ML20087J055
| ML20087J055 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/15/1984 |
| From: | Tucker H DUKE POWER CO. |
| To: | Adensam E, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8403220074 | |
| Download: ML20087J055 (2) | |
Text
e Duxu POWER Gom%NY 18.0. ISOX 331f30 CIIAHIJYI"1E. N.C. 2(3242 IIAL 11. TUCKEH rzt.zenoxz 77/.","~",-
March 15, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4 Re: Catawba Nuclear Station Proof and Review Technical Specifications
Dear Mr. Denton:
Following the meeting between Mr. Fred Anderson, Mr. Horace Shaw (of your staff) and representatives of Duke Power on February 28, 1984 concerning the NRC proposed snubber echnical Specification for Catawba Unit 1, we reviewed the March 1, 197 letter from Joseph Sapir to Dennis L. Ziemann on the subject of " Tech ical Specifications for Snubber Operability and Surveillance."
The purpose of the review was to attempt to determine whether Mr. Sapir intended for the inspection schedule to be used on a system basis or on a unit basis. Application on a system basis requires much less inspection than on a unit basis.
Our conclusion is that Mr. Sapir meant the inspection to be done on an electric generating unit basis. Therefore, it is requested that the Catawba snubber Technical Specification be written to reflect _ inspection on a " unit" basis instead of the current " system" basis. Conclusions of our review are:
e Although there are places where Mr. Sapir mentions " pipe" or " piping system," we find those references to be consistent with inspection on a unit basis. To a lesser degree, the converse is true.
In four locations, indicated by numbered arrows, we find references to We find the last two such references (3 and 4)pection on a system basis.
plant (unit) which are not consistent with ins to be consistent only with a unit basis, e Our understanding of the original intent of the snubber inspect",n it consistent only with inspection on a unit basis. We believe the intent was to survey all snubbers to locate those which suffered from any of a number of problems which are not system specific.
e Mr. Sapir's analysis provides a.65 probability that all snubbers are operable at the time of a dynamic event. When applied on a unit basis, that sounds reasonable.
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Mr. Harold R. Denton, Director March 15,1984 Page 2 If applied on a system basis, we believe the probability of unit protection would be:
's N,
Punit = Psystem 1,x Psystem 2 x Psystem 3... x Psystem n
=(PsystemT,g whare n = number of systems Assuming 30 safety related systems (McGuire 1 has at least 31), the probability of unft protection is very small.
e We bdlieve that 'all utilities and inspectors have interpreted the Technical Specific 6tions to require inspection on a unit basis. We know that this is true at our Oconee and McGuire Nuclear Stations.
Inspections required by 0 & M-4 (latest Revision 1, Draft 4, dated January 1984) are on a unit basis. We know of no contrary interpretation.
Based on the above, we believe that it should be recognized that snubber inspection on a system basis is a new concept and is completely different frcm present industry. direction.
Very truly yours, k AS ?
Hal B. Tucker RWO/php cc: Mr. James P. O'Reilly, Regional Admin.strator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 Palmetto Alliance 21351 Devine Street Columbia, South Carolina 29205 Mr. Robert Guild, Esq.
Attorney-at-Law P. O. Box 12097 tharleston, South Carolina 29412 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 NRC Resident Inspector Catawba Nuclear Station