ML17296A208

Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-197-A, Revision 2 (CAC Nos. MF8971 & MF8972, EPID L-2016-LLA-0026)

ML17296A208
Person / Time
Site:	Catawba
Issue date:	01/04/2018
From:	Michael Mahoney Plant Licensing Branch II
To:	Simril T Duke Energy Carolinas
Mahoney M
References
CAC MF8971, CAC MF8972, EPID L-2016-LLA-0026
Download: ML17296A208 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 January 4, 2018 Mr. Tom Simril Site Vice President Catawba Nuclear Station, Units 1 and 2 Duke Energy Carolinas, LLC 4800 Concord Road York, SC 29745

SUBJECT:

CATAWBA NUCLEAR STATION, UNITS 1 AND 2- ISSUANCE OF AMENDMENTS ADOPTING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-197-A, REVISION 2 (CAC NOS. MF8971 AND MF8972; EPID L-2016-LLA-0026)

Dear Mr. Simril:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 297 to Renewed Facility Operating Licern;e No. NPF-35 and Amendment No. 293 to Renewed Facility Operating License No. NPF-52 for the Catawba Nuclear Station, Units 1 and 2, respectively.

The amendments are in response to your application dated December 15, 2016 as supplemented by letters dated June 8, 2017 and July 17, 2017.

The proposed amendments modify TS limiting condition for operation (LCO) 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and TS LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level." Condition A of TS LCO 3.9.4 applies when RHR requirements are not met and includes four Required Actions.

Required Action A.4 currently requires that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the closure of all containment penetrations providing direct access from containment atmosphere to outside atmosphere. The proposed changes revise Required Action A.4 and add new Required Actions A.5, A.6.1, and A.6.2, to clarify that the intent of the Required Actions is to establish containment closure. Each of these Required Actions will have a completion time (CT) of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Condition B of TS LCO 3.9.5 applies when no RHR loop is in operation, and includes three Required Actions.

Current Required Action 8.3 requires the closure of all containment penetrations providing direct access from containment atmosphere to outside atmosphere. The proposed changes are the same as the proposed changes to TS LCO 3.9.4, consisting of a revision to Required Action B.3 and the addition of new Required Actions 8.4, B.5.1, and B.5.2. The licensee stated that the proposed changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-197-A, Revision 2, "Require containment closure when shutdown cooling requirements are not met."

T. Simril A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

lift.ichaltney, P Ject Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414

Enclosures:

1. Amendment No. 297 to NPF-35

2. Amendment No. 293 to NPF-52

3. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA ELECTRIC MEMBERSHIP CORPORATION DOCKET NO. 50-413 CATAWBA NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 297 Renewed License No. NPF-35

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Catawba Nuclear Station, Unit 1 (the facility), Renewed Facility Operating License No. NPF-35, filed by Duke Energy Carolinas, LLC (the licensee), dated December 15, 2016, as supplemented by letters dated June 8, 2017, and July 17, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I;

8. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-35 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297 which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION

~~~fa-~

Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed License No. NPF-35 and Technical Specifications Date of Issuance: January 4, 2018

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA MUNICIPAL POWER AGENCY NO. 1 PIEDMONT MUNICIPAL POWER AGENCY DOCKET NO. 50-414 CATAWBA NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 293 Renewed License No. NPF-52

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Catawba Nuclear Station, Unit 2 (the facility), Renewed Facility Operating License No. NPF-52, filed by the Duke Energy Carolinas, LLC (the licensee), dated December 15, 2016, as supplemented by letters dated June 8, 2017, and July 17, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I;

8. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-52 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 293, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed License No. NPF-52 and Technical Specifications Date of Issuance: January 4 , 2 O 18

ATTACHMENT TO CATAWBA NUCLEAR STATION, UNITS 1 AND 2 LICENSE AMENDMENT NO. 297 RENEWED FACILITY OPERATING LICENSE NO. NPF-35 DOCKET NO. 50-413 AND LICENSE AMENDMENT NO. 293 RENEWED FACILITY OPERATING LICENSE NO. NPF-52 DOCKET NO. 50-414 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert NPF-35, page 4 NPF-35, page 4 NPF-52, page 4 NPF-52, page 4 Replace the following pages of the Appendix A Technical Specifications (TS) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert TS 3.9.4-2 TS 3.9.4-2 TS 3.9.5-2 TS 3.9.5-2

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297 which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4},

following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

(4) Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.

(5) Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Renewed License No. NPF-35 Amendment 297

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 293, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRG in writing when implementation of these activities is complete and can be verified by NRG inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4),

following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section (4) Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.

(5) Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013, as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRG approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRG approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Renewed License No. NPF-52 Amendment 293

RHR and Coolant Circulation - High Water Level 3.9.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close the containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> equipment hatch and secure with four bolts.

A.5 Close one door in each air 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> lock.

A.6.1 Close each penetration 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

OR A.6.2 Verify each penetration is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> capable of being closed on a high containment radiation signal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 1000 gpm and RCS the Surveillance temperature is~ 140°F. Frequency Control Program SR 3.9.4.2 Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Catawba Units 1 and 2 3.9.4-2 Amendment Nos. 297/293

RHR and Coolant Circulation - Low Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Initiate action to restore Immediately one RHR loop to operation.

8.3 Close the containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> equipment hatch and secure with four bolts.

B.4 Close one door in each air 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> lock.

B.5.1 Close each penetration 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

B.5.2 Verify each penetration is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> capable of being closed on a high containment radiation signal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and In accordance with the circulating reactor coolant at a flow rate of Surveillance Frequency

~ 1000 gpm and RCS temperature is,:: 140°F. Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated In accordance with the power available to the required RHR pump Surveillance Frequency that is not in operation. Control Program SR 3.9.5.3 Verify RHR loop locations susceptible to gas In accordance with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program Catawba Units 1 and 2 3.9.5-2 Amendment Nos. 297/293

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 297 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-35 AND AMENDMENT NO. 293 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-52 DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414

1.0 INTRODUCTION

By letter dated December 15, 2016, as supplemented by letters dated June 8, 2017, and July 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML16350A422, ML17159A460, and ML17198A187, respectively), Duke Energy Carolinas, LLC (Duke Energy, the licensee) submitted an application to change the Technical Specifications (TSs) for the Catawba Nuclear Station, Units 1 and 2 (Catawba). The supplements dated June 8 and July 17, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regutlatory Commision (NRC or Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on May 23, 2017 (82 FR 23618).

The proposed amendments modify TS limiting condition for operation (LCO) 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and TS LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level." Condition A of TS LCO 3.9.4 applies when RHR requirements are not met and includes four Required Actions.

Required Action A.4 currently requires that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the closure of all containment penetrations providing direct access from containment atmosphere to outside atmosphere. The proposed changes revise Required Action A.4 and add new Required Actions A.5, A.6.1, and A.6.2, to clarify that the intent of the Required Actions is to establish containment closure. Each of these Required Actions will have a completion time (CT) of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Condition B of TS LCO 3.9.5 applies when no RHR loop is in operation, and includes three Required Actions.

Current Required Action B.3 requires the closure of all containment penetrations providing direct access from containment atmosphere to outside atmosphere. The proposed changes are the same as the proposed changes to TS LCO 3.9.4, consisting of a revision to Required Action B 3 and the addition of new Required Actions B.4, B.5.1, and B.5.2. The licensee stated that the proposed changes are consistent with Technical Specifications Task Force (TSTF) Traveler Enclosure 3

TSTF-197-A, Revision 2, "Require containment closure when shutdown cooling requirements are not met" (ADAMS Accession No. ML040560357).

The amendments adopt TSTF-197-A, Revision 2, in order to bring the Catawba TSs into closer alignment with NUREG-1431, Revision 4, "Standard Technical Specifications Westinghouse Plants" (ADAMS Accession No. ML 121 OOA222), which contains the Westinghouse Owners Group (WOG) Standard Technical Specifications (STS), hereafter referred to as "WOG STS" or "STS".

2.0 REGULATORY EVALUATION

2.1 Applicable Regulations and Guidance As described in Title 10 of the Code of Federal Regulations ( 10 CFR) Section 50. 36( c )( 2)( i) states, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility."

The regulation in 10 CFR 50.36(c)(2)(i) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

The amendments adopt previously NRG-approved TSTF-197-A, Revision 2, to bring Catawba's TSs into alignment with NUREG-1431, Revision 4, which contains the STS for Westinghouse plants.

2.2 Licensee's Proposed Changes Current TS LCO 3.9.4, Condition A, "RHR loop requirements not met," Required Action A.4, states:

Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

The current CT of TS LCO 3.9.4, Condition A, Required Action A.4, is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Revised TS LCO 3.9.4, Condition A, Required Action A.4, will state:

A.4 Close the containment equipment hatch and secure with four bolts.

The following new Required Actions will be added to TS LCO 3.9.4, Condition A:

AND A.5 Close one door in each air lock.

AND A.6.1 Close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

OR A.6.2 Verify each penetration is capable of being closed on a high containment radiation signal.

The revised Required Action A.4 and new Required Actions A.5, A.6.1, and A.6.2, will each have CTs of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Current TS LCO 3.9.5, Condition 8, Required Action 8.3, states:

Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

The current CT of TS LCO 3.9.5, Condition A, Required Action 8.3, is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Revised TS LCO 3.9.5, Condition 8, "No RHR loop in operation," Required Action 8.3 will state:

8.3 Close the containment equipment hatch and secure with four bolts.

The following new Required Actions will be added to TS LCO 3.9.5, Condition 8:

AND 8.4 Close one door in each air lock.

AND 8.5.1 Close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

OR B.5.2 Verify each penetration is capable of being closed on a high containment radiation signal.

The revised Required Action 8.3 and New Required Actions 8.4, 8.5.1, and 8.5.2, will each have CTs of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3.0 TECHNICAL EVALUATION

3.1 NRC Staff's Technical Evaluation The NRC staff compared the licensee's proposed changes against NRG-approved TSTF-197-A, Revision 2, and NUREG-1431, Revision 4, which contains the WOG STS.

The licensee is not proposing to change the 4-hour CT for the revised Required Actions in TS LCO 3.9.4 and TS LCO 3.9.5, which is consistent with TSTF-197-A, Revision 2. The proposed new actions will also have 4-hour CTs.

Consistent with TSTF-197, Revision 2, and NUREG-1431, Revision 4, the proposed changes to TS LCO 3.9.4 and TS LCO 3.9.5 replace a Required Action (TS LCO 3.9.4, A.4 and TS LCO 3.9.5, 8.3) with a more specific Required Action with the addition of three new Required Actions (TS LCO 3.9.4, A.5, A.6.1, and A.6.2 and TS LCO 3.9.5, 8.4. 8.5.1, and 8.5.2). The revised and new Required Actions will provide more specific instructions for containment closure compared to the orginal TS LCO 3.9.4, Required Action A.4 and TS LCO 3.9.5, Required Action 8.3. The more specific instructions increase the assurance that the containment will be in an appropriate state and lessening the low safety value burdens on the plant, while retaining confidence that the containment will be placed in an acceptable configuration should an event occur.

3.1.1 Deviations from TSTF-197-A, Revision 2 The licensee stated that the following deviations exist between the proposed changes of the licensee's amendment requests and the NRG-approved TSTF-197-A, Revision 2.

3.1.1.1 Required Action A.4 The TSTF-197-A, Revision 2, Inserts 5 and 6 markups, read: "Close equipment hatch and secure with [four] bolts." The licensee proposes the more precise wording of "Close the containment equipment hatch and secure with four bolts" for TS LCO 3.9.4, Required Action A.4, and for TS LCO 3.9.5, Required Action 8.3.

The licensee noted that the proposed wording avoids confusion with other types of equipment hatches at Catawba (e.g., divider barrier equipment hatches utilized in the ice condenser containment). The licensee also noted the use of four bolts to secure the containment equipment hatch is consistent with current TS 3.9.3 "Containment Penetrations."

The NRC staff finds that the proposed Required Action wording for TS LCOs 3.9.4 and 3.9.5 is more precise, avoids confusion, and is consistent with the bolting requirements for other containment penetration equipment hatches as contained in TS 3.9.3. Accordingly, this deviation from TSTF-197-A, Revision 2, continues to meet 10 CFR 50.36(c)(2)(i) and is, therefore, acceptable.

3.1.1.2 Required Actions A.6.2 and 8.5.2 The TSTF-197-A, Revision 2, Inserts 5 and 6 markups, read: "Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System." The licensee proposes to use the words "Verify each penetration is capable of being closed on a high containment radiation signal" for TS LCO 3.9.4, Required Action A.6.2, and TS LCO 3.9.5, Required Action 8.5.2.

The Catawba units have a Containment Purge Ventilation System and Containment Purge Exhaust System, as described in Section 9.4.5 of Catawba's USFAR. Regarding their isolation signals, UFSAR, Section 9.4.5, states that the Containment Purge Ventilation System isolates its supply and exhaust paths from the outside atmosphere upon receipt of a high containment radiation signal and the Containment Purge Exhaust System is isolated on a high containment radiation signal during all plant Modes. Additionally, UFSAR Section 9.4.5 states that for all penetrations through the containment vessel for both systems, there are two, normally closed, isolation valves at each penetration, that provide containment isolation.

UFSAR, Section 6.2.4.1, indicates that containment ventilation isolation occurs automatically on a safety injection (SI) signal or on a high containment "air particle" and/or "radio gas" activity signal. Because the SI systems are not OPERABLE during the mode of applicability for TS 3.9.4 and TS 3.9.5 (MODE 6), the appropriate containment valve closure signal is the high gaseous radioactivity monitor signal.

The operability of the containment high gaseous radioactivity monitor is not addressed in the TSs. The term "OPERABLE" is intended to apply only to TSs. At Catawba, the containment high radiation monitor is addressed in "The Catawba Selected Licensee Commitment [SLC]

Manual," Section 16.7-10, "Radiation Monitoring for Plant Operations." Therefore, the functionality of this monitor is maintained in accordance with Catawba's SLC Manual.

Catawba's SLC Manual contains commitments to control important plant equipment and operating conditions not controlled elsewhere, and is equivalent to other utilities Technical Requirements Manual. Changes to Catawba's SLC Manual are controlled by the 10 CFR 50.59 process.

SLC 16. 7-10 includes requirements for a collection of radiation monitoring instrumentation used during plant operations, including the High Gaseous Radioactivity Monitor (EMF-39-Low Range). If the channel is nonfunctional, the SLC requires immediate verification that the containment isolation valves are maintained closed. SLC 16.7-10 7 includes testing requirements (TRs) to ensure the FUNCTIONAL status of "EMF-39-Low Range". TR 16.7-10-2 requires that a Channel Operational Test (COT) be performed every 9 months. The COT demonstrates the functional capabilities of the High Gaseous Radioactivity Monitor. The mode applicability for the SLC 16.7-10 requirements includes Mode 6, which is the applicable mode for TS 3.9.4 and TS 3.9.5.

The NRC staff has confirmed that the relevant containment isolation valve closure signal in Mode 6 is the high containment activity signal associated with the high containment radiation monitors governed by SLC 16.7-10. Therefore, the NRC staff concludes that for TS LCO 3.9.4, Required Action A.6.2 and TS LCO 3.9.5, Required Action 8.5.2, the use of the words "Verify each penetration is capable of being closed on a high containment radiation signal," in place of TSTF-197-A, Revision 2, words, "Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System," continues to meet 10 CFR 50.36(c)(2)(i) and is, therefore, acceptable.

3.2 NRC Staff Conclusion

The NRC staff has reviewed the licensee's proposed license amendment requests and finds that the proposed changes to TS LCO 3.9.4, Required Action A.4 (and new Required Actions A.5, A.6.1, and A.6.2), and TS LCO 3.9.5, Required Action 8.3 (and new Required Actions 8.4, B.5.1, and B.5.2), are consistent with TSTF-197, Revision 2 and NUREG-1431, Revision 4, and will ensure that the containment will be in the appropriate closure state should unplanned events occur.

Accordingly, the NRC staff finds that the requirements of 10 CFR 50.36(c)(2)(i) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the revised TS LCOs 3.9.4 and 3.9.5. Therefore, the NRC staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, NRC staff notified the South Carolina State official of the proposed issuance of the amendments on October 18, 2017. The State official confirmed on October 20, 2017, that the State of South Carolina had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on this finding (82 FR 23618: May 23, 2017). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: S. Darbali, NRR R. Grover, NRR D. Nold, NRR Date of issuance: January 4, 2018

T. Simril

SUBJECT:

CATAWBA NUCLEAR STATION, UNITS 1 AND 2- ISSUANCE OF AMENDMENTS ADOPTING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-197-A, REVISION 2 (CAC NOS. MF8971 AND MF8972, EPID L-2016-LLA-0026) DATED JANUARY 4, 2018 DISTRIBUTION:

PUBLIC RidsACRS MailCTR Resource RidsNrrLpl2-1 Resource LPL2-1 R/F RidsNrrDssStsb Resource RidsNrrDssSbpb Resource RidsNrrDeEicb Resource RidsNrrPMCatawba Resource RidsRgn2MailCenter Resource DNold, NRR RidsNrrLALKGoldstein Resource ADAMS A ccess1on No.: ML17296A208 *b1y memoran d um OFFICE DORL/LPL2-1 /PM DORL/LPL2-1/LA DSS/SBPB/BC* DE/El CB/BC SRohrer NAME MMahoney (KGoldstein for) RDennig MWaters DATE 11/06/2017 11/01/2017 7/27/2017 11/08/2017 OFFICE DSS/STSB/BC OGC-NLO DORL/LPL2-1/BC DORL/LPL2-1 /PM NAME VCusumano STurk MMarkley MMahoney DATE 11/30/2017 12/18/2017 1/04/2018 1/04/2018 OFFICIAL RECORD COPY