ML20210E350
| ML20210E350 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire, 05000000 |
| Issue date: | 03/25/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| GL-82-33, NUDOCS 8603270319 | |
| Download: ML20210E350 (3) | |
Text
- _ - -.
.e %
y.
a DuxE POWER GOMPANY P.O. BOX 33180 CHARL(YTTE, N.C. 28242 HALB. TUCKER Taternowr.
vws emensment (7o4)373 4531 mm.
o.m.o.
I i
March 25, 1986 1
Mr. Harold R. Denton, Director
}
Office of Nuclear Reactor Regulation
]
U. S. Nuclear Regulatory Commission i
Washington, D. C.
20555 i
Attention:
Mr. B. J. Youngblood, Project Director PWR Project Directorate No. 4 Re: Catawba Nutlaar Station Docket Nos. 50-413 and.50-414 McGuire Nuclear Station I
. Docket Nos. 50-369 and 50-370 1
Dear Sir:
2 l
On March 28 and'29, 1984, respectively, Duke Power Company (Duke) submitted the descriptiens of the' Catawba and.McGuire Safety Parameter Display Systems (SPDS). The SPDS was developed by Duke and has been implemented in essentially identical form at Catawba and McGuire. An onsite design i
verification / validation. audit was conducted by NRC on May 14 and 15, 1985.
Results of the audit were transmitted on September 10 and October 31, 1985 for Catawba Unit 2 and on November 7, 1985 for McGuire.
Safety Evaluati.m Reports were recently received for the SPDS on McGuire (February 28, 1986) and Catawba (SSER-5).. As discussed below, positions taken by the Staff in the essentially identical SER's for McGuire and Catawba, would cause Duke to. change the design and operation of McGuire and Catawba from that consistent with already applicable regulatory staff 3
l positions.
(1) Generic Letter 82-33 Paragraph 4.1(f) notes that "The specific parameters to be displayed shall be determined by.the. licensee".
Contrary to this-statement the Staff has required that additional, specified variables be added to i
the McGuire/ Catawba SPDS.
i
)
-(2) NUREG-0696, Function Criteria for Emergency Response FacilitiesSection II.E notes that the SPDS display may be individual plant 6
parameters or derived variables giving an overall system status (emphasis added). Contrary to this guidance the Staff has required that McGuire/ Catawba SPDS be redesigned / defined to include the actual l
value of all of the SPDS input variables as well as the additional l
variables noted above.
g60 i
\\\\ 0 4
8603270319 860325
\\
PDR ADOCK 05000369 p
,-,,.--n...
-n,
.._--~-,.~-,.,n,,.,,,
,4
-,.-,,.o.-,-w,
' Mr. Harold R. Danten, Director March 25, 1986 Page Two~
i Therefore, in accordance with 10 CFR 50.109 and NRC Manual Chapter 0514 it is requested that the Staff provide an analysis which demonstrates that there is a substantial increase in the overall protection of the public health and safety or common defense and security to be derived from the imposition of the identified backfit and that the direct and indirect costs of implementation are justified in vi~ew of this increased protection.
As further evidence that the Staff's request constitutes a plant-specific backfit, it should be noted that the Staff's SER's were not timely with I
l regards to implementation of the SPDS at McGuire and Catawba. Ap'endix A -
Guidance for Making Backfit Determinations, of NRC Manual Chap;er 0514 notes:
...if a licensee has implemented a technical resolution intended to meet an applicable regulatory staff position, and the Staff for an
^
extended period simply allows the licensee resoltrion to stand with tacit acceptance indicated by nonaction on the pai of NRC, then a subsequent action to change the licensee *a design, construction, or operation is a backfit".
As noted above, the description of the McGuire/ Catawba SESS was transmitted.
to the NRC in March, 1984. The SPDS was implemented on both McGuire units'-
i in November,1984 as required by a Confirmatory Order date> June 15, 1984.
The SPDS was implemented on Catawba Unit 1 prior to April.
1985 as required by License Condition 12(b) of Facility Operating I.lcense NPF-35.
Therefore, Duke considers that the recent SER's, dated Febr.xry,1986, are not timely with respect to Duke's submittals and the.requir.d implementation dates for the SPDS.
On February 24, 1986, Facility Operating License NPF-48 was fseued for j
Catawba Unit 2.
License Condition 9(b) required that the SPDS be modified
]
to add five additional parameters as discussed in SSER-5.
Since this License Condition is contrary to the guidance of Generic Letter 82-33 and in the absence of a backfit analysis, it is requested that this license condition be deleted from the Catawba Unit 2 Full Power License when issued.
3 l
Very-truly yours, C
[ '
-n<c I
Hal B. Tucker ROS:alb Attachment 4
l 4
1 s
Mr. Harsld R. D;nton, Dircetcr March 25, 1986 Page Three xc:
Mr. Victor Stello, Jr., Acting Executive Director for Operations U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Comission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector McGuire Nuclear Station NRC Resident Inspector Catawba Nuclear Station Dr. K. N. Jabbour Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Darl Hood Project Manager Office of Nuclear Reactor Regulatiora U. S. Nuclear Regulatory Commission Washington, D. C.
20555
. ~. -,
.