ML20204G370
| ML20204G370 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/17/1999 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-MA4950, TAC-MA4951, NUDOCS 9903260135 | |
| Download: ML20204G370 (6) | |
Text
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of bN Duko EnCrgy Corporction L# Efte g.
Catawba Nudear Stanon 4800 concord Road York, SC 29745 (803) 831-4251 omCE Gary R. Peterson (803) 831-3426Mx Ma nrsident March 17, 1999 U.
S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
Document Control Desk
Subject:
Duke Energy Corporation Catawba Nuclear Station Units 1 and 2 Docket No. 50-413 and 50-414 l
Proposed Amendment to the Facility Operating ~' enses (FOL) and Technical Specifications (TS)
TS 3.3.7, Control Room Area Ventilation System (CRAVS)
Actuation Instrumentation TS 3.3.8, Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) Actuation Instrumentation TS 3.7.10, Control Room Area Ventilation System (CRAVS)
TAC Numbers MA4950 and MA4951
Reference:
Letter from M.
S. Tuckman to NRC, same subject, dated Mar'h 15, 1999 The reference letter transmitted a proposed license amendment to delete TS 3.3.7 and 3.3.8 for the CRAVS and ABFVES Actuation Instrumentation, respectively.
As part of this amendment request, Catawba proposed to include a modifying note as part of TS 3.7.10, CRAVS, Required Action A.1.
This note would require placing the system in the high chlorine protection mode whenever the automatic transfer to the high chlorine protection mode is inoperable.
Based on further examination of this note within Duke Energy and following discussions with the NRC, it has been determined that the addition of this note is unnecessary.
Catawba therefore requests that that portion of the reference letter which proposed I
the addition of this note to Required Action A.1 of TS 3.7.10 be j
l withdrawn.
The revised pages of the Discussion of Changes and i
Technical Justification and the Environmental Assessment from the reference letter are attached.
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U.S. Nuclear Regulatory Commission March.17, 1999 P' age 2 If you have any questions concerning this information, please call L. J.
Rudy at (803) 831-3084.
Very truly you sv4b25' G. R.
Peterson Attachment xc:
w/ attachment L. A. Reyes U.
S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 P.
S. Tam NRC Senior Project Manager (CNS)
U.
S. Nuclear Regulatory Commission Mail Stop O-8 H12 Washington, DC 20555-0001 D. J. Roberts Senior Resident Inspector (CNS)
U. S. Nuclear Regulatory Commission Catawba Nuclear Site V. R. Autry, Director, Division of Radioactive Waste Management Bureau of Land and Waste Management South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 i
Description of Changes and Technical Justification TS 3.3.7 and 3.3.8 govern the CRAVS Actuation Instrumentation and the-ABFVES Actuation Instrumentation, respectively.
TS 3.3.7, Table 3.3.7-1, CRAVS Actuation Instrumentation, requires two trains of Automatic Actuation Logic and Actuation Relays.
TS 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.
TS 3.3.7 and 3.3.8 each has a set of Surveillance Requirements (SR), which consist of an actuation logic a
master relay test, and a slave relay test.
The actuati 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 frequer;cy of 92 days.
As discussed below, these SRs do not apply to the Catawba CRAVS and ABFVES Actuation Instrumentation design.
TS 3.7.10 governs the CRAVS itself and-TS 3.7.12 governs the ABFVES itself.
This LAR requests deletion of TS 3.3.7 and 3.3.8 cnd addc n note te ncquired Action A.1 of TS 3.7.10 concerning placing the CRA"S in th: high chlorinc protection m;d if the cutcmatic trancftr t0 the high chlorinc protection mcdc ic inspcrnble.
The circumstances surrounding this LAR were discussed with the NRC in a request for enforcement discretion which the NRC granted on March 11, 1999.
This LAR is the formal amendment request made in follow up to the request for enforcement discretion.
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 came 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 are different and less restrictive than those specified for their Safety Injection roles.
This Bases discussion is applicable for a' plant design that utilizes the SSPS to directly actuate the CRAVS and ABFVES.
As indicated above, at Catawba, the CRAVS and ABFVES are actuated by the diesel generator load sequencer, and
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not directly via the SSPS.
Refer to Figure 1 for a simplified depiction of the CRAVS and ABFVES Actuation Instrumentation arrangement.
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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.
Catawba is proposing to delete TS 3.3.7 and 3.3.8.
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 lb 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 lb.
These SRs test SSPS actuation of the diesel generator load seqtancer.
As indicated above, at Catawba, the CRAVS and ABFVES art actuated by the 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 on an actual or simulated actuation signal.
SR 3.7.12.3 requires 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 i
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 LAR.
AC part Of thic LAn, it ic neccccary to add a notc to ncquired Action A.1 cf TS 3.7.10 concerning action to takc if the automatic transfer to the high chlcrinc prctcction =cdc is incperabic.
Addition of thic note ic neccccary to encure that it applics tc Mcdcc 1 through 4.
An identical note ic circady precent in ncquired Action C.1 cf TS 3.7.10, which is applicabic in Mcdc 5 cr 5, cr during =cvement of irradicted fuel acccablics, cr during cerc alteratienc.
Addition of thic note te ncquired
r.
p t.
..ction.'. 1 will ensure thct it cpplica during all mcdcc cnd ccaditienc cf cpplicability for TS 3.7.10.
Finally,.LCOs 3.7.10 and 3.7.12 contain all other necessary requirements for the mechanical portions of the CRAVS and ABFVES, respectively.
In summary, the ESFAS and the CRAVS and ABFVES Actuation Instrumentation will remain 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 approval of this LAR.
Approval of this LAR will have no impact from a probabilistic risk standpoint, since there will be no impact on equipment reliability or availability.
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Pursuant to 10 CPR 51.22(b), an evaluation of this license amendment request has been performed to determine whether or not it me ts the criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) of the regulations.
j This amendment to the Catawba TS deletes TS 3.3.7 and 3.3.8 concerning the CRAVS and ABFVES Actuation Instrumentation, respectively, and adds a notc regarding chlcrinc prctcction tc TC l
3.7.10 concerning the Cn.'.VC itself.
l Implementation of this amendment will have no adverse impact upon the Catawba units; neither will it contribute to any additional quantity or type of effluent being available for adverse i
environmental impact or personnel exposure.
l It has been determined there is:
1.
No significant hazards consideration.
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No significant change in the types, or significant increase in the amounts, of any effluents that may be released
-offsite, and 3.
No significant increase in individual or cumulative occupational radiation exposures involved.
Therefore, this amendment to the Catawba TS meets the criteria of 10 CFR 51.22 (c) (9) for categorical exclusion from an environmental assessment / impact statement.
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