ML20059J161

Application for Amends to Licenses NPF-35 & NPF-52,removing Containment Penetration Conductor Overcurrent Protective Devices Tables from Ts,In Accordance W/Generic Ltr 91-08. Tables Being Relocated to Chapter 16 of FSAR

ML20059J161
Person / Time
Site:	Catawba
Issue date:	01/18/1994
From:	Rehn D DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059J164	List: ML20059J161 ML20059J171
References
GL-91-08, GL-91-8, NUDOCS 9401310383
Download: ML20059J161 (12)

Text

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DukeIbwer Company D L Rots Catawba hdear Generation Departroent lice 14esident 630 ConcordRoad (803)S313205 Office <

York SC29?45 (803)S31412GFax l

DUKEPOWER January 18,1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 i Proposed Technical Specifications Changes - 3 Removal of Containment Penetration Conductor Overcurrent Protective Devices

• Tables from Technical Specifications Gentlemen:

Pursuant to 10CFR50.4 and 10CFR50.90, attached are license amendment requests to Appendix A, Technical Specifications, of Facility Operating Licenses NPF-35 and NPF-52 for Catawba Nuclear Station Units 1 and 2, respectively. The requested amendments allow removal of the ,

tables of containment penetration conductor overcurrent protective devices from the Technical Specifications in accordance with the guidance contained in Generic letter 91-08, " Removal of -

Component Lists from Technical Specifications". The tables are being relocated to Chapter 16 of the Catawba Final Safety Analysis Report (Selected Licensee Commitments Manual).

Attachment I contains a background and description of the enclosed amendment request.'

Attachment 2 contains the required justification and safety evaluation. Pursuant to 10CFR50.91, Attachment 3 provides the analysis performed in accordance with the standards contained in 10CFR50.92 which concludes that the requested amendments do not involve a significant hazards consideration. Attachment 3 also contains an environmental impact analysis for the requested ,

amendments. Attachment 4 contains the marked-up Technical Specification amendment pages for Catawba. Attachment 5 contains the newly-created Selected Licensee Commitment Manual pages for Catawba. Duke Power Company'is forwarding a copy of this amendment request .

package to the appropriate South Carolina state official.- ,

Should there be any questions concerning this amendment request or should additional information be required, please call L.J. Rudy at (803) 831-3084.

O m o a a er 9401310383 94011e n yDR ADOCK 05000413 0 '

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~ January 18,1994 Very truly yours, '

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D.L. Rehn UR/s - 'i

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- Attachments ,

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I Document Control Desk Page 3 January 18,1994 ,

xc (W/ Attachments):

S.D. Ebneter, Regional Administrator Region II R.J. Freudenberger, Senior Resident Inspector R.E. Martin ONRR lleyward Shealy, Chief Bureau of Radiological Health, SC .

American Nuclear Insurers .;

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' M&M Nuclear Consultants 1 INPO Records Center -1 I

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Page 4 January 18,1994 2.

D.L. Rehn, being duly sworn, states that he is Vice President of Duke Power Company; that ,

he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the Catawba Nuclear Station License Nos. NPF-35 and NPF-52 and .

that all statements and matters set forth therein are true and correct to the best of his knowledge.

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D.L. Rehn, Vice President 1

Subscribed and sworn to before me this 18th day of January,1994.

f vau_7 07 ~ m-Ndary Public [/ ~

My commission expires:  :

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ATTACIIMENT 1 1

l BACKGROUND AND DESCRIITION OF AMENDhiENT REQUEST l 1

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Backcround On May 6,1991, the NRC issued Generic Letter 91-08. This generic letter provided guidance to utilities for preparing license amendment requests to remove component lists from plant i technical specifications. The NRC has determined.that the removal of component lists is acceptable because it does not alter existing technical specification requirements or those components to which they apply. One type of list to which the generic letter is applicable is the list of containment penetration conductor overcurrent protective devices. These devices consist of primary and backup fuses and breakers whose purpose is to preclude faults of a magnitude and duration that could comprise the integrity of electrical penetrations. Catawba Technical ,

Specification 3/4.8.4 and associated bases, " Electrical Equipment Protective Devices" is the governing specification for the containment penetration conductor overcurrent protective devices.

Tables 3.8-1 A and 3.8-1B are the lists of containment penetration conductor overcurrent protective devices for Units 1 and 2, respectively.

Description of Amendment Request Technical Specification 3.8.4 limiting condition for operation is modified according to the guidance contained in Generic Letter 91-08 to specify that it is applicable to all primary and backup containment penetration conductor overcurrent protective devices ,

associated with each containment electrical penetration circuit. It further excludes those l circuits for which credible fault currents would not exceed the penetration design rating.

The action statement is modified to make the scope of applicability consistent with that ,

of the limiting condition for operation. All references to Tables 3.8-1 A and 3.8-1B are deleted.  ;

l Technical Specification 4.8.4 surveillance requirement is modified to be consistent with j the above changes to the limiting condition for operation. All references to Tables 3.8- ,

1 A and 3.8-1B are deleted. In addition, the obsolete footnote pertaining to part "a" of the surveillance requirement is deleted.

Technical Specification Tables 3.8-1A and 3.8-1B are deleted.

The Technical Specification index is modified consistent with the above changes. l Technical Specification Bases section B3/4.8.4 is modified to reflect the fact that the tables of containment penetration conductor overcurrent protective devices are included in the Catawba Selected Licensee Commitment (SLC) Manual (see following Justification and Safety Evaluation section of the amendment request).

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JUSTIFICATION AND SAFETY EVALUATION h

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r e . f Justification and Safety Evaluation i Duke Power Company proposes to relocate the information that was contained in Technical j Specification Tables 3.8-1A and 3.8-1B to the Catawba Selected Licensee Commitment (SLC)

Manual. The SLC Manual is Chapter 16 of the Catawba Final Safety Analysis Report (FSAR).

Generic Ixtter 91-08 indicates that the FSAR should not be the sole means to identify l components whose lists were removed from technical specifications. However, the generic letter  !

position is based upon the fact that the FSAR is only required to be updated annually and is only required to reflect changes made six months before the date of filing the update (therefore, information in the FSAR may be as much as eighteen months out of date). In contrast, the SLC Manual is updated immediately and changes to it are controlled via the 10CFR50.59 process whenever any information in it is revised. Therefore, information in the SLC Manual always remains current. -

In addition to relocating the containment penetration conductor overcurrent protective device  ;

information to the SLC Manual, corresponding information related to these devices is also  ;

contained in existing Catawba plant procedures as follows:  ;

1) Calibration test data sheets for the protective relays on 6900 VAC switchgear primary [

breakers RCP1 A, RCP1B, RCPIC, RCP1D, RCP2A, RCP2B, RCP2C, and RCP2D are

• contained in procedure IP/0/B/4971/21, Calibration Procedure for Brown Boveri ITE 51 Relay. This crocedure verifies proper operation of these relays and satisfies technical  ;

specification surveillance requirements for the RCP containment penetration conductor overcurrent protective devices.

2) Calibration test data sheets for the protective relays on 6900 VAC switchgear backup i breakers ITA-3, ITB-3, ITC-3, ITD-3,2TA-3,2TB-3,2TC-3, and 2TD-3 are contained .

in procedure IP/0/B/4971/20, Calibration Procedure for Westinghouse CO-5 Relay. This ~

procedure verifies proper operation of these relays and satisfies technical specification -

surveillance requirements for the RCP containment penetration conductor overcurrent protective devices.

3) All other breakers with the exception of the 6900 VAC switchgear breakers noted above i are referenced in procedures IP/1&2/A/3530/03, Containment Penetration Conductor Overcurrent Protective Devices Inspection and Preventive Maintenance, for Units 1 and  ;

2, respectively. These procedures contain breaker cleaning and inspection tables which  ;

encompass all other breakers delineated in Technical Specification Tables 3.8-1 A and'  !

3.8-1 B.

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Relocating the information contained in Technical Specification Tables 3.8-1 A and 3.8-1B to the SLC Manual has no adverse impact on nuclear safety. Only the component lists themselves are being relocated; all applicable technical specification requirements pertaining to these devices will continue to apply. Any changes made to the lists once they have been incorporated into the SLC Manual will be subject to the provisions of 10CFR50.59. . In addition, because corresponding information to that contained in the component lists is also contained in existing-Catawba plant procedures as noted above, all of the change control provisions for procedures

as set forth in Technical Specification 6.8 apply as well. These provisions govern procedure - -;

review and approval, periodic review, and changes. Taken together, the control provisions governing the SLC Manual and Catawba plant procedures provide a level of control at least as stringent as that set forth in Generic Letter 91-08.

Based on the above, Duke Power Company believes that approval of the proposed amendment will not be inimical to public health and safety.

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r ATTACIIMENT 3 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION AND ENVIRONMENTAL IMPACT ANALYSIS i

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No Sienificant Hazards Consideration Determination As required by 10CFR50.91, this analysis is provided concerning whether the requested amendments involve significant hazards considerations, as defined by 10CFR50.92. Standards for determination that an amendment request involves no significant hazards considerations are if operation of the facility in accordance with the requested amendment would not: 1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2) Create the possibility of a new or different kind of accident from any accident previously -

evaluated; or 3) Involve a significant reduction in a margin of safety.

In 48FR14870, the Commission has set forth examples of amendments that are considered not likely to involve significant hazards considerations. Example (i) describes a purely administrative change to technical specifications, such as a change to achieve consistency throughout the technical specifications. In this case, the proposed amendment is similar to example (i) in that it is administrative in nature and it is intended to promote consistency throughout the technical specifications. Generic Ixtter 91-08 indicates that the intent of allowing the removal of component lists from technical specifications is consistent with previous efforts to remove other equipment lists (e.g., snubbers) from technical specifications.

Criterion 1 ,

The requested amendments will not involve a significant increase in the probability or consequences of an accident previously evaluated. Relocating the component lists of containment penetration conductor overcurrent protective devices from the technical specifications to the SLC Manual (with all attendant required technical specification changes as described previously and  !

also including removal of the above described obsolete footnote) has no impact upon either the probability or consequences of any accident. No plant equipment is affected by the proposed change. No equipment is being added or deleted from the lists; only the source document for the lists is being changed. Any future changes to the lists (i.e., changes to the plant) will be subject to the provisions of 10CFR50.59 and also subject to the change control provisions of Chapter 6 of Catawba's Technical Specifications.

l Criterion 2 The requested amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. No accident causal mechanisms are affected by the proposed change, as no change to the plant is being proposed. In addition, no change to the ,

manner in which the plant is operated is being made. Finally, no changes to plant procedures are being made which would affect any accident causal mechanisms.

Criterion 3 i The requested amendments will not involve a significant reduction in a margin of safety. The proposed change has no impact upon any safety margin. The proposed change is consistent with the guidance provided in Generic Letter 91-08 and the control provisions utilized as a result of ,

relocating the subject component lists are at least as stringent as those set forth in the generic letter.

Based upon the preceding analyses, Duke Power Company concludes that the requested

'4. e amendments do not involve a significant hazards consideration.

Environmental Impact Analysis  :

The proposed Technical Specification amendment has been reviewed against the criteria of 10CFR51.22 for environmental considerations. The proposed amendment does not involve a .

significant hazards consideration, nor increase the types and amounts of effluents that may be-  !

released offsite, nor increase individual or cumulative occupational radiation exposures.

Therefore, the proposed amendment meets the criteria given in 10CFR51.22(c)(9) for a ,

categorical exclusion from the requirement for an Environmental Impact Statement. ,

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