ML20205N238

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Safety Evaluation Supporting Amends 178 & 170 to Licenses NPF-35 & NPF-52,respectively
ML20205N238
Person / Time
Site: Catawba  
Issue date: 04/09/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20205N235 List:
References
NUDOCS 9904160200
Download: ML20205N238 (4)


Text

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  • * * *
  • SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.178 TO FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO.

170 TO FACILITY OPERATING ! ICENSE NPF-52 DUKE ENERGY CO_R_PORATION. ET AL.

CATAWBA NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. F0-413 AND 50-414

1.0 INTRODUCTION

By letter dated February 18.1999, Duke Energy Corporation, et al. (DEC, the licensee),

submitted a request for changes to the Catawba Nuclear Station, Units 1 and 2 Technical Specifications (TSs). The requested changes would revise Surveillance Requirement (SR) 3.6.16.1, SR 3.6.16.3, and Administrative Controls 5.5.2. The licensee found that the revised requirements would provide scheduling flexibility. The staffs review of DEC's proposed revision is set forth below.

2.0 DISCUSSION AND EVALUATION 2.1 Surveillance Requirements and Administrative Controls 2.1.1 Surveillance Requirement 3.6.16.1 This SR currently requires, on a 31-day frequency:

" Verify each door in each access opening is closed, except when the access opening is being used for normal transit entry and exit; then at least one door shall be closed."

The wording pertains to airlock design (two doors) for entry into the reactor building. The licensee stated that there are five openings into each Catawba reactor building; each of these openings has only a single door.

The licensee proposed to revise this SR to state:

" Verify the door in each access opening is closed, except when the access opening is being used for normal transit entry and exit."

The staff reviewed the licensee's submitted information and agreed that errors exist in the j

current TS as descr. bed above. The current requirement is inconsistent with the plant as originally designed and built. The licensee's proposed change would correct the error and is, 4

therefore, acceptable.

9904160200 990409 PDR ADOCK 05000413 F

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) 2.1.2 Surveillance Requirement 3.6.16.3 This SR requires that reactor building structural integrity be verified by performing a visual inspection of the exposed interior and exterior surfaces of the reactor building once every 40 months and during shutdown for SR 3.6.1.1 (i.e., Type A tests). SR 3.0.2 allows SR intervals be extended to 1.25 the specified value. Thus, SR 3.6.16.3 would have to be done within 40 to 50 months of the last surveillance.

The licensee stated that the current interval for Unit 1 would expire soon, leading to the possibility of an unnecessary shutdown in order to perform SR 3.6.16.3. The licensee observed that the Catawba TS before conversion to the improved Technical Specification (ITS) format did not have the 40-to-50-month interval specified, instead, the old TS (Section 4.5.1.7) specified that a structural integrity inspection be performed at the same time as the Type A test (i.e., every 10 years), and two additional structural integrity inspections be performed during shutdowns between Type A tests at approximately equal intervals.

The licensee observed that under the current wording, and if the Type A test did not happen to fall within the 40-to-50-month interval, a total of four structural in'.agrity inspections could be required during a 10-year interval. The licensee also observed that there are now three separate requirements pertaining to visual examination of the steel containment vessel and the reactor building: Appendix J of 10 CFR Part 50, Option B;Section XI of the ASME Code; and SR 3.6.16.3. In order to meet all these requirements, the licensee would like to see more flexibility in SR 3.6.16.3. In particular, the licensee plans to schedule structuralintegrity inspections concurrently with examinations required by other requirements.

Accordingly, the licensee proposed to revise the frequency requirement of SR 3.6.16.3 to "3 times every 10 years, coinciding with containment isual examinations required by SR 3.6.1.1." This would essentially revise the frequency requirement back to what it was before implementation of the ITS.

The staff agrees hat the revised wording will previde more flexibility in sch6duling without decreasing the number of structuralintegrity inspections (three per 10 yea:s). The proposed revision would have no impact on the quality or the safety functions of the affected components.

Therefore, the proposed revision of SR 3.6.16.3 is acceptable.

2.1.3 Administrative Control 5.5.2 This requires a program for leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B, for Type A testing. This also requires that the guidelines contained in Regulatory Guide (RG) 1.163, " Performance-Based Containment Leak-Test Program," be followed.

The licensee proposed to 6dd the following to Administrative Control 5.5.2:

- "Except that the containment visual examinations required by Regulatory Position C.3 shall be conducted 3 times every 10 years, ine'Hing during each shutdown for SR 3.6.1.1 Type A test, prior to initiating the ~ t. 9 A test."

The licensee pointed out that Regulatory Position C.3 of RG 1.163 states that these containment visual examinations should be conducted during two other refueling outages. The licensee stated that performance of these examinations during operation or shutdown has no impact on the quality of these examinations, provided all accessible interior and exterior surfaces are examined. The additional wording would provide the licensee with scheduling flexibility.

The staff agrees that the additional wording will provide more flexibility in scheduling without decreasing the number of containment visual examinations (three per 10 years). The purpose of Regulatory Position C.3 of RG 1.163 was to specify that visual examinations were to be conducted at a certain frequency. The phrase "during two other refueling outages" was used because the staff assumed the examinations would probably be done during refueling outages.

However, this was by no means intended to be an essential condition for the examination. Thus 1

the revision would have no impact on the quality or safety functions of the affected components.

Therefore, the proposed revision of Administrative Control 5.5.2 is acceptable.

2.2 Technical SpecMcation Bases Document The TS Bases is a licensee-controlled document, and is not part of the TS (10 CFR 50.36(a)).

However, the staff reviewed the licensee's proposed changes as supplemental information for the changes to the TS. The staff finds the proposed changes to the Bases document acceptable as summarized below.

2.2.1 Bases for SR 3.6.16.1 The licensee proposed to revise the bases for SR 3.6.16.1 to reflect the correction described above. The staff evaluated the revision of SR 3.6.16.1 in Section 2.1.1 above. In addition, the licensee pointed out that there is no control room indication of reactor building door status; instead, indication is by alarm station methods which are available to Security. The licensee thus proposed to delete the phrase "to the operator" which implies, incorrectly, that there is indication to the operator in the control room.

2.2.2 Bases for SR 3.6.16.3 The licensee proposed to revise the bases for SR 3.6.16.3 to reflect the revised frequency requirement. The staff evaluated the revision of SR 3.6.16.3 in Section 2.1.2 above.

3.0 STATE CONSULTATION

in accordance with tne Commission's regulations, the South Carolina State official, Mr. Virgil Autrey, was notified of the proposed issuance of the amendments. The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

The amendments change su:veillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no signific

.azards consideration, and there has been no public comment on such finding (64 FR ii ' a dated March 10,1999).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 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: James C. Pulsipher Peter S. Tam Date:

April 9,1999