ML20086D785

Application for Amends to Licenses NPF-35 & NPF-52,changing TS Table 2.2-1 to Revise Slope Value for Positive Wing of Axial Offset Band

ML20086D785
Person / Time
Site:	Catawba
Issue date:	11/20/1991
From:	Owen W DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086D789	List: ML20086D785 ML20086D791
References
NUDOCS 9111260260
Download: ML20086D785 (6)

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4 ll l liuke hen Company W 11 OMF%

422 Soutit Ch:n h Street therutut lice nestdent Charlotte, NC 28242M101 1704k17L4120 l

. DUKEPOWER November 20, 1991 i U. S.' Nuclear Regulatory Commission Atti;: Document Control Desk Washington, D.C. 20555

Subject:

Catawba Nuclear Station

-Docket Nos. 50-413 and 50-414 Technical Specification Amendment Table 2.2-1 l

l Please find attached a proposed amendment to the Catawba Nuclear Station Technical Specificatj0ns. This proposed revision-changes the slope value for the positive wing of the axial offset band, which was determined to be nonconservative for Catawba' Unit 2. In addition, the unit specific values for Total Allowance, Z, S, and Allowable Value are added since a e new, more restrictive, Allowable Value was calculated for Unit 2.

Duke Power is requesting that, if necessary, this amendment be processed on an exigent basis, according to 10 CFR 50.91(a) (6) .

Catawba Unit 2 is currently scheduled to start up from refuelling-on-December 14, 1991. If the outage continues as scheduled it will be necessary to issue this amendment without the complete 30 days publi'c comment period in order not to delay startup. Justification for processing this amendment on an exigent basis is included.

Attachment 1 contains- a Discussion of the Circumstances and Need for Prompt Action, Attachment 2 contains the marked up TS pages, Attachment 3 contains the Technical Justification, and Attachment 4 contains the No Significant liazards Analysis and Environmental Impact Statement.

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4 U. S .- Nuclear Regulatory Commission November' 20,- 1991 page xc: Mr. S. D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, GA 30323 Mr. Heyward Shoaly, Chief-Bureau of. Radiological !!calth South Carolina Department of Health &

Environmental Control 2600 Bull Street Columbia, SC 29201 American Nuclear Insurers c/o Dottie Sherman, ANI Library The Exchange, Suite 245 270 Farmington Avenue Farmington,'CT 06032 M & M Muclear Consultants Suite-1500 1100 Circle 75 Parkway Atlanta, GA 30339 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station '

Mr. R. E. Martin Office of Nuclear Regulation U. S. Nuclear Regulatory Commission One White-Flint North,.ill Stop 14112 5 Washington, D.C. 20555 I

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e U. S. Nuclear Regulatory Commission November 20, 1991 page 3 l

W. H. Owen, being duly sworn, states that he is Executive Vice President, 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 _ Technical Specifications, Appendix A to 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.-

W. H'. .Owen Subscribed and sworn to before me this 2h day of Cr t,o x [f 2,- ' 1991.

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Discussion of Circumstances and Need For Prompt Action On August 20, 1991 Duke Power was notified by Westinghouse via telephonS that a potential issue had been identified which af f ected the OTAT f(AI) reset function for Catawba Unit 2. On August 23, 1991 the Catawba Unit 2 Cycle 5 Reload Safety Evaluation was received from Westinghouse. The potential issue was noted in the cover letter, along with a proposed resolution by Westingnouse.

The lettur stated that the current f(al) penalty for Catawba Unit 2 Cycle 5 may not provide sufficient protection without allocation or generation of additional DNB margin. The cover letter also indicated that if the Revised Thermal Design Procedure instead of the current licensing basis Improved Thermal Design Procedure were utilized, suf ficient DNB margin would be providad that the current setpoints would be acceptable.

Between August 26 and September 9, 1991 Duke Power worked to gain 0 a better understanding of both the potential issue identifiod by Wertinghouse, and the rationale behind th< ir r rupt nad resolution.

Discussions were held with Texas Utilities, who dem.ified the non-conservative methodology, to improve our undetstanding of the issue. Conference calls were also held with Westinghouse about application of the Revised Thermal Design Procedure to resolve the issue. Duke was unable to get enough information to be completely comfortable with the Westinghouse resolution to the Potential Issue. On September 9, 1991 a letter was sent to Westinghouse requesting information with a requested response date of September 30, 1991.

On September 30, 1991 Duke Power contacted Westinghouse to inquire about progress on the response to Duke's questions. Duke was informed that the work had not begun because the necessary resources had not been allocated to answer our questions. _

On October 11, 1991 another cc.Tference call was held with Westinghouse. It was agreed that resolution of the issue by reanalysis or methodology change would require changes to the Technical Specifications, however, it had not yet been determined that the resolu ion proposed by Westinghouse was not defensible.

It was also not ', at this time that McGuire could potentially be impacted by this methodology error. Westinghouse indicated that it was already working to determine tP ffect on McGuire.

In the time period between Octouer 14 :tnd October 21, 1991, discussions were held both internally at f .aa and with Westinghouse about the applicability of the resolutiur. proposed by Westinghouse to the Potential Issue. It was de crmi.Ted that the resolution proposed by Westinghouse in the Reload Safety Analysis Report cover letter was not adequate and that a different resolution must be decided on and pursued.

In the time between October 21-23 a new solution, different from the one proposed by Westinghouse, was negotiated with them. It was

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i determined that an evaluation, using the current licensing basis Improved Thermal Design Procedure was necessary and that changes to the Technical Specifications would be necessary. Westinghouse was directed te begin work on the evaluation, and the need for quick resolution based on the Catawba Unit 2 startup date was stressed.

On October 24, 1991 the NRC Project Managers for McGuire and Catawba were notified. The Project Managers were informed that changes to the Catawba Technical Specifications wou}d be necessary prior to startup for Unit 2 and that the effect of this error on McGuire had not been determined.

A package containing proposed changes to the Technical Specifications was received from Westinghouse on November 14, 1991.

After rocciving the package Duke had questions concerning .L a changes. We had not received enough information to adequualy understand all the changes. Westinghouse was contacted 'or this information. After receiving these changes Duke Power had to evaluate their effect on plant operation. The remaining time before submittal was spent assembling the package and obtaining the necessary reviews, Before appl i/ ng for a TS Amendment it is essential to ensure that the requested change is valid, and that the plant can operate using these limits. There is also a TS required review and approval process; including review by cognizant -

individuals at the plant, in the General Of fice, Engineering Group, and in management, that must be followed.

Duke Power is requesting that, if necessary, this amendment be processed on an exigent basis, according to 10 CFR 50. 91(a) (6) .

Catawba Unit 2 is currently scheduled to start up from refuelling on December 14, 1991. If the outage continues as scheduled it will be nocersary to issue this amendment without the complete 30 days public comment period. The period of time between Duke's receiving L notification of the potential issue by Westinghouse and this request for an amendment to the Technical Specifications was spent gathering the information needed to understand the issue and in the reanalysis offort. As described in the preceding paragraphs this requested amendment was pursued in a timely manner, and the exigent circumstances were not created by Duke Power.

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