ML20067C938

Application for Amends to Licenses NPF-35 & NPF-52,changing Unit 1 Condition 2.C.(12)(a) & Unit 2 Condition 2.C.(8)(a) to Allow Two Addl Fuel Cycles for Generic Resolution of Cold Leg Accumulator Instrumentation Issue

ML20067C938
Person / Time
Site:	Catawba
Issue date:	02/05/1991
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9102120257
Download: ML20067C938 (8)

Text

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% ir av hv.h., !wn th ;>t Lu el'i m J<nt l'(I lim lh  :% Iru? IIPrfuln>'n t im i-m \ (' P '-l !I" ~ (?v l!3?]3 O I DUKEPOWER February 5, 1991 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 Operating License Amendments Attached are proposed license amendments to the Catawba Nuclear Station Facility Operating Licenses for Units 1 and 2, NPF-35 and NPF-52, respectively, The attachment outlines proposed amendments to license condition 2.C.(12)(a) of operating license NPF-35 and license condition 2.C.(8)(a) of operating license NPF-52. These amendments would allow two additional fuel cycles for the generic resolution of the cold leg accumulator instrumentation issue.

Pursuant to 10 CFR 50.91 (b)(1) the appropriate South Carolina State Official is being provided a copy of this amendment request.

Very truly yours, i

M. S. Tuckman, Vice President Nuclear Operations CRL/15 Attachment gh 9102120257 910205 l 3 FDR ADOCK 05000413 J P PDR

U. S. Nuclear Regulatory. Commission February 5, 1991

, Page 2 xc: Mr. S. D. Ebneter Regional Administrator, Region 11 U. S. Nuclear kegulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Heyward Shealy, Chief Bureau of Radiological Health South Carolina Department of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201 American Nuclear Insurers c/o Dottie Sherman, ANI Library The Exchange, Suite 245 270 Farmington Avenue Farmington, CT 06032 M & M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 INP0 Records Center Suite 1500 1100 Circle 75 Parkway l Atlanta, Georgia 30339 Mr. W. T. Orders NRC Resident inspector Catawba Nuclear Station Mr. R. E. Martin Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission One White Flint Nor th, Mail Stop 9H3 Washington, D. C, 20555 l

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U. S. Nucleer Regulatory Commission February 5, 1991 Page 3 M. S. Tuckman, 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 facility Operating License, 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.

\ .b-M. S. luckman, Vice President Subscribed and sworn to before me this 5th day of February, 1991, rYb N ota/y Public ~T DR mYk My Commission Expires:

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ATTACHMENT

__ DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNITS l'AND 2 PROPOSED ICENSE AMENDMENTS TO FAr!LITY OPERATINr: LICENSES NPF-35 AND NPF-52 LICENSE CONDITIONS 2.C.(12)(a) AND 2.C.(8)(a) i

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(1) Requested Amendments l

Amend Facility Operating Lictnse NPF-35~ License Condition 2.C.(12)(a) to read: . 3 i

Prior to startup following the seventh refueling outage, Duke  !

Power Ccmpany shall provide qualified accumulator discharge instrumentation.

Amend Facility Operating License NPF-52 License Condition 2.C.(8)(a) to read:

Prior to startup.following the sixth refueling outage, Duke Power Company shall provide qualified accumulator discharge instrumentation, j (2) -Background Supplement 1 to NUREG-0737 - Requirements for Emergency Response

. Capability (Generic Letter 82-33) included additional clarification regarding Regulatory Guide 1.97, Revision 2. By letter dated

-September 26, 1983, Duke Power Company-provided the information concerning the exceptions to conformance to the regulatory guide.

~Pending completion of the-Staff's review of the Catawba design for

-conformance to-the guidance of the' regulatory guide, the' operating licenses for Catawba Unit 1 and Unit 2 were conditioned to require that modifications be completed to provide compliance with the regulatory-guide unless the-exceptions were reviewed and approved by the staff before startup following the first refueling outage, f: The itemslidentified were:

(a) Reactor coolant system cold leg water temperature (b) Containment _ sump water level

-(c) Residual heat. removal heat exchanger outlet temperature (d) Accumulator . tank. level and pressure -  !

(e) Steam generator pressure:

(f) Containment-sump water temperature

-(g) Chemical and volume control-system makeup flow and letdown flow-

-(h) . Emergency ventilation' damper-position l (i) Area radiation L (j) Plant airborne and area radiation Ms. Elinor G. Adensam's letter of August 6, 1985 transmitted a draf t Technical Evaluation Report' (TER) regarding Catawba's h conformance to Regulatory Guide 1.S7, Rev. 2. The TER also l requested aeditional justification for some of the exceptions taken by: Duke. :By letter dated October 22, 1985, Duke provided the requested information. In Supplement 5 to the Catawba Safety Evaluation-Report dated February 19B6, the Staff approved all of the exceptions 'except for accumulator level ano pressure, requiring.

that Duke designate either level or pressure as the key variable to be upgraded. -This position was incorporated into the operating l

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, license'(NPF-35) for_ Catawba Unit'i on January'17, 1987 and into

- the oper_ating-license (NPF-52) for Catawba Unit 2 on May 15,1986.

I By.-letter dated March 25,_1986, Duke requested additional technical justification from the Staff in order for-Duke to be able to evaluate the merits of the Staff's requirement. The NRC's letter

, ' dated = July 27, 1990_ responded-to-Duke's March.25, 1986 letter by

, stating that the. Staff was continuing to generically review the need for environmentally qualified Category 2 instrumentation to -

monitor accumulator -tank level and pressure. This letter also stated that no further plant specific action was required and that the NRC would inform Duke as to whether or not the existing Catawba instrumentation is acceptable when the generic review was completed.

(3)-Discussion The primary function of the accumulator pressure and level

' instrumentation is to monitor the pre-accident status of the accumulators to assure that this passive safety system is in a

' ready state to serve its safety function. The only safety function of the accumulator tank is to empty upon rapid, uncontrolled depressurization of the primary system.

Accumulator tank level and pressure are not referenced in any a emergency procedure covering-design basis events which may '

cause a harsh environment. No-operator actions in these procedures are based on accumulator indications. The only operator action involving the accumulator portion of the Safety infection System is to isolate the _ accumulator when the L primary system pressure is'below 1000 psig and primary system b conditions indicate that the accumulator inventory is not needed to makt up lost Reactor Coolant System volume. That action.is based on system pressure for which-fully qualified instruments are provided (see variable sheet A-1, from the l original- response to RG 1.97).

Cold leg . accumulator' tank pressure--is used in certain emergency procedures which deal with events beyond the design ' basis-of Catawba. These procedures are EP/1C5, Loss of Emergency, Coolant l- Recirculation, Ep/2B1, Inadequate Core Cooling, and EP/2B2', J Degraded Core Cooling. In these procedures, accumulator-pressure

.is used to determine when 'to isolate the accumulator af ter it has emptied. In an internal NRC document, H. B. Clayton to =D. L.

Ziemann, " Meeting Summary, Westinghouse Owners' Group and-Westinghouse Emergency Operating Procedures Guidelines," February 24, 1982,-the_NRC acknowledged that "for.some accident sequences, non-safety-grade. equipment =and instrumentation is needed and this is reflected in the guidelines."- The-use of cold leg accumulator pressure-is in accordance'with this philosophy.

Therefore, it is Duke's position that the accumulator tank level and pressure are not key variables for any design basis events-which result in harsh environment. Providing environmental qualification for the post accident in-containment harsh environment should not be required in that the instruments have no post-accident monitoring function.

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3 Catawba fnit I l'icense amendment numbers 15 and 55 and Onit 2

. license' amendment numbers 27 and 48 granted similar_ requests which allowed additional- time for the resolution of the accumulator instrumentation-issue. The requested extension for. Catawba Unit 1-and Unit 2'would allow additional time for the NRC Staff: to resolve =

the cold leg accumulator instrumentation issue generically. If the-Staff.'s generic review ultimately requires the upgrade of the Catawba instrumentation, it is estimated that approximately 20 months lead time would be required for implementation during a refueling outage. This is the average time for a station modificationLto go through design, procurement, scheduling, and installatione (3) Safety Analysis The primary function of the accumulator pressure and level instrumentation is to monitor the preaccident status of the accumulators to assure that the passive safety system is in a ready

-state to serve its safety _ function. Accumulator tank-level and pressure are not referenced in any emergency procedure covering design basis events which may cause a harsh environment. No operator-actions in these procedures are based on accumulator indications. It is.therefore Duke Power Company's conclusion that extension of the date'for upgrading the accumulator-pressure or level instrumentation does not involve any adverse safety

. considerations.

(4) Analysis of -Significant Hazards Consideration L As required by 10 CFR 50.91, this analysis is provided concerning

.whether the_ proposed. amendment involves significant hazards considerations, as defined by 10 CFR 50.91. Standards.for determination that a proposed amendment involves-no significant hazards considerations-are if operation of the facility in

accordance with the. proposed 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 .ignificant reduction in a margin of safety, t The proposed amen'dment would not involve a = significant increase .in the probabi_lity_of-an-accident previously evaluated because the accumulator level and pressure are provided for preaccident mon i tori ng oft h e status of the cold-leg accumulators and as-such have no effect-on cause mechanisms.

4 The proposed-amendment would not create the possibility of a new or different kind of accident than previously evaluated since the design and operation of the unit will not be'affected.

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4 The proposed amendment would not cause a significant reduction in a margin of safety. The extension of time in which to resolve the accumulator instrumentation issue would have no impact on safety margins since the instrumentation is fully qualified for its intended function of preaccident monitoring of the cold-leg accumulators.

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