ML20216C566

Application for Amend to License NPF-52,changing License Condition 8(a) to Allow One Addl Fuel Cycle for Resolution of Cold Leg Accumulator Instrumentation Issue

ML20216C566
Person / Time
Site:	Catawba
Issue date:	06/19/1987
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8706300307
Download: ML20216C566 (5)

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DUKE POWER GoxPm P.O. nox 03180 CHARLOTTE, N.C. 28242 HALH.TUCKEH reLernown vsont emassomsev (704) 37N531 muotaan peopwmon June 19,'1987 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 .

Subject:

Catawba Nuclear Station, Unit 2 Docket No. 50-414 Operating License. Amendment

Dear Sir:

Attached is a proposed license amendment to the Catawba Nuclear Station, Unit 2 Operating License, NPF-52. This change will be required prior to startup following the first refueling outage at Catawba Unit 2.

Attachment 1 contains a proposed amendment to Itcense condition 8(a) of operating license NPF-52. 'This amendment would allow one additional fuel cycle for resolution of the cold leg accumulator instrumentation issue.

-This request is' applicable to the Catawba Unit 2 operating license. 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 being provided a copy of this amendment request.

Very truly yours,

.- g[- - -

Umi B. Tucker ROS/43/sbn Attachment l i

xc Dr. J. Nelson Grace American Nuclear Insurers i Regional Administrator, Region II c/o Dottie Sherman, ANI Library U. S. Nuclear Regulatory Commission The Exchange, Suite 245 101 Marietta Street, NW, Suite 2900 270 Farmingcon Avenue Atlanta, Georgia 30323 Farmington,~CT 06032 1

Mr. Heyward Shealy, Chief INPO Records Center Bureau of Radiological Health Suite 1500 South Carolina Department of Health & 1100 circle 75 Parkway ,

Environmental Control Atlanta, Georgia 30339 l 2600 Bull Street -

' Columbia, South Carolina 29201 l i

M&M Nuclear Consultants Mr. P. K. Van Doorn 1221 Avenue of-the Americas NRC Resident Inspector /

-New York, New York 10020 Catawba Nuclear Station hg/ )

B706300307 870619 DR ADOCK 050 4 yG o[O cM sf e

U. S. Nuc1 cr Regul tery Commiccica

' June 19, 1987.

1Page Three 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 amendment.to the Catawba Nuclear Station Unit 2 operating license NPF-52; and that all statements and matters set forth therein'are true and correct to the best of his knowledge.

4 N Hal B. Tucker, Vice President Subscribed and sworn to before me this 19th day of June, 1987.

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Notary Public '"

.My Commission Expires:

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ATTACHMENT 1

~ DUKE POWER. COMPANY

CATAWBA NUCLEAR STATION, UNIT 2 PROPOSED LICENSE AMENDMENT--

TO-FACILITY OPERATING LICENSE NPF-52 LICENSE ' CONDITION (8)(a)-

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l(1)L Requested Amendment-Amend Facility Operating License NPF-52 License Condition (8)(a) to read:

' Prior.to startup following the'second refueling outage, Duke E Power Company shall provide' qualified accumulator discharge instrumentation.

(2) ' Discussion -

Supplement l'to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter 82-33) included additional clarification regarding Regulatory.-

Guide.l.97, Ravision 2. -By letter dated September 26,'1983, Duke Power Company provided the information concerning the' exceptions to conformance to the regulatory guide. Pending completion of the Staff's review of the Catawba design for conformance to the guidance of the regulatory guide, the operating.

' license for Catawba Unit I was conditioned to require that modifications be completed to provide compliance.with the regulatory guide unless the 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 heat removal heat exchanger outlet temperature (d) Accumulator tank level and' pressure

,(e) Steam generator pressure (f) Containment sump water temperature

'(g) Chemical and volume control' system makeup flow and letdown flow (h): Emergency ventilation damper position (1)' Area radiation (j) ; Plant' airborne and area radiation Ms. Elinor G. Adensan's. letter'of August 6, l'985 transmitted'a. draft Technical Evaluation Report'(TER) regarding Catawba's conformance to Regulatory Guide 1.97, Rev. 2. The TER also requested additional justification' for some of the exceptions taken by Duke. By letter dated October 22, 1985, Duke provided the

. requested information. In Supplement 5 to the Catawba Safety Evaluation Report,. dated February 1986,-the Staff approved all of the exceptions except for accumulator level and pressure, requiring that Duke designate either level or pressure,as the key variable'to be' upgraded. This position was incorporated into the low power license' (NPF-48)' for Catawba Unit 2 on February 24, 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 merits of the Staff's requirement.- To date, no response has been received.

On-June 6, 1986, Duke requested that the NRC amend the Catawba Unit 1 license to allow an additional two operating cycles for resolution of the accumulator instrumentation issue. On October 6, 1986, the NRC issued Amendment 15, to FOL NPF-35, granting the two cycle extension.

'By letter 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 of i

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l I the'SER'it was noted that-the Staff is currently reviewing the need'for-environmentally qualified category 2 instruments.to monitor' accumulator-tank

' level and pressure. Acceptability of McGuire's accumulator level and pressure instrumentation was deferred until the generic review process'is complete. j I

The requested one cycle extension for Catawba Unit 2 would put Catawba Units 1 and 2 on approximately the same schedule for resolution of this issue and would allow the NRC: Staff additional time to complete their generic review.

(3) Safety Analysis The primary function of-the accumulator pressure and level instrumentation is to monitor the pre-accident status of-the accumulators to assure that the passive safety system is in a ready state to serve its safety function.

Accuisulator tank'le el and pressure are not referenced in any emergency, 1 procedure covering design basis events which may cause a harsh environment..  !

No operator' actions in these procedures are based on accumulator indications. l It is therefore Duke Power Company's conclusion that extension of the date for- ]

upgrading the accumulator: pressure or. level instrumentation until;etartup l following the second refueling outage'does not involve any adverse safety j considerations . .- ,

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~(4) . Analysis of Significant Hazards Consideration i 1

As required by 10 CFR-50.91,.this analysis is provided concerning whether'the ]

,s proposed amendment involves significant hazards considerations, as defined by 1 L

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 in the probability or consequences of an accident previously i evaluated; or 2) create the' possibility of a new or different kind of accident l from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.  !

The proposed amendment would not involve a significant increase in the probability of an accident previously evaluated because the accumulator level and pressure are provided for pre-accident monitoring of the status of the cold-leg accumulators and as such have no effect on cause mechanisms.

The proposed amendment would not create the possibility of a new or different kind of accident than previously evaluated since the design and operation of ,

the unit will not be affected.

l The proposed amendment would not cause a significant reduction in a margin of safety. The extension of time in which to resolve the accumulator l- instrumentation issue, would have no impact on safety margins since the instrumentation is fully qualified for its intended function of pre-accident monitoring of'the cold-leg accumulators.

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