ML20216E653
| ML20216E653 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/13/1999 |
| From: | Barron H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216E657 | List: |
| References | |
| NUDOCS 9909160080 | |
| Download: ML20216E653 (8) | |
Text
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)g Duke Energy Corporation McGuire Nudear Scation 12700 Hagers Ferry Road Huntersville, NC 28078-9340 (704) 875-4800 omCE
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(704) 875-48G9 fax September 13, 1999 U.S. Nuclear Regulatory Commission ATTENTION:
Document Control Desk Washington, DC 20555-0001
SUBJECT:
Duke Energy Corporation (DEC)
McGuire Nuclear Station Unit 1 and Unit 2 Docket Nos. 50-369, 50-370 Proposed Technical Specification Amendment Technical Specification 3.7.9 - Control Room Area Ventilation System (CRAVS)
Introduction Pursuant to 10CFR50.90, 10CFR50.91, and 10CFR50.4, this letter submits an exigent license amendment request for the McGuire Nuclear Station Facility Operating License and Technical Specifications (TS).
The changes proposed by DEC in this request are consistent with generic industry changes currently under NRC review as proposed in TSTF-287. The proposed revisions make permanent the one time only changes that were incorporated into TS 3.7.9 via McGuire TS amendments 185/167.
These changes will allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the Control Room Pressure Boundary (CRPB)to operable status when two CRAVS trains are inoperable due to an inoperable CRPB in MODES 1, 2,
3, and 4.
In addition, a Limiting Condition for Operation note will be added to allow the CRPB to be opened intermittently under adm'sistrative control without affecting CRAVS operability.
This amendment is applicable to Facility Operating License NPF-9 and NPF-17 for McGuire Nuclear Station Unit 1 and Unit 2 respectively.
These changes should be effective on ssuance.
Background
The CRAVS is shared between Units 1 and 2 and consists of two redundant safety related trains.
The system's purpose is to provide normal and emergency ventilation requirements for the Control Room.
During an emergency, each CRAVS train can draw outside air through its own filters and activated charcoal absorber for use in pressurizing the Control Room.
This pressurization function ensures that radiation dose to the 9909160000 9909163 I
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U.S. Nuclear Regulatory Commission September 13, 1999 Page 2 of 7 Con. trol Room operators from airborne radioactive material released during a loss of coolant accident is less than the appropriate acceptance criteria.
Two independent and redundant CRAVS trains are required to be OPERABLE to ensure that at least one is available to pressurize the Control Room if needed, assuming a single failure disables the other train.
In addition, to ensure adequate Control Room pressurization during an event, the CRPB must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.
Technical Specification Surveillance Requirement (TSSR) 3.7.9.4 tests the integrity of the control room boundary.
This test has acceptance criteria that requires a positive pressure limit to be satisfied with one ventilation train operating While other surveillance requirements in the same specification test the operability and function of the ventilation train, the pressure test ensures that the control room pressure boundary leak tightness is adequate to meet the design assumptions for post accident operator doses.
Currently, there are no corresponding permanent conditions, required actions, or completion times specified in LCO 3.7.9 should the control room pressure boundary surveillance not be met.
Under the existing specifications, LCO 3.0.3 must be entered (for two-train inoperability).
Requiring i
both Units to enter LCO 3.0.3 when the ventilation boundary is not intact does not provide time to effect any required repairs, perform corrective maintenance activities, or implement TS related surveillance testing.
The proposed revisions make permanent the one time only changes l
that were incorporeted into TS 3.7.9 via McGuire TS amendments j
185/167.
These changes establish actions to be taken for l
inoperable control room ventilation systems due to a degraded CRPB and provide for intermittent opening of the CRPB under administrative controls.
These changes are consistent with the i
generic changes proposed by TSTF-287.
That TSTF justifies the l
proposed changes based on the low probability of a Design Basis l
Accident occurring during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time or while the CRPB is opened intermittently under administrative controls.
Submittal of this change meets part of DEC's commitments regarding ventilation system changes provided to the NRC in correspondence from H. B.
Barron to H. N.
Berkow, dated August 30, 1999, related to the Three Minute Rule for operability of CRAVS.
DEC maintains that past application of the Three Minute Rule at McGuire and the Catawba Nuclear Station are fully compliant with all regulatory requirements.
Submittal of this LAR does not alter that regulatory position.
U.S. Nuclear Regulatory Commission September 13, 1999
-Page 3 of 7 Exigent Criteria MNS TSSR 3.7.9.2 requires that the filters and activated charcoal absorbent in each CRAVS train Control Room pressurization flow path be periodically tested in accordance with the McGuire Ventilation Filter Testing Program (VFTP) as described in section 5.5.11 of the McGuire TSs.
As part of this testing, the CRAVS train being tested is declared inoperable while the other train remains operable'to pressurize the Control Room if needed.
A representative sample of charcoal absorbent is then obtained from the train being tested by removing a bolted hatch cover on that train's filter / absorber package.
Removing this cover provides a breach in the CRPB.
Since the potentia) exists for backflow through this breach from the operable CRAVS train, McGuire's past practice was to ensure the operability of the non-tested CRAVS train by stationing dedicated plant personnel at the breach in the tested train with instructions to re-install the hatch cover upon notification of an event by Control Room personnel.
The next performance of TSSR 3.7.9.2 on the McGuire CRAVS Train "B"
was originally scheduled for June 1999.
However, Technical Interface Agreement (TIA) 98008 (TAC No. MA2467 and MA2468),
promulgated the NRC position that, given existing wording in the McGuire TSs, administrative controls such as those McGuire used in the past to maintain the operability of the non-tested CRAVS train could not be credited for TS compliance.
At the time that TIA was issued, the NRC and industry groups were proposing generic changes to the standardized TSs (STS), as described in TSTF-287, that would allow intermittent breaching of the CRPB under administrative controls.
Indications were that TSTF-287 would be approved prior to September 25, 1999, the late date for performance of TSSR 3.7.9.2 on CRAVS Train "B" after incorporating the 25% extension of the surveillance frequency allowed by TSSR 3.0.2.
Consequently, McGuire planned to submit changes to TS 3.7.9 based upon the post-TSTF version of the STS and perform the surveillance on CRAVS Train "B" prior to September 25, 1999.
However, in mid-August 1999 when it became apparent that approval of TSTF-287 might be delayed, McGuire began the process of evaluating alternative means of performing the required surveillance testing of CRAVS Train "B".
These evaluations concluded that the best alternative for maintaining operability of CRAVS Train "A" during testing of Train "B" was to isolate Train "B" by closing and gagging its dampers.
McGuire Engineering was then assigned the task of finalizing the details for accomplishing this isolation of the CRAVS Train "B".
At that time, DEC anticipated that isolation of CRAVS Train "B" using that train's dampers would allow successful completion of TSSR
e' U.S. Nuclear Regulatory Commission e
September 13, 1999 Page 4 of 7 3.7. 9.2 on CRAVS' Train "B" prior to September 25, 1999.
Review of this alternative proceeded at a pace that facilitated an accurate and thorough evaluation without any unaecessary delays.
On September 9, 1999, Engineering personnel determined that complete isolation of CRAVS Train "B" using that train's dampers could not be guaranteed given the lack of any required leak testing of those dampers.
Consequently, it might be possible that, when the hatch cover is removed from the CRAVS Train "B"
filter / absorber package to allow carbon sampling, the operability of CRAVS Train "A" could be affected by back flow through the breach in Train "B".
At no time prior to September 9, 1999 was DEC aware that i
isolation of CRAVS Train "B" using its dampers might not ensure the operability of Train "A".
Upon identifying the operability concerns associated with isolation of CRAVS Train "B" using its dampers and after concluding there were no other acceptable alternatives for performing the surveillance testing, DEC 1
immediately notified the NRC of the need for a change to TS 3.7.9.
However, given the September 25, 1999 late date for performance of TSSR 3.7.9.2 on CRAVS Train "B",
less than 30 days exists to allow for the normal comment period under 10 CFR 50.91.
Absent the performance of the surveillance or an amendment, Unit 2 would be forced to shutdown under the requirements of TS 3.0.3 and, since it will be in a scheduled refueling outage, Unit 1 would be required to suspend core alterations or movement of irradiated fuel assemblies under the requirements of TS 3.7.9.
Given the above and the determination that this LAR involves no significant hazards as specified under 10 CFR 50.92, DEC believes the criteria for exigency as described in 10 CFR 50.91 are met.
Consequently, DEC requests that this LAR be processed as an exigent change pursuant to the requirements of 10 CFR 50.91 (6)
(i) which allows for local media notice if less than 14 days exists for the FEDERAL REGISTER notice.
Contents of Amendment Request Given the determination that this proposed amendment contains no significant hazards considerations, McGuire maintains that precluding the possibility of an unnecessary plant transient by
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implementing this exigent LAR is in the best interests of the overall health and safety of the public. provides marked up pages of the existing McGuire TS 3.7.9 showing the proposed changes. contains the new McGuire TS 3.7.9 pages.
The Description of Proposed Changes and Technical Justification is provided in Attachment 3.
Pursuant to 10CFR50.92, Attachment 4 documents the determination that this proposed amendment contains No Significant Hazards l
1 U.S. Nuclear Regulatory Commission September 13, 1999 Page 5 of 7 considerations.
Pursuant to 10CFR51.22 (c) (9), Attachment 5 provides the basis for the categorical exclusion from performing an Environmental Assessment / Impact Statement.
Implementation of this amendment to the McGuire FOL and TSs will not impact the McGuire UFSAR.
This LAR contains a regulatory commitment to ensure that compensatory measures described in the proposed BASES changes associated with Required Action G.1 are available to minimize doses to applicable plant operations personnel.
In accordance with Duke internal procedures and the Quality Assurance Program Topical Report, this proposed amendment has been previously reviewed and approved by the McGuire Nuclear Station Plant Operations Review Committee and the Duke Corporate Nuclear Safety Review Board.
Pursuant to 10CFR50.91, a copy of this LAR is being forwarded to the appropriate North Carolina State Officials.
Please direct questions on this LAR to Julius Bryant at 704-875-4162.
Very truly yours, H.
B.
Barron, Vice President McGuire Nuclear Station Attachments
U-S. Nuclear Regulatory Commission September 13, 1999 Page 6 of 7 xc: (w/ attachments)
L.A. Reyes Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta St.,
NW, Suite 2900 Atlanta, GA.
30323 S.M.
Shaeffer NRC Senior Resident Inspector McGuire Nuclear Station F. Rinaldi NRC Senior Project Manager (MNS)
Office of U.S. Nuclear Reactor Regulation One White Flint North, Mail Stop O-14H25 Washington, D.C. 20555-0001 R.M. Fry, Director Division of Radiation Protection State of North Carolina 3825 Barrett Drive
- Raleigh, N.C.
27609-7221
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.U.S. Nuclear Regulatory Commission September 13, 1999 Page 7 of 7 H.,B. Barron, being duly sworn, states that he is Site Vice President of McGuire Nuclear Station Duke Energy Corporation;
'that he is' authorized on the part of Duke Energy Corporation to sign and file with the U.S. Nuclear Regulatory Commission'this i
revision to the McGuire Nuclear Station Facility Operating License No.s NPF-9 and'NPF-17; and, that all statements and matters set forth'therein are true and correct to the best of his knowledge.
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H.'B.
Barron, Vice President McGuire Nuclear Station Duke Energy Corporation Subscribed and sworn to before me this 13th day of September 1999.
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" '"#Y MICHAEL T. CASH Notary Public Lincoln County, North Carolina 1
i My Commission Expires:
Commission Expires January 22,2003 pmuwy 22, 200 b i
i' bxc: (w. attachments)
H.B. Barron (MG01VP)
B.L. Peele Jr. (MG01VP)
B.J. Dolan'(MG01VP) l M.T. Cash (MG01RC)
J.W. Bryant (MG01RC)
P.T. Vu (MG01RC)
K.L. Crane (MG01RC)
(
_ J.W. Boyle (MG05EE)
D.M Jamil (MG01IE)
G.R. Peterson (CN01VP) l P.R. Herran (CN01EM)
S.L. Bradshaw (CN01SA)
G.D. Gilbert (CN01RC)
L.J. Rudy (CN01RC) l l
J.J. Fisicaro (EC070)
L.A. Keller (EC050)
G.B Swindlehurst (EC08H)
ELL (EC050)
McGuire Masterfile NSRB Support Staff (EC05N) i l
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