ML20137C945

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Requests Addl Info Re Proposed TS Change Re PORVs to Be Submitted on Schedule Consistent W/Urgency of Need for Requested Amends
ML20137C945
Person / Time
Site: Catawba  
Issue date: 03/24/1997
From: Tam P
NRC (Affiliation Not Assigned)
To: Mccollum W
DUKE POWER CO.
References
TAC-M98107, TAC-M98108, NUDOCS 9703250187
Download: ML20137C945 (6)


Text

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Mr. William R. McCollum Site Vice President Catawba Nuclear Station Duke Power Company 4800 Concord Road York, South Carolina 29745-9635

SUBJECT:

CATAWBA NUCLEAR STATION - PROPOSED TECHNICAL SPECIFICATION CHANGE REGARDING THE POWER-0PERATED RELIEF VALVES (TAC N0. M98107 and M98108)

Dear Mr. McCollum:

By letter dated March 7, 1997, Duke Power Company submitted proposed amendments for Catawba Nuclear Station to revise Section 3/4.7.1.6 of the Technical Specifications, and Section 15.6.3 of the Updated Final Safety Analysis Report to require four instead of three steam generator power-operated relief valves (PORVs) operable, and allowing credit for local operation of the PORVs. The staff has completed its initial review and determined that additional information, as identified in the enclosure, is needed.

We request that you provide the additional information on a schedule consistent with the urgency of the need for the requested amendments.

If you or your staff need additional time to respond, or clarification of the questions, please contact me at 301-415-1451.

Sincerely, Original signed by:

Peter S. Tam, Senior Project Manager Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414

Enclosure:

Request for Additional Information cc w/ encl:

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March 24, 1997 Mr. William R. McCollum Site Vice President Catawba Nuclear Station i

Duke Power Company 4800 Concord Road York, South Carolina 29745-9635

SUBJECT:

CATAWBA NUCLEAR STATION - PROPOSED TECHNICAL EPECIFICATION CHANGE RidARDING THE POWER-0PERATED RELIEF VALVES (TAC NO. M98107 and M98108)

Dear Mr. McCollum:

By letter dated March 7, 1997, Duke Power Company submitted proposed amendments for Catawba Nuclear Station to revise Section 3/4.7.1.6 of the Technical Specifications, and Section 15.6.3 of the Updated Final Safety Analysis Report to require four instead of three steam generator power-operated relief valves (PORVs) operable, and allowing credit for local operation of the PORVs. The staff has completed its initial review and determined that additional information, as identified in the enclosure, is needed.

We request that you provide the additional information on a schedule consistent with the urgency of the need for the requested amendments.

If you or your staff need additional time to respond, or clarification of the questions, please contact me at 301-415-1451.

Sincerely, M

i Peter S. Tam, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414

Enclosure:

Request for Additional Information cc w/ enc 1: See next page

1 Duke Power Compr.ny Catawba Nuclear Station ec:

i Mr. M. S. Kitlan North Carolina Electric Membership Regulatory Compliance Manager Corporation i

Duke Power Company P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident Inspector i

Mr. Paul R. Newton 4830 Concord Road Legal Department (PB05E)

York, South Carolina 29745 Duke Power Company 422 South Church Street Regional Administrator, Region II Charlotte, North Carolina 28242-0001 U. S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 J. Michael McGarry, III, Esquire Atlanta, Georgia 30323 Winston and Strawn 1400 L Street, NW Max Batavia, Chief Washington, DC 20005 Bureau of Radiological Health South Carolina Department of North Carolina Municipal Power Health and Environmental Control Agency Number 1 2600 Bull Street 1427 Meadowwood Boulevard Columbia, South Carolina 29201 i

P. O. Box 29513 Raleigh, North Carolina 27626-0513 Mr. G. A. Copp Licensing - EC050 Mr. Peter R. Harden, IV Duke Power Company j

Account Sales Manager 526 South Church Street Westinghouse Electric Corporation Charlotte, North Carolina 28242-0001 Power Systems Field Sales P. O. Box 7268 Saluda River Electric Charlotte, North Carolina 28241 P. O. Box 929 Laurens, South Carolina 29360 County Manager of York County York County Courthouse Ms. Karen E. Long York, South Carolina 29745 Assistant Attorney General North Carolina Department of Justice Richard P. Wilson, Esquire P. O. Box 629 Assistant Attorney General Raleigh, North Carolina 27602 South Carolina Attorney General's Office Elaine Wathen, Lead REP Planner P. O. Box 11549 Division of Emergency Management Columbia, South Carolina 29211 116 West Jones Street Raleigh, North Carolina 27603-1335 Piedmont Municipal Power Agency 121 Village Drive Dayne H. Brown, Director Greer, South Carolina 29651 Division of Radiation Protection N.C. Department of Environment, Mr. T. Richard Puryear Health and Natural Res-)urces Owners Group (NCEMC)

P. O. Box 276B7 Duke Power Comaany Raleigh, North Carolina 27611-7687 4800 Concord f.oad York, South Carolina 29745

c, REQUEST FOR ADDITIONAL INFORMATION REGARDING CATAWBA NUCLEAR STATION UNITS 1 AND 2 PROPOSED AMENDMENTS REGARDING THE STEAM GENERATOR PORVs

Reference:

Letter, W. R. McCollum to NRC, March 7, 1997 l

1.

Provide a dose assessment of the consequences, with respect to Part 100 and GDC 19, of operating in the proposed new configuration which

. requires manually opening one of the-PORVs of the intact steam generators.

2.

The steam generator tube rupture information provided as draft Updated Final Safety Analysis Report (UFSAR) markups is incomplete relative to what.is currently in the UFSAR. Provide the assumstions used in the new steam generator tube rupture (SGTR) analysis and tie sequence of events.

o including an explanation of each assumption that is different from the current analysis of record and a discussion of the effect of the change on the parameters analyzed.

Include a discussion of the old and new s

overfill analysis, delay times.resulting from the need for local manual operator action and the effects of these delay times, initial steam generator level, final level, margin to overfill, primary and secondary system response, and primary-to-secondary' leakage flow rates.

t 3.

In the submittal, the BTP RSB 5-1 criteria were used to' justify local manual operator action of the steam generator PORV during the SGTR.

scenario. The SGTR and the BTP RSB 5-1 scenarios are quite different.

Can local manual operation of the PORV during a SGTR accident be -

j justified without reliance on the more lax criteria of BTP RSB 5-17 j

4.

On page 15-100 of the FSAR, in the last paragraph, the text is changed from "... bounded by feedwater line break coastdown transient from an elevated RCS temperature...." to " complete loss of flow." This change needs explanation.

5.

The second paragraph of Technical Justification and Safety Analysis states:

"In Case 2 above, it was demonstrated that S/G overfill occurs.* What are assumed and demonstrated times for Case 27 6.

On the same page, the licensee states:

,.. leaving only one PORV on an intact S/G available to be remotely operated from the control room.

Local manual operation of another PORV on an intact S/G with a time i

delay is credited in this analysis."

a.

Specify the required operator actions and times associated with the local manual operation.

b.

Clarify the phrase "a time delay is credited."

7..

On the same page, last paragraph, the licensee states:

"Therefore, to

1 1

I-avoid S/G overfill in light of the single failures identified herein, i

credit must be assumed for local manual operation of a PORV on at least one intact S/G."

i a.

State assumptions relative to where an operator (s) will be located j

prior to taking local manual operation.

i i

b.

Describe the steps and times usociated with briefing the 1

operator (s) and ultimately taking the. local manual action, including:

l o

the specific operator actions required, t

o potentially harsh or inhospitable environmental conditions j

expected,

)

1 a general discussion of the ingress / egress paths taken b'y o

i the operators to accomplish. functions, o

procedural guidance for required actions, o

specific operator training necessary to carry out actions including any operator qualifications required to carry out i

actions, i

t i

o any additional support personnel and/or equipment required j.

by operator to carry out actions, o

description of information required by the control room stafftodeterminesuchoperatorac}ionisrequired, j

including qualified instrumentation used to diagnose the situation and to verify that the required action has been successfully.taken, j

a o

ability to recover from plausible errors in performance of j

manual actions, and the expected time required to make such a recovery.

3-o How do operator (s) become aware that there is a need for j

local manual action?

I i

I o

What is the total time for operator (s) to complete local manual action assuming time zero is notification that such i

local manual action is needed?

l o

Describe task analysis used to determine sequence of local manual actions.

1 In accordance with RG 1.97, " Instrumentation for Light Water cooled Nucteer Power Plants to Assess Plant and Environs Conditions During and Following on Accident," revision 3,1963, qualification of the i

instrumentation rolled won by the operators may be en luportant review issue. RG 1.97, defines Type A verlebtes as: "those verlebles to be monitored that provide the primary information required to permit the

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control room operator to take specific manually controlled actions for which no automatic control is provided j

l

- and that are required for eefety systems to accomplish their furetions for design bests accident events." -

o o'

How were R.G. 1.97, Generic Letter 91-18, and ANSI /ANS 58.8 considered in the analysis of operator actions and times?

o Discuss how many operators will perform the local manual i

action (s).

~

o Discuss errors of omission and commission considered in analyzing required local manual actions.

4 c.

What immediate compensatory measures has the licensee taken relative to the amendment request?

i 8.

On the same page, the last paragraph, the licensee states:

"Both time trials and simulator tests have been performed to show that operators can begin local manual operation of a S/G PORV and otherwise respond as assumed in the safety analysis."

a.

Provide information on time trials and simulator test results.

b.

Consider simulator tests for at least 80 percent of plant operators.

4 9.

Discuss the necessity for and your commitment to update the SGTR analysis information (e.g., operator actions and times) provided to the staff that was used as the basis for its findings and conclusions in the safety evaluation dated May 14, 1991.

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