ML20128E625

Forwards Proposed Amends to Licenses NPF-35 & NPF-52, Removing License Conditions 2.C(12)(a) & 2.C(8)(a) Which Require That Util Provide Qualified Accumulator Discharge Instrumentation Prior to Startup Per NRC 920408 Request

ML20128E625
Person / Time
Site:	Catawba
Issue date:	12/02/1992
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212080137
Download: ML20128E625 (8)

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1. 00 Cons orJ Road (M3]M3IJ:05 0fike Wik SC 29745 (M3)olJ426 fu DUKE POWER December 2,1992  ;

I U. S. Nuclear Regulatory Commission A"lTN: Document Control Desk '

Washington, D. C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2  :

Docket Nos. 50-413 and 50-414 Operating License Amendments Accumulator Tank Level and Pressure Instrumentation Attached are proposed license amer.dments to the Catawba Nuclear Station Facility- l Operating Licenses for Units 1 and 2, NPF-35 and NPF-52, respectively.

The attachment outlines proposed amendments that would remove license conditions 2.C.(12)(a) and 2.C.(8)(a) from operating licenses NPF-35 and NPF 52 respectively.

These license conditions require Duke Power to provide qt.alified accumulator discharge -

instrumentation prior to startup following the seventh refueling outage for Unit 1 and prior 1 to startup following the sixth refueling outage for Unit 2. Removal of these license conditions is based on an April 8,1992 letter from the NRC, as supplemented on April 27, 1992, which states that the NRC has concluded that Regulatory Guide 1.97, Rev 2, Category 3 qualified instrumentation is acceptable for cold leg accumulator level and ,

pressure monitoring instrumentation. As indicated in Catawba FinalSafety Analysis Report Section 1.8.1.29, the current Catawba cold leg accumulator instrumentation meets the-requirements for Regulatory Guide 1.97, Revision 2, Category 3 instrumentation.

Pursuant to 10 CFR 50.91 (b)(1) the appropriate South Carolina State Official is being provided a copy of this amendment request.

Very truly yours, 9

i( h (W$$vwr M. S. Tuckman CRL/LICCND.CLA Attachment 0 7 n O 8 3--

9212000137 921202 . A D}

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U. S. Nuclear Regulatory Commission -;

December 2,1992 Page 2 xc: Mr. S. D. libneter Regional Administrator, Region 11 >

U. S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 -i Atlanta, Georgia 30323 Mr. licyward Shealy, Chief Ilureau of RadiologicalIIcalth South Carolina Department of IIcalth & Environmental Control 2600 llull Street Columbia, South Carolina 29201 American Nuclear Insurers e/o Dottie Sherman, ANI Library The lixchange, Suite 245 270 Farmington Avenue Farmington, CT 06032 M & M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 INPO Records Center Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 Mr. W. T. Orders NRC Resident inspector Catawha Nuclear Station Mr. R.11. Martin Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop 9113 Washington, D. C. 20555

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U S. Nuclear Regulatory Commission December 2,1992 Page 3 I

M. S. Tuckman, being duly sworn, states that he is Vlec President of Duke Power l Company, Catawba Nuclear Site; that he is authorized on the part of said Company to sign l and file with the Nuclear Regulatory Commission this revision to the Catawba Nuclear Station Facility Operating 1.icense, 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.

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M. S. Tuckman, Vice President Subscribed and sworn to before me this P' day of bN , 1992.

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I NITACHh1ENT l DUKE POWER COMPANY CATAWBA NUCLEAR SI'ATION, UNITS 1 AND 2 i Proposed License Amendments To  :

Facility Operating Licenses NPP-35 And NPF-52 License Conditions 2.C.(12)(a) And 2.C.(8)(a) 9 T.

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t Requested Aniendments Remove Facility Operating License NPF 35 License Condition 2.C.(12)(a) which reads as follows:  ;

Prior to startup following the seventh refueling outage, Duke Power Company '

shall provide qualified accumulator discharge instrumentation.

Remme Facility Operating License NPF-52 License Condition 2.C.(8)(a) which reads as follows:

Prior to startup following the sixth refueling outage, Duke Power Company shall provide qualified accumulator discharge instrumentation. ,

llackground Supplement I to NUREG-0737 - Requirements for Emergency Response Capability -

(Generic Letter 82 33) included additional clari0 cation regarding Regulatory Guide 1.97, Revision 2. 13y letter dated September 26, 1983, Duke Power Company provided the information concerning the exceptions to conformance to the regulatory guide. Pending completion of the Staff's review of the Catawba design for conformance to the guidance of the regulatory guide, the operating licenses for Catawba Unit I and Unit 2 were conditioned to require that modi 0 cations be completed to provide compliance with the regulatory guide unless the exceptions were reviewed and approved by the staff before startup following the first refueling outage.

The items identified were:

(a) Reactor coolant system cold leg water temperature (b) Containment sump water level (c) Residual heat removal heat exchanger outlet temperature (d) Accumulator tank level and pressure

-(e) Steam generator pressure (f) Containment sump water temperature (g) Chemical and volume control system makeup flow and letdown flow (h) Emergency ventilation damper position (i) Area radiation (j) Plant airborne and area radiation 7

Ms. Elinor G. Adensam's-letter of August 6,1985 transmitted a draft Technical Evaluation Report (TER) regarding Catawba's conformance to Regulatory Guide 1.97, Rev. 2. The TER also requested additional justification for some of the exceptions

taken by Duke. Ily letter dated October 22, 1985, Duke provided the requested information. In Supplement 5 to the Catawba Safety Evaluation Report dated February 1986, the Staff approved all of the cucptions except for accumulator level and pressure, requiring that Duke designate either level or pressure as the key variable to be upgraded. This position was incorporated into the operating license (NPF-35) for Catawba Unit 1 on January 17, 1985 and into the operating license (NPF 52) for Catawba Unit 2 on hiay 15, 1986.

Ily letter dated March 25,1986, Duke requested additional technicaljusti6 cation from the Staffin order for Duke to be able to r, valuate the merits of the Staff's requirement.

The NRC's letter dated July 27,1990 responded to Duke's March 25,1986 letter by stating that the Staff was continuing to generically review the need for environmentally qualified Category 2 instrumentation to monitor accumulator tanle ': vel and pressure.

This letter also steed that no further plant speci6c action was quired and that the NRC would inform Duke as to whether or not the existing Catawba instrumentation is acceptable when the generic review was completed.

in a letter dated April 8,1992, the NRC provided Catawba with a Safety Evaluation entitled " Accumulator Pressure and Level Instrumentation: Relaxation of Regulatory Guide 1.97 Environmental Quali0 cation Requirements". This evaluation concluded that Category 3 qualined accumulator instrumentation was acceptable and that Catawba could apply for removal of the accumulator level and pressure instrumentation license conditions. As indicated in Catawba Final Safety Analysis Report Section 1.8.1.29, the current Catawba cold leg accumulator instrumentation meets the requirements for Regulatory Guide 1.97, Revision 2, Category 3 instrumentation.

Disemslon The primary function of the accumulator pressure and level instrumentation is to monitor the pre-accident status of the accumulators to assure that this passive safety system is in a ready state to serve its safety function. The only safety function of the accumulator tank is to empty upon rapid, uncontrolled depressurization of the primary .

system. Accumulator tank level and pressure are not referenced in any emergency procedure covering design basis events which may cause a harsh environment. No operator actions in these procedures are based on accumulator indications. The only operator action involving the accumulator portion of the Safety Infection System is to .

isolate the accumulator when the primary system pressure is below 1000 psig and primary system conditions indicate that the accumulator inventory is not needed to make up lost Reactor Coolant System volume. That action is based on system pressure for which fully quali6ed instruments are provided (see variable sheet A-1, from the original response to RG 1.97).

Cold leg accumulator tank pressure is used in certain emergency procedures which deal with events beyond the design basis of Catawba. These procedures are EP/lC5, r 1 oss of Emergency Coolant Recirculation,- EP/2B1, Inadequate Core Cooling, and

I EP/2112, Degraded Core Cooling, in these procedures, accumulator pressure is used to determine when to isolate the accumulator after it has emptied. in an internal NRC ,

document,11. B. Clayton to D. L. Ziemann, " Meeting Summary, Westinghouse 6 Owners' Group and Westinghouse Emergency Operating Procedures Guidelines,"

February 24,1982, the NRC acknowledged that "for some accident sequences, non-safety-grade equipment and instrumentation is needed and this is reDected in the guidelines." The use of cold leg accumulator pressure is in accordance with this [

philosophy.

Therefore, it is Duke's position that the accumulator tank level and pressure are not key variables for any design basis events which result in harsh environment.

Providing environmental qualification for the post accident in-containment harsh environment is not necessary in that these instruments have no post-accident monitoring function.

Safety Analysis The primary function of the accumulator pressure and level instrumentation is to monitor the preaccident status of the accumulators to assure that the passive safety system is in a ready state to serve its safety function. Accumulator tank level and pressure are not referenced in any emergency procedure covering design basis events which may cause a harsh environment. No operator actions in these procedures are based on accumulator indications, it is therefore Duke Power Company's conclusion that the use of Category 3 qualified accumulator pressure and level instrumentation does not involve any adverse safety considerations.

Analysis of Significant liarards Consideration 10 CFR 50.92 states that a proposed amendment involves no signincant hazards consideration if operation in accordance with the proposed amendment would 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 signincant reduction in a margin of safety.

The proposed amendment would not involve a signincant increase in the probability or consequences of an accident previously evaluated because the accumulator level and pressure indications are provided for preaccident monitoring of the status of the cold-leg accumulators and as such have no effect on cause mechanisms.

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j The proposed amendment does not create the possibility of a new or different kind of  !

accident from any accident previou ly evaluated. This proposed Technical .

Specification change will not cause any physical changes to the plant and the design i and operation of the unit will not be affected. .

i The proposed amendment would not cause a significant reduction in a margin of safety. The current Category 3 instrumentation is fully qualified for its intended function of preaccident monitoring of the cold leg accumulators.

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