ML20086Q000
| ML20086Q000 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/24/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20086P985 | List: |
| References | |
| NUDOCS 9507270248 | |
| Download: ML20086Q000 (5) | |
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UNITED STATES j
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NUCLEAR REGULATORY COMMISSION E
E WAsMINGTON. O.C. 20006-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i
RELATED TO AMENDMENT NO. in TO FACILITY OPERATING LICENSE NPF-35 i
AND AMENDMENT NO. 126 TO FACILITY OPERATING LICENSE NPF-52 l
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CATAWBA NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 l
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1.0 INTRODUCTION
By letter dated January 18, 1995, Duke Power Company, et al. (the licensee),
l submitted a request for changes to the Catawba Nuclear Station, Units 1 and 2, Technical. Specifications (TS).
The requested changes would relocate the requirements for the seismic instrumentation, meteorological instrumentation, and loose-part detection system, and the associated Bases and surveillance requirements, from the TS to the Selected Licensee Cosuiitment (SLC) Manual.
The SLC Manual _is Chapter 16 of the Final Safety Analysis Report (FSAR). This will allow future changes to these controls to be performed under the t
provisions of 10 CFR 50.59. No changes are being made to the technical content of the affected TS pages.
l Section 182a of the Atomic Energy Act, as amended (the "Act"), requires that-l applicants for nuclear power plant operating licenses include TS as a part of the license. The Commission's-regulatory requirements related to the content of the TS are set forth.in 10 CFR 50.36. That regulation requires that the TS i
include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control' settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls and states also that the Commission may include such additional TS as it finds to be appropriate. However, the l
regulation does not specify the particular TS to be included in a plant's.
license.
t The Commission has provided guidance for the contents of the TS in its " Final Policy Statement bn Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"),.58 FR 39132 (July 22,1993),. in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
In' particular, the Commission indicated -
l that certain items could be relocated from the TS to licensee-controlled
, documents, consistent with the standard enunciated in Port 7and General.
'i Electric Co. (Trojan Nuclear Plant),' ALA8-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical j
specifications are to be reserved for those matters as to which the~ imposition t
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of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:
(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) A structure, system, or component which operatingexperienceorprobabilisticsafetyassessmenthasshowntobe significant to public health and safety.
As a result, existing Limiting Condition for Operation (LCO) requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TS, while those LC0 requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
2.0 EVALUATION 3/4.3.3.3 Seismic Monitorina Instrumentation Section VI(a)(3) of Appendix A to 10 CFR Part 100 requires that seismic monitoring instrumentation be provided to promptly determine the response of those nuclear power plant features important to safety in the event of an earthquake.
This capability is required to allow for a comparison of the measured response to that used in the design basis for the unit.
Comparison of such data is needed to (1) determine whether the plant can continue to be operated safely, and (2) permit such timely action as may be appropriate.
However, seismic instrumentation does not actuate any protective equipment or serve any direct role in the mitigation of an accident.
The capability of the plant to withstand a seismic event or other design-basis accident is determined by the initial design and construction of systems, structures, and components.
The instrumentation is used to alert operators to the seismic event ind evaluate the plant response.
The Final Policy Statement explained that instrumentation to detect precursors to reactor coolant pressure boundary leakage, such as seismic instrumentation, is not included in the first criterion. As discussed above, the seismic instrumentation does not serve as a protective design feature or part of a primary success path for events which challenge fission product barriers.
The staff has concluded that The Connission recently promulgated a proposed change to 10 CFR 50.36, pursuant to which the rule would be amended to codify and incorporate these criteria (59 FR 48180, September 20, 1994). The Consnission's Final Policy Statement specified that the Reactor Core Isolation Coolire, Isolation Condenser, Residual Heat Removal, Stan&y Liquid Control, and Recirculation Pump Trip are included in the is under criterion 4 (58 FR 39132, July 22, 1993).
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the seismic monitoring instrumentation does not satisfy the Final Policy Statement criteria and need not be included in the TS. Thcrefore, it-is
' acceptable for the licensee to relocate the seismic monitoring instrumentation requirements to the SLC Manual and control changes to those provisions in accordance with 10 CFR 50.59.
3/4.3.3.4 Meteoroloaical Instrumentation The meteorological monitoring instrumentation is used to measure environmental parameters (wind direction, speed, and air temperature differences) which may affect the distribution of radioactive effluents following a release of radioactive material.
In 10 CFR 50.47, " Emergency Plans," and 10 CFR Part 50, Appendix E, " Emergency Planning and Preparedness for Production and Utilization Facilities," the Commission requires power plant licensees to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Timely access to accurate 4
local meteorological data is important for estimating potential radiation doses to the public and for determining appropriate protective measures.
In 10 CFR 50.36a(a)(2), the Commission requires nuclear power plant licensees to submit annual reports specifying the quantity of each of the principal radionuclides released to unrestricted areas in liquid and airborne effluents and such other information as may be required by the NRC to estimate maximum potential annual radiation doses to the public. A knowledge of meteorological conditions in the vicinity of the reactor is-important in providing a basis for estimating annual radiation doses resulting from radioactive materials released in airborne effluents. Accordingly, the meteorological monitoring instrumentation serves a useful function in estimating radiation doses to the i
l-public from either routine or accidental releases of radioactive materials to the atmosphere. The licensee has proposed to relocate these provisions to the SLC such that future changes.to the operation and survie11ance of the meteorological monitoring instrumentation could be changed under 10 CFR 50.59.
The meteorological monitoring instrumentation does not serve a primary protective function so as to warrant inclusion in the TS in accordance with the criteria of the Final Policy Statement. The instrumentation does not serve to ensure that the plant is operated within the bounds of initial conditions assumed in design basis accident and transient analyses or that the plant will be operated to preclude transients or accidents.
Likewise, the meteorological instrumentation does not serve as part of the primary success path of a safety sequence analysis used to demonstrate that the consequences of these events am within the appropriate acceptance criteria.
Accordingly, the staff has concluded that the meteorological instrumentation does not satisfy the Final Policy Statement criteria and need not be included in TS. The staff has determined that requirements related to the meteorological monitoring instrumentation can be moved from the TS to the SLC Manual, and that any subsequent changes to the provisions would be controlled pursuant to 10 CFR 50.59. Accordingly, the relocation of the meteorological instrumentation requirements from the TS to the SLC Manual is acceptable.
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3/4.3.3.10 Loose-Part Detection System The loose-part detection system identifies the existence of possible loose parts in the reactor coolant system.
Early detection can provide operators time to take corrective actions and avoid or mitigate damage to or malfunctions of primary system components. However, as discussed in the Final Policy Statement, the loose-part detection system does not function to detect significant abnormal degradation of the reactor coolant pressure boundary.
The loose-part detection system does not serve as an active design feature for establishing initial conditions or mitigation of design basis accidents or transients.
The staff has concluded that requirements for this system do not satisfy the Final Policy Statement criteria and need not be included in TS.
Therefore, it is acceptable for the Licensee to relocate the requirements related to the loose-part detection system from the TS to the SLC Manual and to control changes to those provisions in accordance with 10 CFR 50.59.
3.0 STAFF CONCLUSION On the basis of the evaluations above, the staff concludes that these requirements related to instrumentation are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Act, and are not required in order to provide adequate protection to the health and safety of the public.
- Further, they do not fall within any of the four criteria set forth in the Commission's Final Policy Statement, discussed above.
In addition, the NRC staff finds that sufficient regulatory controls exist under the provisions of 10 CFR 50.59 to ensure that future changes to these requirements will be acceptable.
Accordingly, the staff has concluded that these requirements related to instrumentation may be relocated to the SLC Manual.
The NRC staff has no objection to the deletion of the Bases associated with the relocated requirements.
4.0 STATE CONSULTATION
r 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.
5.0 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 v
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 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 (60 FR 24910 dated May 10, 1995). Accordingly, the amendments meet the eligibility.
criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant P
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-5 to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the 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:
William Reckley Carl Schulten S. Kirslis Date: July 24,1995
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