ML20070F334

Application for Amends to Licenses NPF-35,NPF-52,NPF-9 & NPF-17,revising TS 4.6.2d,by Increasing Surveillance Interval of Containment Spray Sys Header Air or Smoke Test from Five to Ten Years

ML20070F334
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	07/13/1994
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070F337	List: ML20070F334 ML20070F343
References
NUDOCS 9407190013
Download: ML20070F334 (12)

Text

11 i l l DukeIbwer Company yS m l P0 hM Semor VicePresident Charlotte, NC28201-M Nuclear Generation

. (704)382-2200 0tnce (704)3824360 Fax

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DUKEPOWER July 13,1994 U.S. Nuclear Regulatory Commission ,

A'ITN: Document Control Desk Washington, D.C. 20555

Subject:

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 Pmposed Technical Specifications Changes Increase in Surveillance Interval of Containment Spray System Header Air or Smoke Flow Test fmm Five to Ten Years (Technical Specification 4.6.2d)

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 and also to Appendix A, Technical Specifications, of Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2, respectively. The requested amendments allow the testing interval for the air or smoke flow test through each containment spray header to be inemased from five to ten years. The proposed amendments are consistent with NRC staff recommendations and guidance contained in NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements" and Generic letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Opemtion".

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 perfonned 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. Attachments 4a and 4b contain the marked-up technical specification amendment pages for Catawba and McGuire, respectively. Duke Power Company is forwarding a copy of this amendment request package to the appropriate North Carolina and South Carolina state officials.

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9407190013 940713 PDR ADOCK 05000369 P PDR r~m ex .w yi

Document Control Desk Page 2 July 13,1994 The next scheduled containment spmy header flow test is planned for the Catawba Unit I end-of-cycle 8 refueling outage scheduled to begin on January 26,1995. Accordingly, approval of this proposed amendment is requested by November 1,1994, so that plans can be made to defer this test for an additional five years.

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

Very truly yours,

b. n M.S. Tuckman LJR/s Attachments i

Document Control Desk Page 3 July 13,1994 xc (W/ Attachments):

S.D. Ebneter, Regional Administrator Region II R.J. Freudenberger, Senior Resident Inspector Catawba Nuclear Station G.F. Maxwell, Senior Resident Inspector McGuire Nuclear Station R.E. Manin ONRR t

V. Nerses ONRR Max Batavia, Chief Bureau of RadiologicalIIcalth SC Dayne Brown, Director Division of Radiation Protection, NC American Nuclear Insurers M&M Nuclear Consultants INPO Records Center 1

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Document Control Desk Page 4 July 13,1994 M.S. Tuckman, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the pan 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 to the McGuire Nuclear Station License Nos. NPF-9 and NPF-17; and that all statements and matters set fonh therein are true and correct to the best of his knowledge.

N h. v M.S. Tuckman, Vice President i

Subscribed and sworn to before me this 13th day of July,1994.

Notar) Ppc My commission expires:

A212 2, lWVb, l

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i ATTACIIAIENT I IIACKGROUND AND DESCRIPTION OF AMENDMENT REQUEST

Itackuround The containment spray (NS) system consists of two separate trains of equal capacity with each train independently capable of meeting system requirements. Each train consists of a spray header, as well as a pump, heat exchanger, and two ring headers with nozzles, isolation valves and associated piping, instmmentation and controls. Independent electrical power supplies are provided for equipment in each containment spray train. In addition, each train is provided with electrical power from separate emergency diesel genemtors in the event of a loss of offsite electrical power. The NS system is actuated either manually from the control room or automatically by the coincidence of two out of four protection set loops monitoring pressure in the lower containment.

Each spray header is required to be subjected to an air or smoke flow test at least once every five years in order to verify that each spray nozzle is unobstructed. This test is required by Technical Specification (TS) Surveillance Requirement 4.6.2d at Catawba and McGuire.

In December 1992, the NRC issued NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements" In Section 8.1 of the NUREG, " Containment Spray System (PWR)", the NRC recommended that the surveillance interval of the air or smoke flow test should be extended to ten years.

On September 27, 1993, the NRC issued Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation" In this generic letter, the NRC transmitted guidance to assist licensees in preparing license amendment requests to implement the recommendations of NUREG-1366 as line-item technical specifications improvements.

Descr_iption of Amendment Reauest TS Surveillance Requirement 4.6.2d for Catawba and McGuire is modified to increase the surveillance interval for the air or smoke flow test from five to ten years.

No changes to the Bases section of the associated TS are required for Catawba and McGuire.

Also, for Catawba, an obsolete footnote on page 3/4 6-18 has been deleted.

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l NITA(:IIMENT 2 JUSTIFICATION AND SAFETY EVALUATION I

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Justification and Safety Evaluation The proposed ansendments are consistent with the NRC staff position set forth in NUREG-1366 and also with the guidance transmitted in Generic Ixtter 93-05. In addition, they are also  !

compatible with observed plant operating experience as it penains to the conduct of previous spray header flow tcsts at Catawba and McGuire. In no case was a spray nozzle ever found to  ;

be obstructed during perfonnance of the test required by TS 4.6.2d (both Catawba and McGuire utilize an air flow test to satisfy TS 4.6.2d). Also, both Catawba and McGuire utilize stainless steel piping in the NS system. Therefore, an event of the type described in Generic Letter 93-05 (nozzle clogging via the sodium silicate coating applied to carbon steel piping) is not possible at either Catawba or McGuire.

The proposed amendments will not be detrimental from a safety standpoint. The conclusions of NUREG-1366 and Generic Letter 93-05 are fully applicable to Catawba and McGuire.

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i ATTACIIAIENT 3 NO SIGNIFICANT IIAZARDS CONSIDERATION DETERN11 NATION AND ENVIRONAIENTAL ISIPACT ANALYSIS I i

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t No Significant llazards Consideration Determination i As required by 10CFR50.91, this analysis is provided conceming whether the requested amendments involve significant hazards considerations, as defined by 10CFR50.92. Standards for detennination 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.

The requested amendments increase the surveillance interval of the air or smoke flow test of the containment spmy nozzles from five to ten years.

In 48FR14870, the Commission has set forth examples of amendments that are considered not likely to involve significant hazards considemtions. Example vii describes a change to make a license confonn to changes in regulations, where the license change results in very minor changes to facility opemtions clearly in keeping with the regulations. The requested amendments are similar to example vii in that they result in minor changes to plant surveillance requirements and are consistent with the existing NRC position and guidance contained in NUREG-1366 and Generic Letter 93-05. While the issuance of NUREG-1366 and Generic Ixtter 93-05 does not constitute a change in existing regulations, it nevertheless establishes the NRC staff's position concerning the acceptability of increasing the subject surveillance interval. The requested amendments are consistent with the position of NUREG-1366 and with the guidance of Generic Letter 93-05.

Criterion 1 The requested amendments will not involve a significant increase in the probability or consequences of an accident previously evaluated. Increasing the surveillance interval of TS , 4.6.2d from five to ten years will have no impact upon the probability of any accident, since the NS system is not accident initiating equipment. Also, since Catawba's and McGuire's flow test histories support making the proposed change, system response following an accident will not be adversely affected. Therefore, the requested amendments will not result in increased accident consequences. Deletion of the obsolete footnote as indicated in the Catawba TS markup is purely an administrative change, and therefore will have no impact upon either the probability  ;

or consequences of any accident. j Criterion 2 The requested amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated above, the NS system is not accident  ;

initiating equipment. No new failure modes can be created from an accident standpoint. The plant will not be operated in a different manner. Deletion of the Catawba obsolete footnote has no bearing on any accident initiating mechanisms.

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Criterion 3 )

The requested amendments will not involve a significtmt reduction in a margin of safety. Plant ,

safety margins will be unaffected by the proposed changes. The NS system will still be capable j i

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I of fulfilling its required safety function, since plant operating experience supports the proposed ,

change. Finally, the proposed amendments are consistent with the NRC position and guidance i set fonh in NUREG-1366 and Generic Letter 93-05. Deletion of the Catawba obsolete footnote i will not result in any impact to plant safety margins. l Based upon the preceding analyses, Duke Power Company concludes that the requested l amendments do not involve a significant hazards considemtion. j t

Environmental Impact Analysis l 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 10CFR5.1.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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ATTACIISIENT Ja PROPOSED TECIINICAL SPECIFICATION AMENDMENTS FOR CATAWIIA i

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