ML20217K573
| ML20217K573 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/23/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217K561 | List: |
| References | |
| NUDOCS 9805040024 | |
| Download: ML20217K573 (15) | |
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4 UNITED STATES 4
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NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 2006H001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.164 TO FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO.156 TO FACILITY OPERATING LICENSE NPF-52 DUKE ENERGY CORPORATION. ET AL.
CATAWBA NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 j
1.0 INTRODUCTION
By letter dated December 18,1997, Duke Energy Corporation, et al. (DPC or the licensee),
submitted a request to revise the Facility Operating License of each unit to editorially delete license conditions that have been fulfilled, to update information to reflect current plant status and regulatory requirements, and to make other editorial changes. By letter dated January 26, 1998, the licensee revised its request, withdrawing proposed changes to replace " Final Safety Analysa, Rcport" with " Updated Final Safety Analysis Report" on pages 2,3, and 4 of the Operating Licenses.
2.0 DISCUSSION AND EVALUATION 2.1 License Conditions When the Facility Operating Licenses (FOLs) NPF-35 and NPF-52 were issued to the licensee, the NRC staff deemed certain issues essential to safety and/or essential to meeting certain regulatory interests. These issues were imposed as license conditions in the FOLs, with deadlines for their implementation. Since the units were licensed to operate in the 1980s, most of these license conditions have been fulfilled. The licensee's December 18,1997, submittal and January 26,1998, supplement are reviewed below; the item numbers before each paragraph denote the paragraph number in the FOLs. Unless otherwise stated, the evaluation below pertains to both Units 1 and 2.
For the license conditions that have been fulfilled, the licensee proposed to have them deleted entirely from the FOLs. The staff, however, believes that indications should be left in the FOLs to provide easy reference to these past license conditions. For those license conditions that the staff agrees have been fulfilled and that their deletion is administrative and acceptable, the staff will preserve the license condition numbers with the word " Deleted" following in parentheses.
Hence, the licensee's proposed change is partially denied.
1.B.
The licensee proposed to modify the statement, which currently reads " Construction of the Catawba Nuclear Station, Unit 1 (the facility) has been substantially completed.. " to " Construction of the Catawba Nuclear Station, Unit 1 (the facility) was 9805040024 900423 PDR ADOCK 05000413 P
2-completed...." The staff surveyed FOLs granted to other facilities, and found that the expression "has been substantially" is used in each FOL, and its meaning is thus established by such repeated use. The licensee has not provided any reason for the proposed change, other than stating that this is an administrative change to " update the FOL to the current historical status." This proposed change is thus denied.
1.H.
The licensee proposed to delete the clause " subject to the conditions for protection of the environment set forth in the Environmental Protection Plan attached as Appendix B." The Environmental Protection Plan was deleted from the Unit 1 FOL by Amendment No.149, and from the Unit 2 FOL by Amendment No.143, both dated July 8,1996 (filed under TACs M90838 and M90839). Thus, deletion of the cited clause has no impact on the FOLs, is administrative, and is acceptable.
2.A.
The licensee proposed to delete the words "and in its Environmental Report, as supplemented and amended through Revision No. 6" from the Unit 1 FOL, and the words "and in its Environmental Report, as supplemented and amended" from the Unit 2 FOL. In the justification for this deletion, the licensee stated that the Environmental Protection Plan has been deleted, which is correct as stated above in 1.H. However, the licensee gave no justification for deleting the reference to the Environmental Report, which has been required by the National Environmental Policy Act and 10 CFR Part 51, and was a significant part of the basis for granting the FOLs.
This proposed change is denied.
2.C.(1)
The licensee proposed to modify the statement on maximum power level from
" reactor core power levels not in excess of 3411 megawatts thermal" to "a reactor core full steady state power level of 3411 megawatts thermal." The staff surveyed a number of FOLs (Table 1 attached) and found that they fall into two categories: those with " steady-state" and those without. Observation of Table 1 shows that (1) in general, older FOLs tend to have " steady state;" (2) since 1980, FOLs tend to have no " steady state;" (3) when older FOLs were reissued as full-term FOLs, " steady state"is retained; and (4) no uniformity in " steady state"in the split between units at Beaver Valley, St. Lucie, and Turkey Point. Thus, it appears that while there may be a pattem over time with the use of this term, there does not appear to be any clearly defined intent.
Since the licensee had analyzed, and the staff had evaluated, the units at power levels up to 5 percent higher than the maximum (reference various sections of the Catawba Final Safety Analysis Report and Safety Evaluation Report, NUREG-0954) authorized in the FOLs, the issue here is not one of safety, in a publicly available intemal memorandum, E. L. Jordan to E. J. Brunner, et al. (Regional offices), dated August 22,1980, the following guidance was stated:
The average power level over any eight hour shift should not exceed the
" full steady-state licensed powu level"(and similarly worded terms). The exact eight hour periods defined as " shifts" are up to the plant, but should not be varied from day to day (the easiest definition is a normal shift manned by a particular " crew").
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3-The staff's inspection Procedure 61706, " Core Thermal Power Evaluation,"
consistently associates maximum thermal power with ' steady-state'. It makes no distinction between plants whose FOLs have ' steady-state,' and those whose FOLs have not, it would appear that there is no difference between FOLs which have ' steady-state' and those which have not. Otherwise, the staff's guidance documents cited above would not be applicable to some plants. On the basis of the above discussion, the staff agrees that the licensee's proposed wording is acceptable. This change would bring Catawba's FOLs in line with the wording used in most FOLs (Table 1), and would permit the licensee to use the staff's guidance cited above.
2.C.(1)
(Unit 1) The licensee proposed to delete the reference to Attachment i regarding preoperational tests, startup tests, and other items. Note that Attachment 1, last revised by Amendment No.16 (October 21,1986), contains only requirements on TDI diesel engines; there are no "preoperational tests, startup tests" requirements currently in Attachment 1. As stated in Section 2.3 of this evaluation, all requirements currently imposed by Attachment i have been fulfilled. Thus, the deletion of the reference to Attachment 1 is administrative and is acceptable, 2.C.(2)
The licensee did not request any change on this condition, which endorses the l
Technical Specifications. Due to recently issued amendments, the highest Amendment numbers for Unit 1 and Unit 2 should be No.163 and No.155, respectively. The staff will issue the revised FOLs with these correct numbers.
2.C.(3)
The licensee proposed to delete the license condition pertaining to the initial Startup Test Program. This license condition was fulfilled, as documented in the Startup i
Report dated September 27,1985 (for Unit 1), and November 17,1986 (for Unit 2).
j The deletion of this license condition and its associated footnote (for the Unit 1 FOL, marked with two asterisks) is purely administrative and is acceptable.
The footnote (marked with one asterisk) pertains to license condition 2.C.(3) and others in the FOL. Since all other license conditions covered by this footnote are deleted (see evaluations below), except license condition 2.C.(8) for Unit 1 and i
2.C.(6) for Unit 2, the subject footnote is reworded editorially to reflect such. This change is acceptable.
2.C.(4)
The licensee proposed to renumber this license condition, pertaining to antitrust conditions, to 2.C.(3) due to deletion of 2.C.(3) discussed above. However, as stated in the second paragraph of this section, all license condition numbers will be preserved. Hence, the licensee's proposed change is denied.
2.C.(5)
(Unit 1) The licensee proposed to delete this license condition pertaining to inservice testing of pumps and valves. This license condition granted temporary reliefs in response to the licensee's requests. The reliefs were later granted by the staff (letter, B. J. Youngblood to H. R. Tucker, dated January 8,1987), thus obviating the need for
0 o the temporary f eliefs. Also, the applicable time frame (first 10 years of unit operation) for the reliefs has expired. Thus, the license condition is no longer needed; its deletion is administrative and acceptable.
2.C.(6)
(Unit 1) The licensee proposed to delete this license condition and footnote pertaining to the inservice inspection program, requiring submittal of material by January 8,1985.. The material was submitted by the licensee, and approved by the staff (letter, D. B. Matthews to H. B. Tucker, dated November 3,1989). Also, the applicable time frame (first 10 years of unit operation) for the inservice inspection program has expired. Thus, the license condition is no longer needed; its deletion is administrative, and acceptable.
2.C.(5)
(Unit 2) The licensee proposed to delete this license condition pertaining to the inservice inspection program, requiring submittal of material by January 8,1985. The material was submitted by the licensee and approved by the staff (letter, D. B. Matthews to H. B. Tucker, dated November 3,1989). Also, the applicable time frame (first 10 years of unit operation) for the inservice inspection program has expired. Thus, the license condition is no longer needed; its deletion is administrative, and acceptable.
2.C.(7)
(Unit 1) The licensee proposed to delete this license condition pertaining to environmental equipment qualification. The licensee listed documents docketed with the NRC regarding compliance with the subject regulation,10 CFR 50.49. The staff's evaluation of the licensee's compliance was published in the Catawba Safety Evaluation Report (NUREG-0954) and supplements, and Inspection Reports such as 50-413,414/86-26, 88-07, 89-20, etc. The licensee has thus fulfilled this license condition. Its deletion is administrative and acceptable.
2.C.(8)
(Unit 1) The licensee proposed to renumber this to be license condition 2.C(4) due to deletion of previous license conditions. However, as stated in the second paragraph of this section, alllicense condition numbers will be preserved. Hence the licensee's i
proposed change is denied.
The licensee also proposed to correct the reference of "SER [ Safety Evaluation Report, NUREG-0954] through Supplement 6" to "SER through Supplement 5." The staff consulted the referenced documents and confirmed that Supplement 6 contains no evaluation on fire protection; the last evaluation on fire protection was set forth in Supplement S. The proposed change corrects a typographical error and is 1
acceptable.
2.C.(6)
(Unit 2) The licensee proposed to renumber this to be license condition 2.C.(4) due to deletion of previous license conditions. However, as stated in the second paragraph of this section, all license condition numbers will be preserved. Hence, the licensee's j
proposed change is denied.
1 The licensee also proposed to correct a typographical error to the reference of "SER through Supplement 6." See evaluation for 2.C.(8) for Unit 1.
'4 o l 2.C.(9)
(Unit 1) The licensee proposed to delete this license condition pertaining to protection from turbine missiles. The licensee fulfilled this requirement by a submittal, H. B. Tucker to H. R. Denton, dated April 24,1986. The staff approved the licensee's submittal by letter, K. N. Jabbour to H. B. Tucker, dated June 2,1987. Thus, the deletion of this license condition is administrative and is acceptable.
2.C.(10) (Unit 1) The licensee proposed to delete this license condition, which imposed requirements on operating staffing and experience. The requirements for shift staffing and personnel qualification are set forth by Technical Specifications Table 6.2-1, Minimum Shift Crew Composition; Section 6.2.2, Unit Staff; Section 6.2.4, Shift Manager; and Section 6.3, Unit Staff Qualifications. (Note that the '
term ' advisor"in this license condition has been replaced by the position Shift MPAager, whose functions include those of a Shift Technical Advisor.) On the basis that appropriate requirements that already exist in the Technical Specifications, the j
staff agrees that license condition 2.C.(10) is no longer needed and its deletion is acceptable.
j 2.C.(11) (Unit 1) The licensee proposed to delete this license condition conceming detailed control room design review; specifically, correct all human engineering deficiencies according to the schedule contained in the licensee's letter of February 20,1984. In a letter, H. B. Tucker to T. E. Murley, dated April 18,1989, the licensee advised the staff that the activities related to this license condition have been completed. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(7) (Unit 2) Same discussion as 2.C.(11) above for Unit 1.
2.C.(12) (Unit 1) Part (a) of this license condition has been previously deleted by Amendment. No.106 on March 23,1993. To distinguish the previous deletion from those addressed by this safety evaluation, the staff will add the designation "by Amendment No.106" after the word " Deleted." Part (b) requires that the Safety Parameter Display System (SPDS) be operational before April 1,1985. By letter, H. B. Tucker to H. R. Denton, dated March 15,1985, the licensee advised the staff that the SPDS has been declared operational. Thus, the requirement imposed by Part (b) of this license condition has been fulfilled; its deletion is administrative and is acceptable.
2.C.(8)
(Unit 2) Part (a) of this license condition has been previously deleted by Amendment. No.100 on March 23,1993. To distinguish the previous deletion from those addressed by this safety evaluation, the staff will add the designation "by Amendment No.100" after the word " Deleted." Part (b) requires that the SPDS be operational before December 8,1989, with four modifications. By letter, H. B. Tucker to NRC, dated February 18,1988, the licensee advised the staff that the modifications will be implemented. By letter, S. A. Varga to H. B. Tucker, dated May 13,1988, the
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- staff informed the licensee that its proposed modifications were acceptable for resolution of the outstanding SPDS issues. Thus, the requirements imposed by Part (b) of this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(13) (Unit 1) This license condition requires the licensee, before reaching 70 percent power (during startup), to perform turbine trip tests to verify that power-operated relief valves (PORVs) will not be challenged when the anticipatory trip bypass is in effect.
l The results of these tests were detailed in the Catawba Unit 1 Startup Report, which l
stated that the PORVs were not challenged. The Startup Report was submitted to the staff on September 27,1985. Thus, the requirement imposed by this license l
condition has been fulfilled; its deletion is administrative and is acceptable.
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2.C.(9)
(Unit 2) This license condition requires the licensee, before reaching 70 percent power (during startup), to perform turbine trip tests to verify that PORVs will not be challenged when the anticipatory trip bypass is in effect. The results of these tests were detailed in the Catawba Unit 2 Startup Report, which stated that the PORVs l
were not challenged. The Startup Report was submitted to the staff by letter, H. B.
l Tucker to J. N. Grace, on November 17,1986. Thus, the requirement imposed by this license condition has been fulfilled; its deletion is administrative and is I
acceptable.
2.C.(14) (Unit 1) The licensee proposed to delete this license condition pertaining to analyses and tests on in-containment hydrogen control measures. This license condition has l
been fulfilled, as documented in Revision 16 of the licensee's report "An Analysis of l
Hydrogen Control Measures at McGuire Nuclear Station," submitted to the staff by l
letter, M. S. Tuckman to NRC, dated August 5,1993. Revision 16 incorporates the staff's safety evaluation dated May 26,1993, and closed the hydrogen issue for both l
McGuire and Catawba Nuclear Stations. Thus, the requirements imposed by this l
license condition have been fulfilled; its deletion is administrative and is acceptable.
l 2.C.(15) (Unit 1) This license condition requires the licensee, following the first refueling outage, to compicte upgrade of the existing subcooling margin monitor and the existing backer display. By letter, H. B. Tucker to H. R. Denton, the licensee advised i
the staff of the sompletion status of these upgrades. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is
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acceptable.
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2.C.(16) (Unit 1) This license condition requires the licensee, before startup from the second refueling outage, to submit an analysis that would demonstrate that the steam generator tube rupture accident presented in the Final Safety Analysis Report is the most severe case with respect to release of fission products and calculated doses.
Accordingly, the licensee made a series of submittals starting on December 7,1987, culminating in the staff's issuance of license Amendment No. 68. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
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. 2.C.(10) (Unit 2) This license condition requires the licensee, before startup from the first refueling outage, to submit an analysis that would demonstrate that the steam generator tube rupture accident presented in the Final Safety Analysis Report is the most severe case with respect to release of fission products and calculated doses.
Accordingly, the licensee made a series of submittals starting on December 7,1987, culminating in the staff's issuance oflicense Amendment No. 62. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(17) (Unit 1) This license condition requires the licensee, before startup following the first refueling outage, to submit the results of a completed program of tests and analyses -
to confirm the validity and accuracy of the models and assumptions employed in the containment response analysis for main steam line break accidents. It also requires that, during the interim period of operation, the licensee to submit bimonthly reports on the progress of the confirmatory research program of tests and analyses regarding containment response for these accidents. By letter, R. E. Martin to M. S. Tuckman, dated June 10,1991, the staff issued its safety evaluation on the licensee's and Westinghouse's submittals, stating that the specific analyses performed for Catawba were acceptable. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(18) (Unit 1) This license condition requires the licensee, before startup following the first refueling outage, to upgrade the PORVs and steam generator PORVs to safety related. The licensee affirmed its commitment by letter, H. B. Tucker to H. R. Denton, dated March 21,1985. In its letter of December 18,1997, the licensee advised that the modifications were completed (site documents NSM 10523 and 10524). Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(19) (Unit 1) This license condition requires that a " seismic test will be performed utilizing a generic mounting scheme with a Gl.ASTIC pad and fiberglass bushing for electrical isolation to verify the acceptability of the existing mounting. This test will be completed by July 1985." By letter, H. B. Tucker to H. R. Denton, dated June 24, 1985, the licensee advised the staff that testing associated with this license condition had been completed. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(20) (Unit 1) The licensee did not request any changes to this license condition, which was previously introduced by Amendment No.16 (October 21,1986) to address TDI diesel engines, and later deleted by Amendment No.119, dated June 2,1994.
However, as explained in the second paragraph of this section, the staff is interested in preserving the history of the changes. Hence, the staff will add the phrase
" Amendment No.119" after the word " Deleted."
2.C.(11) (Unit 2) The l'censee did not request any changes to this license condition, which was previously introduced by Amendment No.18 (May 26,1987) to address TDI diesel engines, and later deleted by Amendment No.113, dated June 2,1994.
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.. However, as explained in the second paragraph of this section, the staff is interested in preserving the history of the changes. Hence, the staff will add the phrase
" Amendment No.113" after the word " Deleted."
2.C.(21) (Unit 1) This license condition requires the licensee to submit responses to and implement the requirements of Generic Letter 83-28 (regarding the Salem anticipated j
transient without scram event) on a schedule given in the licensee's letters. The licensee accordingly submitted information, which led to a number of NRC issuances approving design and implementation (see the listing of these issuances in the H
licensee's December 18,1997, letter). The staff's own Safety Issues Management System (SIMS) database dated December'15,1997, indicates that all the requirements associated with Generic Letter 83-28 have been implemented by the I
licensee. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
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2.C.(12) (Unit 2) Identical to eva!uation above for Unit 1,2.C.(21).
2.C.(22) (Unit 1) This states that "[i]n the event that the NRC finds that the lack of progress in completion of the procedures in the Federal Emergency Management Agency's l
[ FEMA) final rule,44 CFR Part 350, is an indication that a major substantive problem l
exists in achieving or maintaining an adequate state of [ emergency) preparedness, i
l the provisions of 10 CFR Section 50.54(s)(2) will apply." In letters dated October 8, 1985 and August 15,1986, FEMA advised the NRC of the approval of the North and South Carolina emergency response plans. Thus, the requirements imposed by this license condition have been fulfilled by FEMA's approval; its deletion is administrative and is acceptable.
2.C.(23) (Unit 1) This license condition requires that the licensee submit for staff review, by June 4,1985, information regarding emergency preparedness, such as public information, waming signs r.nd decals, early notification, etc. By letters, H. B. Tucker j
to H. R. Denton, dated March 18 and June 12,1985, the licensee submitted the required information. By letters T. M. Novak to H. B. Tucker, dated May 14 and June 3,1985, the staff issued its approval. Thus, the requirements imposed by this license condition have been fulfilled; its deletion is administrative and is acceptable.
2.C.(24) (Unit 1) This license condition refers to Appendix D, which was introduced by t
l Amendment No.159. Appendix D was last changed by Amendment No.161. The licensee pointed out that the license condition still refers to Appendix D as "through Amendment No.159." The licensee's current proposed changes will lead to Amendment No.164. Accordingly, the staff will correct the Amendment number to 164. This correction is administrative and acceptable.
The licensee proposed to renumber this license condition as 2.C.(5) due to deletion of previous license conditions. However, as stated in the second paragraph of this section, all license conditio, numbers will be preserved. Hence, the licensee's proposed change is denied.
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, 2.C.(13) (Unit 2) This license condition refers to Appendix D, which was introduced by Amendment No.151. Appendix D was last changed by Amendment No.153. The licensee pointed out that the license condition still refers to Appendix D as "through Amendment No.151." The licensee's current proposed changes willlead to Amendment No.156. Accordingly, the staff will correct the Amendment number to 156. This correction is administrative and acceptable.
The licensee proposed to renumber this license condition as 2.C.(5) due to deletion of previous license conditions. However, as stated in the second paragraph of this section, all license condRn numbers will be preserved. Hence, the licensee's proposed change is denie:J.
2.E The licensee proposed to revise this license condition in both Unit 1 and Unit 2 FOLs, changing "... Commission-approved physical security, guard training and qualification, and safeguards contingency plans..." to two plans, and revising the titles as the following:
" Nuclear Security and Contingency Pian, -which contains safeguards information and is protected under 10 CFR 73.21. Th;s revision was submitted to the staff by letter dated April 18,1996, from M. S. Tuckman.
" Nuclear Security Training and Qualification Plan,"- which does not contain safeguards information. This revision was submitted to the etaff by letter dated April 19,1996, from M. S. Tuckman.
The licensee also proposed to delete any reference to revision numbers since these security plans are subject to change periodically. However,10 CFR 50.54(p) has set forth the conditions under which the licensee may make changes without NRC approval, and the conditions under which changes need to be approved via an amendment to the license prior to implementation. The references to revision numbers do not prevent the licensee from making changes allowed by this regulation.
Hence, the licensee's proposal to omit revision numbers and dates is der.id.
The licensee also proposed an editorial change; to delete an extra "CFR" from both FOLs. This change is acceptable.
2.F (Unit 1) This license condition specifies the method und timing for reporting of violations of Section 2.C of the FOL. Currently, it reads " Duke Energy Corporation shall report any violations of the requirements contained in Section 2, items C.(1),
C.(3) through C.(23) of this license. Initial notification shall be made within twenty-four (24) hours in accordance with the provisions of 10 CFR 50.72 with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73(b),
(c) and (e)." The licensee proposed to revise this condition to read "Except for item 2.C.(2), Duke Energy Corporation shall report any violations of the requirements contained in Section 2.C of this license h the following manner. Initial notification shall be made within twenty-four (24) hours to the NRC Operations Center via the
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. Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c) and (e)."
(Unit 2) The licensee proposed to delete the reference to the Environmental Protection Plan, which was previously deleted by Amendment No.143 (see License Condition 1.H. above). This deletion is administrative. The licensee also proposed to replace the reference to the Technical Specifications with item 2.C.(2), which is the license condition for the Technical Specifications of the FOL. This change is administrative.
For both units, the proposed wording complies with the cited regulations, does not change the substance of the requirements expressed by the original wording and is in line with recently issued FOLs such as Watts Bar Unit 1. The proposed changes are acceptable.
2.2 Exemptions The FOLs convey a number of exemptions to certain NRC regulations. Some of these exemptions have expired due to built-in time limits, while others are no longer needed. For these exemptions that are no longer needed, the licensee proposed to have them deleted entirely from the FOLs. The staff, however, believes that indications should be left in the FOLs i
to provide easy reference to these past exemptions. The staff will preserve the exemption numbers with the word " Deleted" following in parentheses. Hence, the licensee's proposed complete deletion is partially denied.
2.D The licensee proposed to delete from the opening statement references to 10 CFR Part 50, Appendices A and E, leaving only Appendix J in the statement. Since the exemptions to Appendices A and E are to be deleted (see below), there is no more need to mention these appendices. The deletion is administrative and acceptable.
(Unit 1) The licensee proposed to add these additional words to indicate where detailed information may be found regarding these exemptions: "as delineated below and pursuant to evaluations contained in the referenced SER and SSERs." These additional words editorially improve the opening sentence and are acceptable. The Unit 2 sentence already contains these words and therefore needs no such change.
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'2.D.(a)
(Unit 1) This exempted the licensee from General Design Criterion 1 of Appendix A, with respect to the upgrade to safety-related of the pressurizer PORVs and steam generator PORVs until the first refueling outage. As discussed above under License Condition 2.C.(18), the licensee has completed the upgrade. Thus, the exemption is no longer needed; its deletion is administrative and acceptable.
2.D.(b)
(Unit 1) This exempted the licensee from the requirements of Appendix E insofar as I
they require active participation of all Crisis Management Center personnel for emergency preparedness exercises. The licensee s'.ated in its December 18,1997, letter that this exemption is no longer needed since the Emergency Operations Facility personnel now drill in accordance with 10 CFR Part 50, Appendix E (reference
a u letter, W. R. McCollum to NRC, dated September 16,1996, transmitting change 96-3 of the Catawba Emergency Plan).. The staff agrees that the exemption is no longer needed based on the licensee's information; its deletion is acceptable.
2.D.(c)
(Unit 1) The licensee proposed to renumber this exemption as 2.D.(a) due to deletion of previous exemptions. However, as stated in the first paragraph of this section, all exemption numbers will be preserved. Hence, the licensee's proposed change is
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denied.
2.D.(d)
(Unit 1) The licensee proposed to renumber this exemption as 2.D.(b) due to deletion of previous exemptions. However, as stated in the first paragraph of this section, all exemption numbers will be preserved. Hence, the licensee's proposed change is i
denied.
l 2.D.(e)
(Unit 1) The licensee proposed to renumber this exemption as 2.D.(c) due to deletion of previous exemptions. However, as stated in the first paragraph of this section, all l
exemption numbers will be preserved. Hence, the licensee's proposed change is i
denied.
l 2.D (Unit 1) The licensee proposed to revise the wording of the first sentence of the closing statement, currently cited verbatim from 10 CFR 70.14(a). The exemptions j
that this statement covers are all granted against 10 CFR Part 50. Hence, the i
wording from 10 CFR 50.12(a) would be more appropriate. Accordingly, the statement will be changed from:
"These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest."
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to:
"These exemptions are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and are consistent with certain special circumstances, as discussed in the referenced SER and SSERs."
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The revised wording conforms with 10 CFR 50.12(a) and the current wording in the Unit 2 FOL, and is acceptable.
2.D (Unit 2) The licensee proposed a number of editorial changes involving punctuation marks and revised wording. The staff reviewed each of these proposed changes and found that they editorially improve sentence structure without changing the meaning.
Thus, these proposed editorial changes are acceptable.
The licensee proposed to delete the mention of two exemptions. The first exemption was granted separate from the FOL on April 23,1985, regarding 5.rotection of certain structures, systems, and components from the dynamic effects associated with
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I postulated reactor coolant system pipe breaks (General Design Criterion 4 of Appendix A,10 CFR Part 50). The FOL also stated that this exemption was no longer required since the subject regulation was revised on May 12,1986 (3 days before issuance of the FOL), and that the licensee had met the revised rule. Thus, deletion of its mention in the Unit 2 FOL is administrative and acceptable.
The second mention refers to an exemption granted on January 17,1985, as part of the Unit 1 FOL. See 2.D.(b) for Unit 1 above for its deletion from the Unit 1 FOL.
Since the exemption is deleted, the deletion of its mention in the Unit 2 FOL is administrative and acceptable.
2.3 Attachment 1 to Unit 1 FOL Attachment i for the Unit 1 FOL was revised by Amendment No.16 (October 21,1986) to solely impose requirements on TDI diesel engines. Attachment 1 for the Unit 2 FOL was revised by Amendment No.17 (May 26,1987) to solely impose requirements on TDI diesel engines.
As stated above, the License Conditions 2.C.(20) for Unit 1 and 2.C.(11) for Unit 2, which endorsed Attachment 1, have been deleted by Amendments 119 (Unit 1) and 113 (Unit 2). was inadvertently not deleted when these amendments were issued. The proposed deletion of Attachment 1 corrects a previous administrative error, and is acceptable.
2.4 Appendir D See evaluations above for Unit 1 License Condition 2.C.(24) and Unit 2 License l
Condition 2.C.(13).
Appendix D contains two requirements. The licensee proposed to delete the first requirement, which was introduced by Amendment Nos.159 (for Unit 1) and 151 (for Unit 2). This
"... requires the licensee to incorporate in the Updated Final Safety Analysis Report (UFSAR) certain changes to the description of the facility, implementation of this amendment is the incorporation of these changes as described in the licensee's application dated March 7,1997, as supplemented by letters dated April 2,10,16,22, and 28,1997, and evaluated in the staff's l
Safety Evaluation dated April 29,1997." The staff had reviewed the licensee's 1997 update to f
the UFSAR and, in Section E3.2 of Inspection Report 50-413,414/97-15, confirmed that the licensee had fulfilled this requirement. Thus, the deletion of this requirement from Appendix D is administrative and is acceptable.
3.0- STATE CONSULTATION in accordance with the Commission's regulations, the South Carolina State official, Mr. Virgil I
Autrey, was notified of the proposed issuance of the amendments. The State official had no comments.
i de j
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4.0 ENVIRONMENTAL CONSIDERATION
l Pursuant to 10 CFR 51.21,51.32, and 51.35, an Environmental Assessment and Finding of No Significant impact was published in the Federal Reaister on April 22,1998 (63 FR 19%3).
Accordingly, based on the Environmental Assessment, the Commisison has determined that issuance of this amendment will not have a significant effect on the quality of the human environment.
i I
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is l
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.
Attachment:
Survey of FOLs for the Term " Steady State" (Table 1) l Principal Contributors: Peter S. Tam Barry R. Manili Richard M. Pelton Carole Jamerson Date: April 23,1998 l
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1
,e l
l l
Table 1: Survey of FOLs For The Term ' Steady State' FOL lssuance Date PJant
'Steadv State' 70/10 Point Beach 1 N
70/09 Robinson 2 Y
71/01 Dresden 3 Y
l 71/12 Quad Cities 1 N
72/07 Turkey Point 3 Y
l l
72/04 Davis-Besse 1 Y
72/05 Surry 1 Y
i 72/09 Pilgrim Y
72/12 Quad Cities 2 N
l 73/02 Vermont Yankee N
l 73/12 Kewaunee Y
l 73/04 Turkey Point 4 N
l 73/09 Indian Point 2 Y
l 73/06 Browns Ferry 1 Y
73/10 Peach Bottom 2 Y
73/01 Surry 2 N
73/08 Ft. Calhoun Y
73/03 Point Beach 2 N
74/01 Cooper Y
74/07 Peach Bottom 3 Y
l 74/07 Oconee 1, 2, 3 Y
I 74/06 Browns Ferry 2 Y
74/10 Prairie Island 2 Y
74/05 Arkansas 1 Y
l 74/02 Duane Arnold Y
l 74/04 Prairie Island 1 Y
l 74/04 TMI1 Y
74/12 Haddam Neck Y
74/12 Nine Mile ' Point Y
75/12 Big Rock Y
j 76/07 Beaver Valley 1 Y
76/12 Salem 1 Y
l 76/03 Cook 1 Y
l 76/08 Browns Ferry 3 Y
l 76/03 St. Lucie 1 Y
l 77/01 Crystal River Y
77/12 Cook 2 Y
78/04 North Anna 1 Y
78/10 Arkansas 2 Y
80/09 Sequoyah1 N
81/06 McGuire 1 N
81/05 Salem 2 Y
81/01 Monticello Y
Attachment
N
,. FOL lasuance Date Elant
'Steadv State' 82/11 San Onofre 3 N
l 82/12 Susquehanna1 N
83/06 St. Lucie 2 N
83/03 McGuire 2 N
83/12 Washington Nuclear 2 N
84/10 Callaway 1 N
84/10 Grand Gulf N
84/11 Diablo Canyon 1 N
84/03 Susquehanna 2 '
N 84/12 (full-term)
Ginna Y
I 85/06 Wolf Creek 1 N
85/11 River Bend N
85/06 Palo Verde 1 N
85/07 Fermi 2 N
85/08 Limerick 1 N
85/03 Waterford N
85/01 Catawba 1 N
86/07 Hope Creek N
i 86/11 Perry N
i 86/04 Palo Verde 2 N
86/05 Catawba 2 N
86/10 (full-term)
Millstone 1 Y
87/08 Beaver Valley 2 N
87/01 Shearon Harris 1 N
i 87/11 Palo Verde 3 N
87/04 Clinton 1 N
88/03 South Texas 1 N
89/03 South Texas 2 N
89/08 Limerick 2 N
90/04 Comanche Peak 1 N
91/02 (full-term)
Palisades Y
91/02 (full-term)
Dresden 2 Y
93/04 Comanche Peak 2 N
96/02 Watts Bar 1 N
97/07 (full-term)
Oyster Creek Y