 3.6.1.4 Remove two divider barrier seal test C-l8 months 0 coupons and verif5M 6 Ioth test coupons' tensile strength is Z! psi;-

is Both coupons' elongation (continued) 3.6-60 Rev 1, 04/07/95 me