ML20091L297

Application for Amends to Licenses NPF-35 & NPF-52,modifying TS SR 4.2.5.2 to Delete Requirement to Calibr RCS Flowrate Measurement Instrumentation within 7 Days Prior to Performance of Flow Measurement

ML20091L297
Person / Time
Site:	Catawba
Issue date:	08/17/1995
From:	Mccollum W DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091L301	List: ML20091L297 ML20091L307
References
NUDOCS 9508290118
Download: ML20091L297 (11)

Text

g;Wy _

-~ ~^ " ^ "' ~ '~ ~ " ~ ~ ~ ~ ' ~ ~ ~

}

k 'I

l a .

' ; Duke MdCompany; ,.

WawuR.51Xount, k '

s - Catauha Nudear Gmeration Department ' ficehesidmt  ;

.4800OnordPost (803)S314J00 Office . ]

LM SCDT4L (8W)83144%% i l

DUKEPOWER -

August 17, 1995 -

U.S. Nuclear Regulatory Commission f JATrN: DocumentControlDesk

~ Washington, D.C.'20555 l; i

1

Subject:

. Catawba Nuclear Station, Units 1 and 2 )

Docket Nos. 50413 and 50-414  :

Proposed Technical Specifications (TS) Changes Delete the Requirement to Calibrate the Reactor Coolant System Flowrate  ;

Measurement Instruraentation l l

. Gentlemen:

1 Pursuant to 10CFR50.4 and 10CFR50.90, attached are license amendment requests to Appendix A, l Technical Specifications, of Facility Operating Limnses NPF-35 and NPF-52 for Catawba Nuclear Station Units 1 and 2, respectively.  ;

1

' Ihe' proposed amendments modify TS Surveillance Requirement (SR) 4.2.5.2 to delete the I

'. requirement to calibrate the reactor coolant system (RCS) flowrate measurement instrumentation  !

within 7 days prior to the performance of the flow measutement.

, Attachment I contains a background and description of the enclosed amendment. request.

Attachment 2 contains the required justification and safety evaluation. Pursuant to 10CFR50.91, j Attachment 3 provides the analysis performed in Ewidic,ce with the standards contained in  !

L_ 10CFR50.92 which concludes that the requested amendments do not involve a significant hazards consideration.. Attachment 3 also contains an environmental impact analysis for the requested amendments. Attachment 4 contains the marked-up TS amendment pages for Catawba. Duke Ptmer Company is forwarding a copy of this amendment request package to the appropriate South t Carolina state ofHeial. ,!

. l

As a sesult of Amendment Nos.128 and 122 for Units 1 and 2, respectively, Catawba now ntilim La RCS flowrate mensmement method based on a one-time calibration of the cold leg elbow .

~

differential pressme taps. 'Ihis method replaced the previous method which involved a precision l w , calorimetric heat balance. . In Catawba's original January 10, 1994 applicatinn', as amended,  !

pertaining to Amendment Nos.'_128/122, Catawba' failed to modify SR 4.2.5.2 to delete that portion I I

O '95082 0118 950917 'p I r1~

h; PDR ..ADDCK 05000413 n<a m wwm . P1 PDR ,, ,I[

. _ . . . .. _ ._ _ _ __ J

,U ,

Doc'ument Control Desk

._Page 2 August 17,1995 of the SR which specifies that the measurement instrumentation shall be calibrated within 7 dr.ys prior to the performance of the flowrate measurement. 'Ihis portion of the SR should have been deleted at the time the January 10, 1994 amendment application was submitted been= it only applied to the precision calorimetric heat balance method of RCS flowrate measurement.

On April 3,1995, following the completion of the Unit 1 endef-cycle 8 refueling outage, the 18-month surveillance pursuant to SR 4.2.5.3 was performed on Unit 1 using the cold leg elbow tap method of flowrate measurement. Credit was not taken for SR 4.2.5.3 at the time it was performed, since the requirement to calibrate the RCS flownte measurement instrumentation within 7 days of the performance of the surveillance could not be met due to the fact that this requirement is not applicable to the cold leg cibow tap method of RCS flowrate measurement. Approval of this amendment request is therefore receuary to allow credit to be taken for the April 3,1995 surveillance. 'Ihe latest date on which the next required performance of SR 4.2.5.3 becomes due, including grace time, is February 14, 1996. Duke Power Company is therefore requesting NRC approval of this amendment request by January 1,1996. In addition, Duke Power Company is requesting a thirty 4y period following NRC approval of the proposed amendments to allow for implementation.

Should there be any questions concerning this amendment request package or should additional information be required, please call LJ. Rudy at (803) 831-3084.

Very truly yours,

! W.R. McCollum IJR/s

Attachments

i r <

r ,

na4=w=t Contml Desk '}

Page 3'  !

August 17,1995 '!

i i

t xc(with attachments):  ;

i S.D. Ebneder, Regional Administrator Region H ,

RJ. Facudenberger, Senior Resident Iner  ;

1 R.E. Martin, Senior Project Manrger -  !

ONRR  !

Max 1hdavia, Chief Burtsu of Radiological Health, SC l 1

1 I

E 1

1 l

l

D .-  !

l

. i t

Document Contml Desk Page 4 August 17,1995  :

i W.R. McCollum, being duly swom, 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 these revisions to the Catawba Nuclear Station Ucense 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.  :

t I

't'

~ '

W.R. McCollum, Vice l t

i i

i Subscribed and sworn to before me this 17th day of August,1995.

i 1

~ [

JDeldll5 ts)1YA Notary Public ' 6 i t

My commission expires:  :

h l

i* . 4 Dodanent Control Desk l

' I Page 5 August 17,1995 bxc (with attachments):

A.V. Carr Z.L. Taylor J

. L.J. Rudy S.W. Brown ,

A.S. Bi.4r.egar S.L. Bradshaw i M.J. Brady

. W.E. Green l

M.D. Furtick B.G. Addis l NCMPA-1 i NCEMC PMPA SREC .

Document Control File CN-801.01  :

, Group File CN-801.01 l EILE0050

, 1 1

4 4

J 4

I  !

l 5

l l

4 I

e 6 e

e e

l I

l i

ATTACIIMENT 1 BACKGROUND AND DESCRIFFION OF AMENDMENT REQUESTS

l m-L. -4 =4 h .t.S= or A=r.d.w;;; ReaWe i

Amendment Nos.128 and 122 for Units 1 and 2, respectively, approved by the NRC on February 17,1995, revised TS Table 2.2-1 and TS 4.2.5 to allow a change in the method for measuring RCS flowrate from the calorimetric heat balance method to a method based on a one-time calibrabon of the RCS cold leg elbow differential pressure taps. (Amendments 116 and 110 for Units 1 and 2, respectively, approved this methodology for Unit 1 Cycle 8 operation only.)

In Catawba's original January 10, 1994 application, as amended, Catawba failed to modify SR 4.2.5.2 to delete that portion of the SR which specifies that the measurement instrumentation shall i be calibrated within 7 days prior to the performance of the flowrate measurement. The requirement to calibrate the measurement instrumentation within 7 days prior to the performance of the flowrate measurement is impractical based on utilization of the cold leg elbow pressure tap method of RCS flowrate measurement. Accordingly, SR 4.2.5.2 is hereby modified to reflect the deletion of the subject requirement. No change to the corresponding Bases section of the TS is required.

f 1

i

40 ,

t ATTACIIMENT 2 JUSTIFICATION AND SAFETY EVALUATION 1

l l

l

Justlncatka and Safety Evaluation Prior to the issuance of Amendment Nos. 128/122 (and Amendment Nos.11&l10 for Unit 1 Cycle 8 operation), Catawba performed the 18-month RCS flowrate determination of TS 4.2.5 by utilidng a precision heat balance rnethod of measurement. 'Ihe TS therefore required that the measurement instrumentation be calibrated within 7 days prior to the performance of the flowrate mensurement. 'Ihe only instmmentation that was subject to this requirement was the data logger used to log RCS temperature values. All other parameters used in the determination of RCS flowrate via the precision heat balance method were obtained from the Operator Aid Cna=w (OAC). t

.With the issuance of Amendment Nos. 128/122 (and Amendment Nos.11&l10 for Unit 1 Cycle 8 operation), all data taken in support of the flowrate measurement using the cold leg elbow tap method is now obtained from the OAC. The special test instrumentation used previously, and subject to the 7-day requirement, is no longer used. 'Ihe statement in SR 4.2.5.2 was never intended to apply to the RCS loop flowrate transmitters themselves, as they are calibrated only during refueling outages as seguired by SR 4.3.1.1. It is not desirable to calibrate the flowrate transmitters while the unit is operating due to the potential that exists for a unit trip. Each transmitter on a RCS loop shares an impulse line with the other two transmitters on that loop; henm, if the transmitters were calibrated while the unit were operating, the potential would exist to isolate all three transmitters on a RCS loop simultaneously (isolation of any two transmitters on a loop would result in a unit trip). It is therefore concluded that the statement in SR 4.2.5.2 concerning calibrating the measurement instmmentation within 7 days prior to the performance of j the flownte measurement was never intended to apply to the RCS loop flowrate transmitters. This j TS change is consequently considered an administrative change which should have been made when the January 10, 1994 amendment application pertaining to Amendment Nos. 128/122 (and 11&l10) was made.

Based on the above technical justification, Duke Power Company concludes that it is acceptable to i delete the requirement pertaining to calibration of the subject measurement instrumentation.

4 4

- - - - . . ~ ~ ~ . . . .- . . .- .. .

s- : 6 1

• e I

• I i

l e,

4 4

l l

i i

l, l

J 3

, ATTACHMENT 3 NO SIGNIMCANT IIAZARDS CONSIDERATION DETERMINA110N AND ENVIRONMENTALIMPACT ANALYSIS j

i-i 1

4 d

4 I

r S

(e *o

( .

4 No Significant Hazards Consideration Detennination  !

l As required by 10CFR50.91, this analysis is provided concerning whether the requested amendments involve significant hazards considerations, as defined by 10CFR50.92. Standards for

determination that an amendment request involves no significant hazards considerations are if

operation of the facility in accordance with the requested amendment wouki not

1) Involve a

significant increase in the probability or consequences of an accident previously evaluated; or 2)

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.

Criterion 1 The requested amendments will not involve a significant increase in the probability or consequences of an accident previously evaluated. 'Ihis change is considered administrative in nature and should have been requested in Duke Power Company's January 10,1994 application, as amended. 'Ihe )

instrumentation which was subject to the requirement is no longer utilized in the fulfillment of the 1 TS required RCS flowrate determination. 'Ihe proposed changes will not result in any impact upon accident probabilities, since the RCS flowrate measurement instrumentation is not accident initiating equipment. Likewise, they will not result in any impact upon accident consequences, since no change to any method or frequency of calibratio' n of the RCS flowrate transmitters will result. 'Ihe plant response to accidents will not be affected.

Criterion 2 The requested amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated. No change is being made to any plant design feature, or to the manner in which the plant will be operated. Therefore, no new accident causal mechanisms can be generated. As noted above, the proposed changes are considered administrative in nature, and should have been requested in the January 10,1994 application, as amended.

Criterion 3 The requested amendment will not involve a significant reduction in a margin of safety. No impact upon any fission product barriers will occur as a result of the approval of the proposed changes. No change to plant design, operating, maintenance, or test characteristics will result from the proposed amendments. No impact upon any plant safety margins will result.

EnvironmentalImpact Analysis l

The proposed amendments have been reviewed against the criteria of 10CFR51.22 for l cnvironmental considerations. The proposed amendments do not involve a significant hazards  !

consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or cumulative occupational radiation exposures. Therefore, the pauposed amendments meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.