ML20196L179
| ML20196L179 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 05/20/1999 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9905270121 | |
| Download: ML20196L179 (4) | |
Text
h r~]
Duke Energy Corporation L.
1 M2 526 South Church Sinxt
=
EO. Box 1006 (EC07H)
Charlarre, NC 28201-1006 M. S. Tuciunnn (704)382-2200 omcr Executin Vice Prnident (704)382-4360 MX Nuclear Generation
- May 20, 1999 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Licensing Position Regarding Snubbers i
The purpose of this letter is to communicate to the NRC Office of Nuclear Reactor Regulation (ONRR) a licensing position regarding inoperable snubbers.
Duke Energy Corporation has determined that the structure of the Improved Technical Specifications (ITS) has resulted in certain confusion regarding the treatment of inoperable snubbers.
This licensing position clarifies the issue and will be reflected in revised Bases for the snubber Selected Licensee Commitments (SLCs).
Background:
Prior to the implementation of the ITS at Catawba and McGuire, the previous TS for both plants contained a TS governing snubbers.
This TS stated that all snubbers shall i
be operable with the exception.of snubbers installed on non safety-related systems and then only if their failure or
\\
failure of the system on which they are installed would O
have no adverse effect on any safety-related system.
The TS further stated that with one or more snubbers inoperable, the inoperable snubber (s) must be replaced or 0k j
restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and an 9
engineering evaluation must be performed per the Functional Test Failure Analysis provision of the TS on the attached component.
Alternatively, the attached system must be r
9905270121 990520 PDR ADOCK 05000369 P
PD g
u
e-1 j
j U.S. Nuclear Regulatory Commission Page 2' May 20, 1999 declared inoperable and the appropriate action statement for that system must be followed.
The previous TS for Catawba and McGuire were based on the model TS contained in NUREG-0452, " Standard Technical Specifications for Westinghouse Pressurized Water Reactors."
Under the snubber TS, Catawba and McGuire had always taken the position that since snubbers had their own separate TS, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for inoperable snubbers could be utilized before having to declare any supported I
components or systems inoperable as a result of inoperable snubbers.
This position was consistent with the position taken by many other plants with similar snubber TS.
In 1997, Catawba and McGuire submitted a license amendment request to convert their TS to the ITS, based on the model contained in NUREG-1431, Revision 1,
" Standard Technical Specifications, Westinghouse Plants."
Since the ITS NUREG does not include a TS for snubbers, the snubber TS was reloca'ted in its entirety to the respective station SLC i
Manual.
The SLC Manual is Chapter 16 of the respective station's Updated Final Safety Analysis Report (UFSAR).
No changes were made to any technical requirements of the snubber TS in conjunction with its relocation to the SLC Manual.
This treatment in the ITS submittal indicates that
)
the relocation of snubber requirements from the TS to the SLC Manual was meant to be an administrative change and not a substantive (technical) change.
The NRC subsequently approved the ITS submittal for both stations and ITS was implemented at McGuire in November 1998 and at Catawba in January 1999.
The Catawba and McGuire ITS contain a new Limiting Condition for Operation (LCO) which governs the relationship between support and supported systems, LCO 3.0.6.
LCO 3.0.6 states, in part:
"When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.
Only the support system LCO ACTIOtlS are required to be entered.
This is an exception to LCO 3.0.2 for the supported system.
j
y
.a-t
[
' U.S. Nuclear Regulatory Commission Page 3 l-May 20.,
1999 E
- The rationale behind LCO 3.0.6 is that the' required actions for the support system provide' sufficient remedial measures.
Details of Licensing Position:
LCO 3.0.6 only applies to those support systems which have their.own TS.
For support systems which are not in TS, it is Duke' Energy Corporation's understanding that when a supported system is made inoperable due to a non-TS support l
system being inoperable, the TS conditions and required actions for the supported system are' required to be immediately entered.
However, it is Duke Energy.
Corporation's position that.the snubber SLC is applicable L
in the same manner as the snubber TS was used before ITS l
implementation.
The ITS submittal did not include any l
information to indicate that snubbers should be treated any differently under ITS than they were treated under the old TS..
Additionally, there was no information contained in l
the NRC's Safety Evaluation for the Catawba and McGuire ITS license amendments that would indicate that any change in L
the treatment of snubbers was warranted.
It is Duke. Energy l
Corporation's understanding that this position is l
consistent with the position taken by other plants that have implemented ITS.
If you have any: questions concerning this issue, please contact L.J. Rudy at (803) 831-3084.
Very truly yours,
= - - _ -
M.S. Tuckman i
LJR/s-l i
i
c-U.S. Nuclear Regulatory Commission Page 4 May,20, 1999 XC:
L A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 D.J. Roberts Senior Resident Inspector (CNS)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station S.M. Schaeffer Senior Resident Inspector (MNS)
U.S. Nuclear Regulatory Commission McGuire Nuclear Station P.S. Tam NRC Senior Project Manager (CNS)
U.S. Nuclear Regulatory Commission Mail Stop 08-H12 Washington, D.C. 20555-0001 F. Rinaldi NRC Senior Project Manager (MNS)
U.S. Nuclear Regulatory Commission Mail.Stop Old-H25 Washington, D.C.
20555-0001 1
l i