Text

Safety Evaluation Supporting Amends 122 & 116 to Licenses NPF-35 & NPF-52,respectively
	ML20071J185
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Site:	Catawba
Issue date:	07/19/1994
From:	; Office of Nuclear Reactor Regulation
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	NUDOCS 9407270221
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k UNITED STATES s

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055M001

,o SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 122 TO FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO. 116 TO FACILITY OPERATING LICENSE NPF-52 DUKE POWER COMPANY. ET AL.

CATAWBA NVCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414

1.0 INTRODUCTION

By letter dated January 25, 1993, as supplemented May 12, 1993, Duke Power Company, et al. (the licensee), submitted a request for changes to the Catawba Nuclear Station, Units 1 and 2, Technical Specifications (TS).

The requested j

changes would allow longer surveillance test intervals (STIs) and allowed i

outage times (A0Ts) for the reactor protection system (RPS or RTS, interchangeably) and engineered safety features actuation system (ESFAS) instrumentation.

2.0 EVALVATION The licensee's application is based on a series of reports submitted by the j

Westinghouse Owner's Group (WOG) and the associated NRC staff safety evaluation reports (SER) as discussed in further detail below.

The rationale for these reports, presented in the staff's SER of February 21, 1985, is summarized in this section as follows.

By letter dated February 3,1983, the WOG submitted WCAP-10271," Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System," to the NRC for review and approval.

The report proposed TS changes governing operability and surveillance testing of the RTS which Westinghouse utilities can request on a plant-specific basis and presented equipment unavailability and risk analyses to support those changes.

Also, the WOG requested that the NRC approve the WCAP as providing an acceptable methodology for evaluating and supporting TS revisions and as being generically applicable to operating plants.

In requesting these actions, the WOG noted that operating utilities are becoming increasingly aware of the impact of current test and maintenance requirements on plant operation.

Inadvertent reactor trips have occurred during surveillance testing and have resulted in unnecessary plant transients and challenges to protection systems. Additionally, there is a significant manpower commitment associated with the performance and administration of the surveillance program. Much of this manpower could be redirected to other i

matters to assure safe operation by decreasing the frequency of surveillance while still maintaining a highly reliable Reactor Trip System.

9407270221 940739 DR ADOCK 05000413 PDR

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'3.0 PRE-APPROVED REVISIONS AND ASSOCIATED CONDITIONS The WOG published results of its study and proposals for remedial actions in 1983 in the original WCAP-10271. This document was later revised several times in response to NRC's comments and the current version of WCAP-10271, Supplement 2, Revision 1, was published on May 12, 1987.

The staff reviewed all versions of WCAP-10271 including W0G's responses to staff's questions on these submittals.

During this review, the NRC staff engaged the services of Brookhaven National Laboratory (BNL) to evaluate the approach used and the analyses performed in the WOG reports.

BNL determined the adequacy of WOG's methodology to establish technical bases for unavailability data, reliability calculations, and proposed STI/A0T extensions. After the NRC staff and BNL staff had completed their review, the NRC issued the following reports:

A safety evaluation on the RTS dated February 21, 1985, A letter from H. Denton, NRC, to the WOG, dated July 24, 1985, providing marked-up TS pages and additional guidance regarding the staff's February 21, 1985, safety evaluation, A safety evaluation on the ESFAS dated February 22, 1989, and l

A supplemental SER (SSER) dated April 30, 1990.

These SERs approved various TS changes extending STIs, test and maintenance A0Ts, and bypass time for instrument channels in the RTS and the ESFAS, and to the logic cabinets for these systems.

However, the staff stipulated certain conditions that licensees must meet to include these pre-approved changes in plant-specific TS.

The pre-approved changes and associated conditions are addressed below.

3.1 Pre-Aporoved Chanaes As mentioned above, the NRC staff stipulated certain conditions to be met before the approved TS changes to RTS and ESFAS and to the logic cabinets of these systems could be made in any plant-specific TS. The pre-approved TS changes are described below and the associated conditions are described in section 3.2 of this report.

j 3.1.1 SER issued on February 21. 1985 (RTS SER) in this SER, the staff approved the following TS changes relating to RTS analog channels only.

(1)

STI for RTS analog channel operational testing may be increased from once a month to once per quarter.

(2)

The duration for which an inoperable RTS analog channel may be maintained in an untripped condition may be increased from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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, (3)

The duration for which an inoperable RTS channel may be bypassed to allow testing of another channel in the same function may be increased from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Also, the channel test may be done in the bypass mode, leaving the inoperable channel in a tripped condition.

(4)

Testing of RTS analog channels in a bypassed condition instead of a tripped condition will be allowed.

3.1.2 SER issued on February 22. 1989 (ESFAS SER)

In this SER, the staff approved the following TS changes relating to ESFAS instruments:

(1)

The STis for the analog channels may be increased from 1 month to 3 months.

(2)

The A0Ts for testing of analog channels may be increased from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for both relays and solid state systems.

(3)

The A0Ts for testing all components may be up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in solid state systems.

(4)

In relay systems, the A0T for testing of the logic trains and master relays could be increased to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and for the slave relays to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(5)

The A0Ts for maintenance on all components may be extended to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for both relays and solid state systems.

All components except the analog channels could be in the bypass mode during maintenance A0T, i

with an analog channel tripped after spending 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in the bypass mode.

(6)

Staggered testing is not required for analog channels in the ESFAS and this requirement may be removed for analog channels in RTS.

3.1.3 Supolemental SER issued on_ April 30. 1990 (SSER)

The staff's review of the proposed STI/A0T extensions for the logic cabinets and reactor trip breakers for the RTS system was based on its evaluation of Appendix 0 to the WCAP-10271, Supplement 2, Revision 1.

The RTS and ESFAS share some common instrumentation; therefore it was necessary to consider STI/A0T extensions for RTS logic cabinets.

The staff's conclusions are given below.

(1)

The A0T extensions for the RTS logic cabinets as presented in j

Appendix D are acceptable.

These are 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for testing and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for maintenance instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , respectively.

(2)

The STI/A0T extensions (covered by the ESFAS SER) for ESFAS functions associated with the Safety Injection, Steam Line Isolation, Main Feedwater Isolation, and Auxiliary Feedwater Pump Start Signals are acceptable.

. (3)

The STI/A0T extensions proposed in Appendix D are not acceptable for reactor trip breakers because the extensions would reduce availability

)

of these breakers.

3.1.4 Letter. H.R. Denton. NRC to L.D. Butterfield. WOG dated July 24. 1985 The letter referenced the NRC staff's SER of February 21, 1985, as discussed in section 3.1.1 of this report.

The letter provided pages of the Westinghouse STS marked up to provide an acceptable model for TS revisions to incorporate the changes approved by the NRC's February 21, 1985, SER.

It also included notes providing additional clarification of (1) the changes related to WCAP-10271, and (2) other corrections the staff identified.

3.2 Associated Conditions for Acoroval 3.2.1 For the RTS SER chanaes (1)

Performance of testing shall be done on a staggered basis. (This condition was later removed by the ESFAS SER.)

(2)

Procedures should be implemented to evaluate test-failures for common cause and additional testing should be performed if necessary.

(3)

Approval of channel testing (items 3.1.1.(3) and (4) above) in a bypassed condition assumes that the plant design allows such testing without lifting any leads or installing jumpers.

3.2.2 For SSER chanaes Acceptance of item 3.1.3.(1) is contingent on including a separate new action statement for modes 1 and 2 for RPS Automatic Trip and Interlock Logic Functional Units.

The model Action Statement given below is in the format of Westinghouse Standard Technical Specifications, Revision 4, Table 3.3-1.

ACTION 12 - With the number of OPERABLE Channels (analog channels and trip logic) one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.1.1, provided the other channel is OPERABLE.

3.2.3 Expeditious Review In the letters transmitting the ESFAS SER and SSER, the staff indicated that a licensee's request for the proposed changes to the plant-specific TS will be expeditiously reviewed by the staff provided, the licensee:

(1)

Confirms the applicability of the generic analyses of WCAP-10271, Supplement 2 Revision 0 and Revision 1 to its plant.

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, (2)

Confirms that any increase in instrument drift as a result of the extended STIs has been properly accounted for in setpoint calculation methodology.

(3)

Confirms that the proposed TS changes are consistent with those approved by the staff in the SERs.

4.0 EVALVATION OF PROPOSED REVISIONS The staff evaluated the licensee's proposed TS changes to verify that they are consistent with pre-approved changes and that the licensee has met all the conditions associated with those changes.

4.1 Reactor Trio System (RTS) Instrumentation 4.1.1 TS Table 3.3-1 (1)

TS Table 3.3-1. RTS Instrumentation. Note **

Proposed chanae:

Delete the RTS Table 3.3.1 notation ** which required compliance with the ESFAS specification 3.3.2 for any portion of the channel required to be operable by Specification 3.3.2.

Evaluation:

This notation required that RTS instrument channels, for Functional Units 9 (Pressurizer pressure low) and 10 (Pressurizer pressure i

high), and 12 (SG water level low-low) channels should be tested per 1

surveillance frequency and/or mode as described in Specification 3.3.2 (for ESF instrumentation channels), because these requirements were more l

restrictive.

This was to implement a condition in the RTS SER for those channels that provided input to both the RTS and the ESFAS.

Now that the previously approved relaxations for these Catawba RTS channels are being approved for the Catawba ESFAS channels this condition need not apply.

Therefore, the ** is removed.

This is acceptable.

(t)

TS Table 3.3-1. RTS Loaic Cabinets P.t.gposed Chanae:

Add new ACTION 7 as specified in the previous section 3.2.2(1), to allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable channel to operable status before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to allow bypass of a channel for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing, provided the other channel is operable.

Make this new ACTION statement applicable to Functional Units 19 (Automatic Trip and Interlock Logic), and make it applicable to Functional Unit 16 (Safety injection Input from ESF) rather than ACTION 9.

Evaluation:

The previously applicable ACTION 9 requires the plant "to be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , however, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance test provided the other channel is operable."

The new ACTION 7 allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the inoperable channel before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and allows

.... bypassing one channel up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , for surveillance testing.

The above change is acceptable because it is consistent with pre-approved change as described in sections 3.1.2 and 3.2.2 of this evaluation.

4.1.2 Surveillance Test Interval (STI) For RTS (1)

Proposed Chance and Evaluation:

TS 4.3.1.2 is modified by deletion of a footnote (*) which refers to testing required before the Unit 2 first refueling.

Since this milestone has been passed this footnote is extraneous and may be deleted.

(2)

TS 4.3.1.1. Table 4.3-1. Functional Units 2.a. 3. 5. 6. 7. 8. 9. 10.

11. 12. 13. and 14 Prooosed Chanae: Revise the analog channel operational test entries and the reactor coolant pump trip actuating device operational test entries to increase the STI from monthly to quarterly for all the above functional units generically approved for such change by the NRC via WCAP-10271 and revise the associated Table 4.3-1 Notations (1), (8) and (9).

Evaluation: The STI for these RTS instruments per existing TS Table 4.3-1 requirement is monthly. 'The revision to the Table 4.3-1 changes the STI for these instruments from monthly to quarterly. This change is acceptable because it is consistent with the pre-approved changes described in sections 3.1.1 and 3.1.4 of this evaluation.

(3)

TS 4.3.1.1. Table 4.3-1. Functional Units 2.b. 4.17.a. b. c. d. e. f Prooosed Chanag:

Revise the analog channel operational test entries to increase the STI from monthly to startup (S/U) or refueling (R) and delete functional unit 17.b, Low Power Reactor Trips Block, P-7, for the above functional units.

Evaluation:

The STI for these functional units has been monthly. These changes are acceptable because they are consistent with the pre-approved changes described in section 3.1.4 of this evaluation.

4.2 Enaineered Safety Features Actuation System (ESFAS) Instrumentation 4.2.1 TS Table 3.3-3 (1)

Functional Units 1.c. l.e. 4.d. 4.e. 8.e. 10.a. 10.b E.tooosed Chance:

Revise ACTION 15, which required that an inoperable channel be placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to require an inoperable channel to be placed in the tripped condition within 6. hours.

Add ACTION 15a for functional units 8, llb, 14c, and 15c.

This ACTION 9

continues the requirements of the previously numbered ACTION 15 for functional l

. unit parameters that were not included in the WCAP analysis.

Thus there is no change in the required ACTION for these functional units.

This is acceptable.

Evaluation:

For ESFAS functional units Ic (containment pressure high), le (steam line pressure low), 4d (steam line pressure low) and 4e (steam line pressure-negative rate high), 8e (Loss of offsite power - Start Motor-Driven Pumps and Turbine-Driven Pump),10a (4 KV Bus Undervoltage - Loss of Voltage),

10b (4 KV Bus Undervoltage - Grid Degraded Voltage) in a condition with the number of operable channels one less than the total number of channels, the existing ACTION 15 allows operation to proceed until performance of the next required ANALOG CHANNEL OPERATIONAL TEST, provided the inoperable channel is placed in the tripped position within I hour.

The revised ACTION 15 extends the time for the inoperable channel to be placed in the tripped condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The above change is acceptable because it is consistent with the pre-approved change as described in sections 3.1.2.(5).of this evaluation.

(2)

MTOMATIC ACTUATION LOGIC and ACTUATION RELAYS (ACTIONS 14. and 21)

P_r92q_sd.lhanqe:

Revise ACTIONS 14 and 21 to include an additional provision t

to allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable channel to operable status before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to increase the allowed bypassed time from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

Add ACTION 14a for functional units 12b (containment air return and hydrogen skimmer) and 13b (annulus ventilation operation).

This ACTION continues the requirements of the previously numbered ACTION 14 for functional unit parameters that were not included in the WCAP analysis.

Thus, there is no change in the required ACTION for these functional units.

This is acceptable.

Evalua1Lgn:

With the number of OPERABLE channels one less than the allowed minimum operable channels, the existing ACTION statements 14 and 21 require the plant to be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , however, one channel may be bypassed up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other channel is operable.

The revised ACTION statements allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable channel before requiring shutdown to HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and increases the allowed bypassed time from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

The above change is acceptable because it is consistent with the pre-approved change as described in section 3.1.2 of this evaluation.

(3)

ACTION 16. Containment Pressure Hiah-High

_P_toposed Change:

Revise ACTION 16 to increase the time a second containment pressure High-High channel may be bypassed to allow testing of the channel from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

- a

. Add a new ACTION 16a for functional unit 9b, RWST Level-low.

This ACTION continues the requirements of the previously numbered ACTION 16 for this parameter that was not included in the WCAP analysis. Thus, there is no change in the required ACTION for this functional unit. This is acceptable.

Evaluation: With the number of OPERABLE channels one less than the total number of channels, ACTION 16 of existing TS allows operation to proceed provided the inoperable channel is placed in the bypassed condition and the requirement for the minimum channels operable is met. One additional channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.

The revision to the action statement allows a channel to be bypassed up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing.

The above change is acceptable because it is consistent with the pre-approved changes described in 3.1.2(2) of this evaluation.

(4)

ACTION 19 and 16b Proposed Chanae:

Revise ACTION 19.a to increase the time an inoperable channel may be maintained in an untripped condition from 1 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Revise ACTION 19.b to increase the time an inoperable channel may be bypassed to allow surveillance testing of other channels in the same function from 2 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Evaluation: With the number of operable channels one less than the total number of channels, ACTION 19 of existing TS allows startup and/or power operation to proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and the requirement for the minimum channels operable is met; however, one additional channel may be bypassed up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing.

The revision to the action statement allows up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , instead of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , for putting a channel in the tripped condition and allows for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , for one additional channel to be in a bypassed status for surveillance testing.

The above change is acceptable because it is consistent with the pre-approved changes described in section 3.1.2 of this evaluation.

4.2.2 Surveillance Test Interval (STI) For ESFAS (1)

Proposed Chanae and Evaluation:

TS 4.3.2.2 is modified by deletion of a footnote (*) which refers to testing required prior to startup following the Unit 2 first refueling.

Since this milestone has been passed this footnote is extraneous and may be deleted.

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,e, a

_g-(2)

TS 4.3.2.1. Table 4.3-2. Functional Units 1.c.1.d. l.e. 2.c.

3.b.3.4.c. 4.d. 4.e. 5.b. 5.c. 6.c. 8.c.12.c. and 18.a.b.c.e.

Proposed Chanae:

Revise the analog channel operational test entries to increase the STI from monthly to quarterly for all the above functional units generically approved for such change by the NRL lia WCAP-10271.

Footnote (4) for functional units 5.d, 6.d and 6.e in Table 4.3-2 allowed a delay in the first time performance of this test for Unit 2 until after the first fuel cycle. With that milestone now completed the note is obsolete and may be removed. This is acceptable.

Evaluation:

The STI for these ESF instruments per existing TS Table 4.3-2 requirement is monthly.

The revision to the Table 4.3-2 changes the STI for these instruments from monthly to quarterly. This change is acceptable because it is consistent with t'e pre-approved changes described in section 3.1.2.(1) n of this evaluation.

4.3 Other Miscellaneous Chanaes TS Table 3.3.3 Item 14.g(l) and the associated Table Notations

and ** and ACTION STATEMENT 28 are deleted now that the purpose they were created for, to facilitate changeover of the nuclear service water swapover logic, has been completed.

These changes are administrative in nature and improve the readability of the TS and are acceptable.

The licensee also proposed changes to the TS BASES 3/4.3.1 and 3/4.3.2 to support the STI and A0T changes.

4.4 Verification of Conditions Through its submittals, the licensee confirmed that it has met the SER i

conditions as described below.

(1)

Condition 3.2.1.(1):

Performance of testing on a staggered basis was stipulated by the RTS SER, but was removed by the ESFAS SER. The licensee had not applied for an amendment based on WCAP-10271 to change the RTS STI's before the January 25, 1993 application. Therefore, staggered testing had not been incorporated in the Catawba TS.

Therefore, no change is required for the Catawba TS in response to this issue.

This is acceptable.

(2)

Condition 3.2.1.(2): The licensee stated that station directives, maintenance procedures and guidelines exist for the administration of station equipment reliability programs.

Identification of significant or recurring failures in an RTS or ESFAS channel would require a Problem Investigation Report.

The licensee's assessment would include but not be limited to evaluations for common cause failure mechanisms and subsequent testing of comparable equipment when deemed necessary.

This is acceptable.

.I

)

,. (3)

Condition 3.2.1.(3):

The licensee stated that the Catawba design does not have installed bypass capability within the 7300 Protection and Control System at this time.

The licensee has no plans to pursue that portion of the WOG effort which would allow for routine channel testing in the bypass condition.

Routine channel testing will continue to be performed in the tripped condition.

This is acceptable.

(4)

Condition 3.2.3.(1):

The generic analyses used in WCAP-10271 and its supplements are applicable to Catawba. The licensee uses the Westinghouse process control system and the Westinghouse solid state protection System for ESFAS and RTS. These systems were specifically modeled in the generic analyses. The licensee states that the RTS and ESFAS functions for which increased surveillance intervals and allowed outage times are being requested are those for which NRC approval has i

already been granted through issuance of the SERs and supplements for the WCAP-10271 reports.

The staff has found this to be the case and this is acceptable.

(5)

Condition 3.2.3.(2):

The licensee performed a review of the plant's "as found" and "as left" data for the RTS and ESFAS setpoints for a 12 month period and concluded that sufficient margin is present to offset the drift anticipated as a result of quarterly surveillance.

The licensee further stated that the allowable margin present in the setpoints is more than adequate to offset any drift observed based upon review of the data.

This is acceptable to the staff.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the South Carolina State official was notified of the proposed issuance of the amendments.

The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.

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 l

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 such finding (58 FR 41501 dated August 4, 1993). 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.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the

1

.... public will not be endangered by operation in the proposed manner, (2) 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 Contributor:

R. Martin Date:

July 19, 1994 i

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ML20071J185

Contents

Text

1.0 INTRODUCTION

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

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ML20071J185

Text

1.0 INTRODUCTION

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

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