ML20204F646
| ML20204F646 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/11/1999 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20204F650 | List: |
| References | |
| TAC-MA4948, TAC-MA4949, NUDOCS 9903250334 | |
| Download: ML20204F646 (9) | |
Text
r e-Duk3 Energy Corporation Catawba Nudear Stadon i
=
4800 Concord Road l
York, SC 29745 l
(803) 831-425I OFFICE Gary R. Menon Vice hrsident (803) 831-3426 FM March 11, 1999 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555
Subject:
Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Notice of Enforcement Discretion (NOED) Request Technical Specifications (TS) 3.3.7 (Control Room Area Ventilation System (CRAVS) Actuation Instrumentation) and 3.3.8 (Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) Actuation Instrumentation)
TAC Numbers MA4948 and MA4949 Attached is the written documentation of the background and technical information supporting the Catawba Units 1 and 2 Notice of Enforcement Discretion (NOED) request.
This information was discussed with the NRC staff in a telephone conference call on March 11, 1999.
As discussed in detail in Attachment 1, Catawba is requesting discretion from enforcing TS Limiting Conditions for Operation (LCOs) 3.3.7 and 3.3.8.
These specifications govern the CRAVS and ABFVES Actuation Instrumentation, respectively.
As shown in i
the attached justification, Duke Energy maintains that granting
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of discretionary enforcement in this case is in the best interests of nuclear safety.
This request for enforcement discretion was approved by the Catawba Plant Operations Review Committee (PORC) on March 11, k
1999.
!l 1
Should you have any questions concerning this information, please call L.J.
Rudy at (803) 831-3084.
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'14017 h 9903250334 990311 PDR ADOCK 05000413 p
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Nuclear Regulatory Commission l
Page 2 March 11, 1999 1
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Gary R.
Peterson LJR/s Attachment xc (with attachment):
l 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 P.S.
Tam
.NRC Senior Project Manager (CNS)
U.S. Nuclear Regulatory Commission Mail Stop O-8 H12 Washington, D.C.
20555-0001 V.R. Autry, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201
o Catawba Nuclear Station, Units 1 and 2 Request for Enforcement Discretion TS 3.3.7 (CRAVS Actuation Instrumentation) and 3.3.8 (ABFVES Actuation Instrumentation)
Duke Energy hereby requests that the NRC grant discretion in enforcing TS LCOs 3.3.7 (CRAVS Actuation Instrumentation) and 3.3.8 (ABFVES Actuation Instrumentation) and allow the units to remain in Mode 1 (Power Operation) until an exigent TS change can be submitted and approved to delete the subject TS.
The basis for this proposed deletion is delineated in the discussion below.
- 1. TS violated Catawba is requesting enforcement discretion from TS LCOs 3.3.7 and 3.3.8.
These LCOs govern the CRAVS and ABFVES Actuation Instrumentation, respectively.
LCO 3.3.7, Table 3.3.7-1, CRAVS Actuation Instrumentation, requires two trains of Automatic Actuation Logic and Actuation-Relays.
LCO 3.3.8, Table 3.3.8-1, ABFVES Actuation Instrumentation, also requires two trains of Automatic Actuation Logic and Actuation Relays.
These requirements are applicable in Modes 1, 2,
3, and 4.
Both TS 3.3.7 and 3.3.8 have a set of Surveillance Requirements (SRs),
which consist of an actuation logic test, a master relay test, and a slave relay test.
The actuation logic test and the master relay test have a specified frequency of 31 days on a staggered test basis.
The slave relay test has a specified frequency of 92 days.
As indicated in Item 2 below, these SRs do not physically apply to the CRAVS and ABFVES Actuation Instrumentation at Catawba.
- 2. Circumstances surrounding the situation At Catawba, the CRAVS and ABFVES are actuated by the diesel generator load sequencer, which in turn, is actuated by the Solid State Protection System (SSPS) Automatic Actuation Logic and Actuation Relays.
The CRAVS and ABFVES are not directly actuated by the SSPS.
Catawba TS 3.3.7 and 3.3.8 were based on the standard version of these TS contained in NUREG-1431, Revision 1,
" Standard Technical Specifications, Westinghouse Plants."
The Bases for both NUREG-1431 and the Catawba TS state that the Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for the Safety Injection function.
It also states that the specified conditions for the CRAVS and ABFVES portion of these functions
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are different and less restrictive than those specified for their 1
E
Safety Injection roles.
This Bases discussion is appl ;able for a, plant design that utilizes the SSPS to directly actuate the CRAVS and ABFVES.
As indicated above, at Catawba, the CRAVS and l
ABFVES are actuated by the diesel generator load sequencer, and I
not directly via the SSPS.
Refer to Figure 1 for a simplified depiction of the CRAVS and ABFVES Actuation Instrumentation arrangement.
l Catawba implemented the Improved TS on January 16, 1999.
The above described actuation logic test, master relay test, and slave relay test are not new requirements that were imposed as a result of the conversion to the Improved TS.
They existed in identical technical form in Catawba's previous TS.
It was recognized on March 10, 1999, that these SRs did not apply to the Catawba CRAVS and ABFVES Actuation Instrumentation design, whether under the previous or Improved TS.
Following discovery of this situation, Catawba invoked the 24-hour allowance of SR 3.0.3 for a missed surveillance.
Catawba is requesting enforcement discretion from the LCO requirements of TS 3.3.7 and 3.3.8 until such time that a license amendment can be submitted and approved to delete the subject TS.
Catawba has determined that due to the CRAVS and ABFVES Actuation Instrumentation design, that these TS should not have been included in the Improved TS.
(It was also determined that identical requirements existed in Catawba's previous TS.)
Catawba is proposing to delete TS 3.3.7 and 3.3.8.
The basis for this proposed deletion is fully explained in Item 3 below.
- 3. The safety basis for the request, including the evaluation of the safety significance and potential consequences of the proposed action.
There are no safety consequences associated with this request.
Granting of enforcement discretion will not have any adverse safety impact, as the subject SRs are not applicable to the Catawba CRAVS and ABFVES Actuation Instrumentation design.
TS 3.3.2, Engineered Safety Feature Actuation System (ESFAS)
Instrumentation, contains all the necessary requirements that apply to the Automatic Actuation Logic and Actuation Relays insofar as SSPS testing is concerned.
These requirements are found in Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation under the Safety Injection function (Function 1b in the table, Automatic Actuation Logic and Actuation Relays).
As indicated in the table, an actuation logic test (SR 3.3.2.2), a master relay test (SR 3.3.2.4), and a slave relay test (SR 3.3.2.6) are specified for Function 1b.
These SRs test SSPS actuation of the diesel generator load sequencer.
As
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Fiaure 1 SSPS Cabinet Seouencer input Logic Output Bay Bay Bay Slave CRAVS and Relays 2"
ABFVES
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Systems
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Tested by 4
7300 Input
_i' Cards Master Slave Relay
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Logic NIS Relays Relays Test etc.
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Note: CRAVS and ABFVES Tested by Actuation acttntions tested during outage ESF Test.
Logic Test / Master Relay Test a.
indicated above, at Catawba, the CRAVS and ABFVES are actuated by th.e load sequencer, and not directly via the SSPS.
The automatic start of the CRAVS and ABFVES functions from the load sequencer are performed as part of engineered safeguards testing, which is conducted during refueling outages.
SR 3.7.10.3 requires on an 18-month frequency, verification that each CRAVS train actuates
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on an actual or simulated actuation signal.
SR 3.7.12.3 requires j
on an 18-month frequency, verification that each ABFVES train actuates on an actual or simulated actuation signal.
Therefore, deletion of TS 3.3.7 and 3.3.8 is acceptable, as the EFSAS SSPS testing, in combination with engineered safeguards testing, fully tests all functions from the SSPS, through the load sequencer, and to the CRAVS and ABFVES.
Deletion of TS 3.3.7 and 3.3.8 will not have any adverse consequences insofar as high radiation protection and high chlorine protection requirements are concerned.
At Catawba, there is no control room automatic isolation function on a high radiation signal.
As part of the Improved TS conversion process, operability and testing requirements for the chlorine detectors were relocated from the TS to the Selected Licensee Commitments Manual, which is Chapter 16 of the Updated Final Safety Analysis Report.
No changes to any operability or testing requirements pertaining to the chlorine detectors will occur as a result of this request.
Finally, LCOs 3.7.10 and 3.7.12 contain the necessary requirements for the mechanical portions of the CRAVS and ABFVES, respectively.
These requirements have been and will continue to be met.
In summary, the ESFAS and the CRAVS and ABFVES Actuation Instrumentation are fully capable of fulfilling their required safety function, consistent with the manner in which they were designed.
No decrease in equipment availability or reliability will be incurred as a result of the granting of this request.
Granting of this request will have no impact from a probabilistic risk' standpoint, since there will be no impact on equipment reliability or availability.
- 4. The basis for the licensee's conclusion that noncompliance will not be of potential detriment to the public health and safety and that neither an unreviewed safety question nor a significant hazard consideration is involved.
NRC granting of this request for enforcement discretion will not have any adverse consequences from the standpoint of public health and safety.
As stated previously, there is no impact on equipment reliability or availability associated with the 3
l granting of this request.
Granting of this request will allow co.ntinued operation of Catawba Units 1 and 2 until a license amendment can be submitted and approved which will delete TS 3.3.7 and 3.3.8, as these requirements are not applicable to the Catawba design.
Catawba has determined that clarification l
changes will be required to the Updated Final Safety Analysis Report in conjunction with this request for enforcement discretion.
There are no significant hazards considerations associated with this request for enforcement discretion.
This is demonstrated as follows:
t This request for enforcement discretion does not involve a significant increase in the probability or consequences of an l
accident previously evaluated.
Granting of this request will have no effect on accident probabilities or consequences.
No physical changes are being made to the plant design which will i
result in any increase in accident probabilities.
Granting of thic request will not result in a decrease in system or equipment reliability or availability.
Therefore, there will be no impact on any accident consequences.
This request has no impact on accident sequences found to be risk significant in the Catawba Probabilistic Risk Assessment.
This request for enforcement discretion does not create the possibility of a new or different kind of accident from any accident previously evaluated.
No new accident causal mechanisms are created as a result of the NRC granting of this request for enforcament discretion.
No changes are being made to the plant which will introduce any new accident causal mechanisms.
This request for enforcement discretion does not involve a significant reduction in a margin of safety.
Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation.
These barriers include the fuel cladding, the reactor coolant system, and t'.-
containment system.
The performance of these fission produc' barriers will not be degraded by the NRC's granting of this request.
No safety margins will be impacted.
- 5. The basis for the licensee's conclusion that the noncompliance will not involve adverse consequences to the environment.
This request for enforcement discretion will not result in any changes in the types, or increase in the amounts, of any effluents that may be released offsite.
In addition, no increase j
in individual or cumulative occupational radiation exposures will 4
I be involved.
Therefore, it can_be concluded that the NRC's granting of this request for enforcement discretion will not involve any adverse consequences to the environment.
- 6. Proposed compensatory measures No compensatory measures are required in association with this request, since no actual system or equipment unavailability exists.
- 7. Justification for the duration of the non-compliance The duration of the noncompliance is dependent on the time required to submit and obtain approval of a license amendment to delete TS 3.3.7 and'3.3.8.
As stated in Items 3 and 4, there is no safety significance or potential detriment to the health and safety of the public.
- 8. Statement that the request has been approved by the facility organization that normally reviews safety issues.
l This request was reviewed and approved by the Catawba Plant Operations Review Committee in a special meeting on March 11, 1999.
- 9. How one of the NOED criteria for appropriate plant conditions specified in Section B is satisfied.
]
This request is intended to avoid an undesirable unit shutdown transient as a result of requiring compliance with the TS and, thus, minimize potential safety consequences and operational risks.
11 0. If a follow-up license amendment is required, the NOED request must include marked-up TS pages showing the proposed TS changes.
The marked-up TS pages are attached.
Catawba will submit the license amendment request no later than March 15, 1999.
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i ATTACHMENT l
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l MARKED-UP TS PAGES 1
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