ML20205N212
| ML20205N212 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/08/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20205N210 | List: |
| References | |
| NUDOCS 9904160187 | |
| Download: ML20205N212 (4) | |
Text
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t UNITED STATES j
E NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20666 4 001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 177 TO FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO. 169 TO FACILITY OPERATING LICENSE NPF-52 DUKE ENERGY CORPORATION. ET AL, CATAWBA NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
On March 11,1999, Duke Energy Corporation (the licensee) determined that Technical Specifications (TS) Surveillance Requirements (SRs) 3.3.7, " Control Room Area Ventilation System (CRAVS) Actuation Instrumentation," and 3.3.8," Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) Actuation instrumentation," were not being met at Catawba Nuclear Station, Units 1 and 2. Specifically, the Surveillance Requirements (SRs) in Section 3.3.7 and 3.3.8 are not applicable to Catawba because these SRs do not reflect the design of the units.
By letter dated March 11,1999, the licensee requested that the NRC exercise discretion not to enforce compliance with the actions required by the Limiting Conditions for Operation (LCOs) associated with Sections 3.3.7 and 3.3.8. The March 11,1999, letter documented information previously discussed with the staff in a telephone conversation on the same day. As a result of its review, the staff verbally granted enforcement discretion to Catawba on March 11,1999, and documented the verbal authorization by a Notice of Enforcement Discretion (NOED) letter dated March 15,1999 (99-6-003). The NOED will expire upon issuance of an amendment to correct the subject TS sections.
By letter dated March 15,1999, the licensee submitted a request for changes to the Catawba Nuclear Station, Units 1 and 2, Technical Specifications. On March 17,1999, the licensee revised the original request, eliminating the proposed revision of Section 3.7.10. The licensee's requested changes would delete in their entirety Sections 3.3.7 and 3.3.8, and the associated sections in the Technical Specifications Bases document. The staff's detailed evaluation follows.
2.0 EVALUATION The licensee proposed to delete Sections 3.3.7 and 3.3.8 in their entirety. The basis for this deletion is that Sections 3.3.7 and 3.3.8 do not correctly reflect the oesign of the Catawba CRAVS and ABFVES actuation instrumentation. At Catawba, the Solid State Protection System (SSPS) provides input to the diesel generator load sequencer, which, in turn, provides input to the CRAVS and ABFVES. Thus, the CRAVS and ABFVES are not directly actuated by the 9904160187 9904os PDR ADOCK 05000413 P
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2-SSPS. However, the surveillance requirements (actuation logic test, master relay test, slave relay test) currently specified by in Sections 3.3.7 and 3.3.8 are written on the assumption that the CRAVS and ABFVES are directly actuated by the SSPS. Catawba TS Table 3.3.2-1 (not the subject of this amendment), Function 1b, already specifies all the necessary requirements that apply to the automatic actuation logic and actuation relays (master relays and slave relays) insofar as SSPS testing is concerned. Accordingly, the load sequencer output signal is tested as part of the engineered safeguards testing, which is conducted during refueling outages.
Thus, the automatic start capability of the CRAVS and ABFVES will continue to be appropriately tested.
- Control Room Area Ventilation System (CRAVS)," and 3.7.12, " Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)," which are not the subject of this amendment, will continue to specify mechanical requirements for the CRAVS and ABFVES.
Further, the staff recognizes that the Catawba CRAVS and ABFVES are not actuated by high radiation, and chlorine detector circuit testing had been previously moved out of the TS (i.e.,
Amendment No.173 for Unit 1 and Amendment No.165 for Unit 2). Thus, deletion of Sections 3.3.7 and 3.3.8 will have no adverse consequences insofar as high radiation protection and high chlorine protection requirements are concerned.
In the March 15,1999, letter the licensee originally proposed to also revise Section 3.7.10. By letter dated March 17,1999, the licensee withdrew that proposal. Hence, Section 3.7.10 is not a 1
subject of this safety evaluation.
On the basis of the preceding information, the staff has determined that Sections 3.3.7 and 3.3.8 are not necessary in that all mechanical and actuation requirements for these sections are i
already specified by other sections in the TS. Further, Sections 3.3.7 and 3.3.8 were incorrectly written for the Catawba CRAVS and ABFVES instrumentation design. There are no negative safety consequences associated with deleting the actions specified by these sections. The staff thus concludes that it is acceptable to delete Sections 3.3.7 and 3.3.8 in their entirety.
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3.0 STATEMENT OF EXIGENT CIRCUMSTANCES The Commission's regulation, as stated in Title 10 of the Code of Federal Reaulations (10 CFR)
Section 50.91, provides special exceptions for the issuance of amendments when the usual 30-day notice cannot be met. One type of special exception is an exigt cy. An exigency exists when the staff and the licensee need to act quickly and time does nu permit the staff to publish a Federal Reaister notice allowing 30 days for prior comment, and the staff determines that the amendments involve no significant hazard consideration.
In accordance with 10 CFR 50.91(a)(6)(i)(A), the staff issued a Federal Reaister notice on March 24,1999 (64 FR 14274), providing notice of an opportunity for hearing and proposing that the requested amendments involve no significant hsard consideration. The public was allowed 14 days after the date of publication of that notice to provide comments. No comments were received.
On March 11,1999, as result of discussions with the staff, the licensee concluded that compliance with the SRs of Sections 3.3.7 and 3.3.8 was not needed because these sections
. were incorrectly written for the design of the CRAVS and ABFVES at Catawba. On August 15, 1999, the licensee submitted its amendment request. On March 17,1999, the licensee submitted a revision to the original amendment request. In its application, the licensee explained why the exigent situation occurred.
These amendments complete the review process and implement the proposed TS changes, pursuant to the NRC's policy regarding exercising discretion for an operating facility set forth in Section Vll.c of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, for processing NOEDs. The staff has determined that, because compliance with the subject requirements would necessitate shutdown of the units, and in light of the NOED, issuance of these amendments is needed in less than the 30-day comment ysriod normally allowed for precessing TS amendments. In addition, the licensee used its best s' forts to make a timely application, and that the licensee did not cause the exigent situation.
" herefore, pursuant to 10 CFR 50.91(a)(6), the staff has determined that exigent circumstances exist and the amendments are being processed accordingly.
4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility, in accordance with the amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (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.
In its analysis of the issue of no significant hazards consideration, as required by 10 CFR 50.91(a), the licensee has provided the following:
First Standard Implementation of this amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. Approval of this amendment will have no effect on accident probabilities or consequences. No physical changes are being made i
to the plant design which will result in any increase in accident probabilities. Approval of this amendment will not result in a decrease in system or equipment reliability or availability.
Therefore, there will be no impact on any accident cor, sequences.
Second Standard implementation of this amendment would 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 NRC approval of this amendment request. No changes are being made to the plant that will introduce any new accident causal mechanisms.
Third Standard implementation of this amendment would 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 j
4 barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system.
I The performance of these fission product barriers wi!! not be degraded by the I
implementation of this amendment. No safety margins will be impacted.
The NRC staff has evaluated the amendments and the licensee's analysis against the three standards of 10 CFR 50.92(c). The NRC staff concludes that the amendments meet the three criteria of 10 CFR 50.92(c). Therefore, the staff has made a final determination that the proposed amendments do not involve a significant hazards consideration.
5.0 STATE CONSULTATION
in accordance with the Commission's regulations, the South Carolina State official, Mr. Virgil Autry, was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATMN The amendments change surveillance requirements. The NRC staff has determined that (1) the amendments involve no signifcant. change in the types or significant increase in the amounts of any effluents that may be released offsite,~ and (2) there is no significant increase in individual or cumulative occupational radiation exposure. In addition, the NRC staff has made a final finding that the amendments involve no significant hazards consideration. Accordingly, the amendrnents meet the eligibility criteria for catego:ical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant tu 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: Hukam Garg Peter S. Tam Date: April 8,1999 4
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