ML20044C270

Discusses Relocation of Limits to Core Operating Limits Rept

ML20044C270
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	03/12/1993
From:	Martin R Office of Nuclear Reactor Regulation
To:	Tuckman M DUKE POWER CO.
References
TAC-M85472, NUDOCS 9303190367
Download: ML20044C270 (5)

Text

March 12,1993

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Docket Nos.

50-413, 50-414, 50-369, and 50-370 Mr. M. S. Tuckman Vice President, Catawba Site Duke Power Company 4800 Concord Road York, South Carolina 29745

SUBJECT:

RELOCATION OF LIMITS TO CORE OPERATING LIMITS REPORT (TAC NOS. M85472 AND M85473)

By letter dated January 13, 1993, you submitted applications to amend the Technical Specifications (TS) for the Catawba and McGuire Nuclear Stations.

The proposed amendments would relocate certain fuel cycle-specific parameter limits from the TS to the Core Operating Limits Report (COLR). The parameter limits to be relocated include overtemperature and overpower trips setpoints, several tank volumes and boron concentration limits, and reactor makeup water pump flowrate limits.

We have reviewed the application against the guidance for making such changes provided in Generic Letter 88-16, " Removal of Cycle-Specif1c Parameter Limits From Technical Specifications." As a result of our review, we find that we need additional information and clarifications as discussed in the enclosure.

Your expeditious response will facilitate our prompt review and action on your applications.

If you have any questions on these issues please feel free to contact us.

Sincerely, Rober

. Martin, Senior Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

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50-413, 50-414, 50-369, and 50-370 Mr. M. S. Tuckman Vice President, Catawba Site Duke Power Company 4800 Concord Road York, South Carolina 29745

SUBJECT:

RELOCATION OF-LIMITS TO CORE OPERATING LIMITS REPORT (TAC NOS. M85472 AND M85473)

By letter dated January 13, 1993, you submitted applications to amend the Technical Specifications (TS) for the Catawba and McGuire _ Nuclear. Stations.

The proposed amendments would relocate certain fuel cycle-specific parameter limits from the TS to the Core Operating Limits Repor_t (COLR). The parameter-limits to be relocated include overtemperature and overpower trips'setpoints, several tank volumes and boron concentration limits, and reactor makeup water pump flowrate limits.

We have reviewed the application against the guidance for making such changes provided in Generic Letter 88-16, " Removal of Cycle-Specific: Parameter Limits From Technical Specifications." As a result:of our review, we find that we-need additional information and citrifications as discussed in' the' enclosure.

Your expeditious response will facilitate our prompt review and action on_ your applications.

If you have any questions on these issues please feel _ free to contact us.

r Sincerely, Z

Rober E. Ma ti, Senior Project Manager Project Directorate 11-3 Division of Reactor Projects 3-I/II-Office of_ Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page

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I Mr. M. S. Tuckman Dake Power Company Catawba Nuclear Station cc:

Mr. R. C. Futrell Mr. Alan R. Herdt, Chief Regulatory Compliance Manager Project Branch #3 Duke Power Company U. S. Nuclear Regulatory Commission 4800 Concord Road 101 Marietta Street, NW. Suite 2900 York, South Carolina 29745 Atlanta, Georgia 30323 Mr. A. V. Carr, Esquire North Carolina Electric Membership Duke Power Company Corporation 422 South Church Street P. O. Box 27306 Charlotte, North Carolina 28242-0001 Raleigh, Porth Carolina 27611 J. Michael McGarry, III, Esquire Sen'ior Resident Inspector Winston and Strawn Route 2, Box 179 N 1400 L Street, NW York, South Carolina 29745 Washington, DC 20005 Regional Administrator, Region II North Carolina MPA-1 U. S. Nuclear Regulatory Commission Suite 600 101 Mtrietta Street, NW. Suite 2900 P. O. Box 29513 Atlanta, Georgia 30323 Raleigh, North Carolina 27626-0513 Mr. Heyward G. Shealy, Chief Mr. T. Richard Puryear Bureau of Radiological Health Nuclear Technical Services Manager South Carolina Department of Carolinas District Health and Environmental Control Westinghouse Electric Corporation 2600 Bull Street P. O. Box 32817 Columbia, South Carolina 27602 Charlotte, North Carolina 28232 Mr. G. A. Copp County Manager of York County Licensing - EC050 York County Courthouse Duke Power Company York, South Carolina 29745 P. O. Box 1006 Charlotte, North Carolina 28201-1006 Richard P. Wilson, Esquire Assistant Attorney General Saluda River Electric South Carolina Attorney General's P. O. Box 929 Office Laurens, South Carolina 29360 P. O. Box 11549 Columbia, South Mrolina 29211 Ms. Karen E. Long Assistant Attorney General Piedmont Municipal Power Agency North Carolina Department of Justice 121 Village Drive P. O. Box 629 Greer, South Carolina 29651 Raleigh, North Carlina 27602

1 i

ENCLOSURE i

i Reouest for Additional Information Apolication to Transfer TS Values to COLR for Catawba and McGuire Stations Jntroduction The Generic Letter (GL) 88-16, " Removal Of Cycle Specific Parameter Limits from Technical Specifications" provides guidan:e for the transfer of fuel cycle dependant parameter limits from the Technical Specifications (TS) to a Core Operating Limits Report (COLR). The GL notes that, generally, the methodology for determining these limits is documented in a report that has received previous NRC review and approval. Accordingly, the subsequent NRC review of proposed TS changes for those limits would be primarily limited to ensuring that the limits had been calculated using the NRC approved methodology and were otherwise consistent with all other applicable limits.

However, in the case of many of the parameters addressed in the Duke Power Company (DPC) application dated January 13, 1993, that verification is difficult to perform since the approved methodology reports address the parameters only implicitly. Therefore, to provide clarification on these items, we request that DPC provide responses to the following items.

1.

Identify the report providing the methodology for calculating the value of each of the parameters proposed to be transferred to the COLR.

If the report discusses the parameter only implicitly, provide a reference for the definition of each parameter and a specific discussion of how the parameter values are determined. These parameters should include 7, r 7,K K

K K, K, K, f (AI), f (AI), the t,

7, 7,

i 3

3 breakpointsand's'lopesfo,rf,(AI),,BASTvolume,andconcentration,RWST.

4 6

4 3

6 2

volume and concentration, reactor water makeup pump flow rate, and accumulator boron concentration.

2.

The overtemperature AT trip setpoint is understood to be defined by the equation in Note 1 of Table 2.2-1.

The identification of K, a constant 3

within that overall equation, as the "overtemperature AT reactor trip setpoint" would therefore seem to be inappropriate.

Please expand on the definition and source of the K constant.

Please comment similarly 3

on the K constant.

5 3.

As an example of the concern expressed in 1. above, it is stated in the applications Technical Specification (pages C-66 and C-67) that the calculational methodology for about 20 parameters is described in Chapter 4 of the report DPC-NE-20ll-P-A; however, this report does not explicitly discuss the majority of these parameters.

Also, it would appear that a change to the reference to DPC-NE-20ll in TS 6.9.1.9 would be appropriate to reflect its applicability to TS 2.2 methodology.

No changes to TS 6.9.1.9 were proposed in the January _13, 1993, application.

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4.

The Technical Justification discusses several checks wherein thermal l

margin calculations are performed pursuant to DPC-NE-2011.and physics i

parameter calculations pursuant to DPC-NE-3001 are performed to ensure that previously existing analysis results remain valid. The discussion i

states that, if the TS amendment transferring these values to. the COLR is approved and these checks fail but acceptable reanalysis can be performed, "...no Technical Specification change would be necessary."

-l This is confusing since, if the parameter has been relocated to the l

COLR, a change to the TS is no longer necessary to change its value.

Please clarify.

i 5.

Clarify whether the report DPC-NE-2004 is intended as s' methodology report for.the parameters to be relocated to the COLR.

If so, it should 1

also be included in a revised TS 6.9.1.9.

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6.

Please clarify the applicability of the limits on minimu-volume and boron concentration for the BAST and the RWST to providing an adequate 1 shutdown margin.

l 7.

One of the references cited in support of the reactor makeup pump i

flowrate limits has not yet been approved by NRC staff review processes.

In the event of its approval, as part of the review of the subject amendment application,.it should also be included in TS 6.9.1.9.

8.

The markup. to the FSAR, enclosed with the application, proposes to -

j replace the term f(od) with either f (od) or f (od). However, the 3

2 definition of the term remains unchanged.

Please comment on the significance of the change in terminology.

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