ML20207G200

Application for Amends to Licenses NPF-35 & NPF-52, Respectively,Allowing Two Addl Fuel Cycles for Resolution of Cold Leg Accumulator Instrumentation Issue

ML20207G200
Person / Time
Site:	Catawba
Issue date:	08/15/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8808240003
Download: ML20207G200 (7)

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DuxE POWEn GOMPANY P.O. NOX 33180 i CH AMLOTTE. N.O. 28949 l HA1. B. TUCKER veternown two passesat (704)375 4834 mwtaan eensecreo=

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l August 15, 1988 >

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U. S. Nuclear Regulatory Commission .

Attention: Document Control Desk Washington, D. C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Operating License Anendments ,

Dear Sir:

Attached are proposed license amendments to the Catawba Nuclear Station, Units 1  ;

and 2 Operating Licenses, NPF-35 and NPF-52, respectively. '

The attachments outline proposed amendments to license condition 12(a) of j operating license NPF-35 and license condition 8(a) of operating license NPF-52. l These amendments would allow two additional fuel cycles for resolution of the ,

cold leg accumulator instrumentation issue.

This request is applicable to the Catawba Unit 1 and Unit 2 operating licennes. i Accordingly, pursuant to 10 CFR 170.21, a check for $150.00 is enclosed.

Pursuant to 10 CFR 50.91(b)(1) the appropriate South Carolina State Official is l' being provided a copy of this amendment request.

Very truly yours l

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I lial B. Tucker j l

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1 PE** , p i 0608240003 880815 '

PCR ADOCK 05000413 l

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, y. S. Nuc1str R:gulctory Commiccion August 15, 1988 Pagu Two xc Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission 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 American Nuclear Insurers l c/o Dottle 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 l INPO Records Center )

Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station l

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^ugust 15, 1988 -i

+ ' Page Three l HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power. j Company that he is authorized on the part of said Company to sign and file with

• the Nuclear Regulatory Conunission this revision to the Catawba Nuclear Station l Technical Specifications, Appendix A to License No. NPF-35 and.NPF-523 and that  !

all statements and matters set-forth therein are true and correct to the best of his knowledge. 3 4

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Hal B. Tucker, Vice President I L.

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Subscribed and sworn to before me this 15th day of August, 1988.

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ATTACHMENT DUKE POWER COMPANY .

CATAWBA NUCLEAR STATION, UNITS 1 AND 2 l l

PROPOSED LICENSE AMENDMENTS TO  !

FACILITY OPERATING LICENSFS NPF-35 AND NPF-52 l LICENSE CONDITIONS (12)(a) AND (8)(a) )

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j (1) Requested Amendments Amend Facility Operating License NPF-35 License Condition (12)(a) to read:

Prior to startup following the fifth refueling outage. Duke l Power Company shall provide qualified accumulator discharge i instrumentation.

Amend Facility Operating License NPF-52 License Condition (8)(a) to read:

Prict to startup following the fourth refueling outage Duke Power Company shall provide qualifled accumulator discharge instrumentation.

(2) D_iscussion Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter 82-33) included additional clarification regarding Regulatory Guide 1.97, Ravision 2. Ey letter dated September 26, 1983 Duke Power Company provided the information concerning the exceptions to conformance to the regul.atory guide. Pending completion of the Staff's review of the Catawba design for conformance to the guidance of the regu'.atory guide, the operating licenses for Catawba Unit 1 and Unit 2 were conditioned to require that modificatl. ens be completed to provide compliance with the regulatory guide unlesc aie exceptions were reviewed and approved by the staff before startup following the first refueling outage. The items identified were:

(a) Reactor coolant system cold leg water temperature (b) Containment sump water level (c) Residual heau removal heat exchanger outlet temperature (d) Accumlator tank level and pressure (c) Steam generator pressure (f) Containment sump water temperature (g) Chemical and volume control system makeup flow and letdown flow (h) Emergency ventilation damper position (i) Area radiation (j) Plant airborne and area radiation Ms. Elinor G. Adensam's letter of August 6, 1985 transmitted a draft Technical Evaluation Report (TER) regarding Catawba's conformance to Regulatory Guide l 1.97, Rev. 2. The TER also requested additional justification for some of the l exceptions taken by Duke. By letter dated October 22, 1985, Duke provided the l requested information. In Supplement 5 to the Catawba Safety Evaluation i Report, dated February 1986, the Staff approved all of the exceptions except I for accumulator level and pressure, requiring that Duke designate either level l or pressure as the key variable to be upgraded. This position was  !

incorporated into the operating license (NPF-35) for Catawba Unit 1 on  !

January 17, 1987 and into the operating license (NPF-52) for Catawba Unit 2 1 on May 15, 1986.

By letter dated March 25, 1986 Duke requested additional technical )

justification from the Staff in order for Duke to be able to evaluate the i merits of the Staff's requirement. Based on the receipt of these responses, it is anticipated that Duke would either begin implementation or pursue the issue further through the NRC's appeal process.

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1 06 June 6, 1986, Duke requested that the NK amend the Catawba Unit 1 license to allow an additional two operating cycles for resolution of the accumulator l instrumentation issue. On October 6, 1986, the NRC issued Amendment 15, to L

FOL NPF-35, granting the two cycle ey'.cnsion.

l On June 19, 1987, Duke requested the NRC amend the Catawba Unit 2 license to allow an additional operating cycle for resolution of the accumulator ,

I instrumentation issue. On November 25. 1987, the NRC issued Amendment 27 to '

l NPF-52, granting the cycle extension.

l By 3ctter dated March 23, 1987, the NRC transmitted an SER on the conformance of Duke's McGuire Nuclear Station to Regulatory Guide 1.97. In Enclosure 1 '

l of the SER it was noted that the Staff is currently reviewing the need for j environmentally qualifled category 2 instruments to monitor accumulator tank l

level and pressure. Acceptability of McGuire's accumulator level and pressure l Instrumentation was deferred until the generic review process is' complete.

t The requested two cycle extension for Catawba Unit 1 and Unit 2 would put Catawba Units 1 and 2 on appror.imately the same schedule for resolution of.

this issue and would allow the NRC Staff additional time to complete their  :

generic review. Assuming that Duke ultimately agrees to upgrade either the accumulator level or pressure instrumentation, it is estimated that -

approximately 23 months lead time would be required for implementation e during a refueling. The Unit i fifth refueling outage is currently scheduled to start February 6, 1991. The Unit 2 fourth refueling outage is currently scheduled to start August 9, 1991.

These amendment requests are needed by December 1, 1988 to support the current refueling schedule. '

(3) Safety Ana1Ls}e l The primary functier; cf the vt cumulator pressure and level instrumentation is to monitor the pre accident n atus of the accumulators to assure that the passive safety sysiw is in a ready state to serve its safety function.

Accumulator tank level ed pressure are not referenced in any emergency procedure ecvering desip, basis events which may cause a harsh environment.

No operator actions in these procedurcs are based on accumulator indications.

l lt is therefore Duke Power Tompany's concluaion that extension of the date for upgrading the accumulator pressure or level instrumentation does not involve any adverse safety considerations.

(4) Analysis of Shnificant Hazards Consideration As required by 10 CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hazards considerations, as defined by 10 CFR 50.91. Standards for determination that a proposed amendment involves no significant hazards considerations are if operation of the facility in accordance with the proposed amendment would not 1) involve a significant increase fo 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 evaluatedt or 3) involve a significant reduction in a margin of safety.

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The proposed amendment would not involve a significant increase in the l probability of an accident previously evaluated because the accumulator l l 1evel and pressure are provided for pre-accident monitoring of the status of 3

the cold-leg accumulators and as such have no effect on cause mechanisms. j The proposed amendment would not create the' possibility of a new or different l' l kind of accident than previously evaluated since the design and operation of the unit will not be affected.

The proposed amendment would not cause a significant reduction in a margin of -

safety. The extension of time in which to resolve the accumulator

. instrumentation issue, would have no impact on safety margins sinca the-instrumentation is fully qualified for its intended function of pre-accident a monitoring of the cold-leg accumulators. j J

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