ML20205L112
| ML20205L112 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/24/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20205L116 | List: |
| References | |
| GL-84-15, IEIN-84-69, NUDOCS 8604030163 | |
| Download: ML20205L112 (5) | |
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DUKE POWER GOMPANY P.O. DOX 33189 CitARLOTTE, N.C. 28242 ^
HALB. TUCKER TELEPHOM vwa reessment (704) 373-4538
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March 24, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. B. J. Youngblood, Project Director PWR Project Directorate No. 4 Re: Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Technical-Specification Amendment for Diesel Generators
Dear Mr. Denton:
This letter contains proposed amendments to the Technical Specifications for Facility Operating License Nos. NPF-35 and NPF-48 for Catawba Units 1 and 2.
The attachment contains the proposed changes and a discussion of the justification and safety analysis. The analysis is included pursuant to 10 CFR 50.91 and it has been concluded that the proposed amendments do not involve significant hazards considerations.
. A similar request was previously submitted on July 31, 1985 for Catawba's Unit 1 Technical Specifications. Part of that requested amendment was granted concerning allowance of an engine prelube and warmup prior to starting the diesel. The remainder of the previously requested changes are being resubmitted. The changes contained within this request are slightly different than those previously submitted. This is a result of a better understanding of the intent of Generic Letter 84-15 and recently reviewed Specifications for the Perry Nuclear Plant. Requested changes to Table 4.8-1 and the ACTION statements are in keeping with Generic Letter 84-15 and IE Information Notice 84-69, Supplement 1.
The other changes would provide flexibility to station personnel for testing purposes and for maintaining adequate levels of fuel oil in the fuel oil storage tanks.
This request is applicable to both units, accordingly, pursuant to 10 CFR 170.21 a check for $150.00 is enclosed.
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l Mr. Hars1d R. Dantsn, Dirsetcr March 24, 1986 Page Two 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, s /b M "W y
Hal B. Tucker RWO: sib Attachment xc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Connaission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Heyward Shealy, Chief Bureau of Radiological Health South Carolina Department of Health &
Environmental Control 2600 Bull Street Columbia, South Carolina 29201 INPO Records Center Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 American Nuclear Insurers e/o Dottie Sherman, ANI Library The Exchange, Suite 245 270 Farmington Avenue Farmington, CT 06032 M&M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 Mr. P. H. Skinner NRC Resident Inspector Catawba Nuclear Station
' Mr. Harcld R. Denten, Dircct:r
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March 24, 1986 Page Four HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the Catawba Nuclear Station Technical Specifications Appendix A to License No. NPF-35 and NPF-48; and that all statements and matters set forth therein are true and correct to the best of his knowledge.
g /k y Hal B. Tucker, Vice President Subscribed and sworn to before me this 24th day of March, 1986.
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JUSTIFICATION AND ANALYSIS 0F NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes to the ACTION statements and to Table 4.8-1~are in accordance with the Staff's guidance outlined in Generic Letter 84-15 and those Technical Specifications approved for the North Anna and Perry Nuclear Plants. These changes would reduce the number of diesel generator test starts currently required in the Catawba U its 1 and 2 Technical n
Specifications. The intent of the changes are to improve and maintain diesel
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generator reliability by. reducing the required number of tests conducted on the diesels. By limiting the number of teats required, the diasels will be subjected to less wear. with less potential for engine failure due to too frequent testing.
The proposed changes t'o 3.8.1.lb.1), b.2), 3.8.1.2b.1) and b.2) reflect new fuel oil storage requirements based upon the 5750 kw rating for the diesel generators. The original fuel oil volumes were calculated based upon the diesels' original rating of 7000 kw.
The NRC Staff's Supplement 4 to the Catawba SER discusses the change in the rating of the diesel generators.
The new limit of 5750 kw for each diesel is adequate to cover all necessary LOCA and blackout loads. There are no current plans to return the diesels' ratings back up to 7000 kw since the lower ratings are adequate and also cause less wear during testing.
If, in the future, it is desired to upgrade the diesels to their original ratings -the Technical Specification requirements will be revised accordingly. The proposed fuel oil storage volumes were derived from actual fuel consumption rates with the diesels operating at 5750 kw.
ANSI N195-1976, " Fuel Oil Systems For Standby Diesel Generators", Section 5.4 was used as guidance in calculating the minimum storare requirements.
The proposed changes to Specifications 4.8.1.1.lb. and 4.8.1.1.2g. are to allow certain Surveillances to be conducted during unit operation.
Currently, all of these Surveillances are required to be performed during shutdown.- These Surveillances were intended to be performed during shutdown because the Surveillance testing would not allow the diesels to start upon receipt of a valid actuation signal. This is true only for those Surve111ances proposed to be conducted during shutdown [i.e. 4.8.1.1.2g.1),
4), 6), 7), 8), 9) and 10)]. During performance of the other Surveillance tests an override signal would be generated and the diesels would be capable of carrying out their intended functions. Those particular Surveillances 4.8.1.1.lb., 4.8.1.1.2g.2), 3), 5), 11), 12), 13) and 14). The effect are:
of this change would be additional flexibility in scheduling Surveillances and the ability to do cert ~ain. tests at times other than during outages.
10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations 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 significant reduction in a margin of safety.
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. None of the proposed amendments increase the probability or the consequences of an accident previously evaluated. The change in the fuel oil volumes is administrative in nature and maintains the _ required volume of fuel oil assraed in the safety analysis.
Changes in the ACTION statements and Table 4.2-1 will not have any affect on any previously analyzed accidents since there will be no changes to any of the assumptions used in the analyses. The
. changes to the Surveillances conducted during shutdown will likewise not affect any previously evaluated accidents in that the diesels will still be capable of performing their intended safety functions if called upon.
The proposed amendments do not create.the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes introduce no new mode of plant operation and no physical modifications are required to be performed to the plant.
The proposed changes do not involve a significant reduction in a margin of safe ty.
The changes to the ACTION statements and Table 4.8-1 are intended to increase the.. diesel generators reliability and thus result in an increase in the overall margin of safety. The new fuel oil volumes are ccasistent with the current assumptions in the safety analysis and therefore do not decrease the margin of safety assumed. The changes to the Surveillances required during shutdown would not decrease a margin of safety. The tests would still be conducted at least once per 18 months as is currently required. The diesels would continue to be able to carry out their intended safety functions during these tests. Therefore, no reduction in a margin of safety would result if these tests were allowed to be conducted during unit operation.
Based upon the above discussion, Duke Power concludes that the proposed changes to the diesel ;;.cerator Technical Specifications do not involve.
significant hazards co991derations.
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