ML20079G549

Application for Amend to License NPF-9,extending Required Implementation Date for outside-containment Portion of in-core Thermocouple Sys Upgrade,Per NUREG-0737,Item II.F.2, Inadequate Core Cooling Instruments, & Suppl 1 to NUREG

ML20079G549
Person / Time
Site:	McGuire
Issue date:	01/12/1984
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM TAC-53503, TAC-56777, TAC-56778, NUDOCS 8401200186
Download: ML20079G549 (8)

Text

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P.O. Ilox 3 31150 CHAnLOTTE. N.G. 2152 4 2 IIAL II. TUCKI:H TELEPHONE m.....,,, January 12, 1984 pov ara c u

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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Es. E. G. Adensam, Chief Licensing Branch No. 4

Subject:

McGuire Nuclear Station Dockat No. 50-369 License Condition 2.C. (11)f. (3) Amendment License Section 2.G Report

Dear Mr. Denton:

l Attached is a proposed amendment to Facility Operating License No NPF-9 for McGuire Nuclear Station Unit 1. The proposed amendment involves extending the required implementation date for the outside-containment portion of the incore t.hermocouple system upgrade (NUREG-0737, " Clarification of TMI Action Plan Requirements"; Item II.F.2 - Inadequate Core Cooling Instruments) as l specified in License Condition 2.C.(11)f.(3). The new implementation date is consistent with the schedules being identified as part of the response to NUREG-0737, Supplement 1. The in-containment portion of the upgrade will be -

i completed on schedule.

1 Attachment I contains the License Amendment, and Attachment 2 discusses the l justification and safety analysis to support the proposed amendment. Pursuant to 10 CFR 50.91, Attachment 3 provides an analysis performed in accordance with the standards contained in 10 CFR 50.92 which concludes that the proposed amendment does not involve a significant hazards consideration. The proposed amendment has been reviewed and determined to have no adverse safety or envir-onmental impact.

Pursuant to 10 CFR 170.22, Duke Pouer proposes that this application contains one Class II license amendment for McGuire Unit 1. Therefore, a check in the amount of $1200 is enclosed in accordance with 10 CFR 170.12.

Initial notification of Duke Power's inability to comply with condition 2.C.

(11)f.(3) of License No. NPF-9 was made with members of your staff and the regional office on December 30, 1983 in compliance with Section 2.G of the license, with a confirming letter submitted the same date.- Accordingly, the information provided herein is also submitted in fulfillment of the written followup reporting provisicas of license Section 2.G.

Very truly yours. (

e4 C _~ J M 0,#.

Hal B. Tucker []9 9 e i

PBN:jfw B401200186 8401i2 Attachments PDR ADOCK 05000369 P PDR a . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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• Harold R. Denton Page 2 -

January 12, 1984 cc: Mr. Dayne Brown, Chief Radiation Protection Branch Division of Facility Services Department of Human Resources P. O. Box 12200 Raleigh, NC 27605 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station P

e I

l Harold R. Denton '

Page 3 January 12, 1984 i.

HAL B. TUCKER, 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 amendment to the McGuire Nuclear Station Facility Operating License No. NPF-9; and that all statements and matters set forth therein are true and correct to the best of his knowledge.

M .v_- - -

Hal B. Tucker, Vice President Subscribed and sworn to before me this 12th day of January,1984 Notary Public My Commission Expires: {

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Attachment 1.

McGUIRE NUCLEAR' STATION FACILITY OPERATING LICENSE NO. NPF-9 PROPOSED LICENSE AMENDMENT License Condition No. 2.C.(11)f.

Inadequate Core Cooling Instruments (3) Upgrade Incore Thermocouple Monitoring System Proposed Change Change the subject license condition to read as follows:

"The licensee shall_ upgrade the in-containment portion of the incore thermocouple system prior to startup following the first refueling outage, and ahall provide a schedule for. upgrade of the remainder of the system in the Redulatory Guide 1.97 Accident Monitoring Review Report: submittal. pursuant to

-NUREG 0737, Supplement 1."

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Attachment 2 ,

JUSTIFICATION AND SAFETY ANALYSIS Discussion

-The license condition requires the incore thermocouple system to meet a revised set of design criteria in the areas of performance, qualification and operator inter-face. At the time the condition was initially included in the McGuire license, Duke Power Company concluded that satisfying these requirements by the original date of January 1,1982 was a virtual impossibility because of the nature of the changes that would be required and the relatively short time available to accom-plish them. In a letter to the NRC on April 23, 1981 Duke provided its assess-ment of the installed thermocouple system and stated its intent to pursue develop-ment of a thermocouple system which would meet the criteria in NUREG-0737.

In spite of efforts by Duke Power Company, a final system design had not been developed by December, 1981. Since once a proposed system design was received it still had to be evaluated against other related requirementL such as control room design review requirements, safety parameter display system requirements, Regula-tory Guide 1.97 requirements and NUREG 0588 requirements to name a few, a license amendment request was submitted (ref. Mr. A. C. Thies' December 16, 1981 letter) and approved extending the required implementation date of the license condition.

The change to the license condition recognized that there are two distinct phases to the effort. In Duke Power's March 9, 1983 response to NRC Generic Letter No.

82-28 a plan was provided for upgrading the installed incore thermocouple system to meet the criteria in NUREG 0737. This response described the present system and its capabilities, and described the upgraded system along with the two phase -

approach to this upgrade. The first phase to be completed prior to the end of **

the first refueling, involves upgrading the in containment portion of the system.

This would include meeting qualification and separation requirements. The second phase involves upgrading of the control room displays. Rather than modify the control room displays in isolation, it was proposed that these displays be modified upon completion of the Control Room Design Review and the RG 1.97 Accident Monitor-ing Instrumentation Review which have been initiated. This assures that all per-tinent' criteria are properly considered in the final design of the display system and is consistent with the intent of Supplement 1 to NUREG 0737.

In pursuing this objective, Duke has dcne the following:

(1) Written specifications, reviewed proposals, and procurred the equipment necessary for the phase 1 upgrade.

(2) Reviewed vendor drawings and performed the supporting Duke detailed design necessary for the phase 1 installation.

(3) Initiated the Control Room Design Review. ,

(4) Initiated the RG 1.97 Accident Monitoring Review.

Schedule and Status The phase 1 upgrade is on target for the submitted schedule. IC 1 equipment is presently on site and all design documents have been released cf. support the

' February-March 84 refueling outage installation.

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• The current license condition requires the outside containment upgrade to be implemented ~no later than December 31, 1983. As previously addressed, the phase 2 upgrade design is being incorporated into the RG 1.97 Accident Monitoring Instrumentation Review and the Control Room Design' Review. In the April 14, 1983 response to Supplement 1 of NUREG 0737, the schedule for NRC submittal for the reports from both these reviews is March, 1984 The RG 1,97 Accident Monitoring Review Report will contain the schedule for the phase 2 upgrade which will be an integrated part of the installation of changes from the Accident Monitoring Instrumentation Review and Control Room Design Review.

Safety Analysis It is Duke Power Company's conclusion that extension of the implementation date for upgrading of the outside containment portion of the incore thermocouple system beyond December 31, 1983 does not involve any adverse safety considerations. The thermocouple monitoring system as presently installed is a very simple system which by virtue of its simplicity is highly reliable and accessible. The system has the following capabilities:

(a) A spatially oriented core map is available on demand which indicates the temperature at core exit thermocouple locations.

This map can be displayed or printed on demand.

(b) An example of the McGuire selective readings is an on-demand tabular listing of instantaneous incore thermocouple values.

This listing can be displayed or printed on demand.

(c) Direct readout of average and instantaneous values, as well -

as hard-copy capabilities, are provided for thermocouple ~~

temperatures. The range is 0-2300*F.

(d) Trend capability showing temperature-time histories is designed into the system. Strip chart recorder points are available to assign to any incore thermocouples on demand. In addition, a point-value trend pr.intout is available on the control room typer.

(e) Alarm capability is provided in conjunction with the Subcooling Monitor, which uses the average of valid thermocouple readings in its calculations and alarms when the valve drops below the setpoint.

(f) The CRT displays are designed for rapid operator access and ease of viewing data. In addition, the incore program has a validity-check comparison which reduces the probability of accessing false readings.

The backup display has an extended range (0-2300*F) which does not rely on the plant computer. Both the primary and backup display channels are powered by a highly reliable battery-backed power supply.

Following the February-March 84 refueling outage, the portion of the upgraded system which may be exposed to a harsh environment will be qualified to withstand i

. - _ _ _ - _ _ _ _ - - _ _ _ _ _ l

, ?. .

1 the.. accident' environment. . All other parts of the system which remain to be-

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-upgraded are located in a mild environment.

In that these and other control room modifications.will only provide incremental improvements in the reliability and human factors aspects of. existing displays, deferral of the required implementation date will not result in a reduction in

-the level of safety.

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Attachment 3.

i ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION As required by 10 CFR 50.91, this analysis is provided concerning whether the proposed amendments involve significant hazards considerations, as defined by 10 CFR 50.92. 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 21 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 proposed amendment would not involve a significant increase in the probability of an accident previously evaluated because the incore thermocouple monitoring system is designed to assess plant conditions during and following an accident and can have no effect on cause mechanisms. The consequences of accidents pre-viously evaluated would not be significantly increased by extending the required .

implementation date because upgrading of the outside-containment portion of the incore thermocouple system will only provide incremental improvements in the reliability and human factors aspects of existing concrol room displays. The

?.hermocouple monitoring system as presently installed is highly reliable and accessible.

The proposed amendment would not create tha possibility of a new or different kind of accident than previously evaluated since the incore thermocouple monitoring system cannot cause an accident to occur. In addition, no changes to margins of **

safety are involved in extending the implementation date.

Based upon the preceding analysis, Duke Power Company concludes that the proposed amendment does not involve a significant hazards consideration, i

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