ML20236D503

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Application for Amends to Licenses NPF-35 & NPF-52,revising Requirements for Undervoltage & Shunt Trip Attachments to Reactor Trip Breakers & Bypass Trip Breakers,Per Generic Ltr 85-09
ML20236D503
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 03/10/1989
From: Tucker H
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236D507 List:
References
GL-83-28, GL-85-09, GL-85-9, TAC-65751, TAC-65752, NUDOCS 8903230134
Download: ML20236D503 (7)


Text

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DUKE POWER COMPANY l

- P.O. Box 33180 CitAnLOTTE, N.O. 28242 HALU. TUCKER Tatsenonu 5

voos ramesinerr (704) 0*3-4534 90fie.RAB PRODUCTHHf

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March 10, 1989 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.'C. 20555 Re: Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Technical Specification Amendment Generic Letter 85-09' 1

Gentlemen:

This letter contains a revision to a propose'd amendment dated June 19, 1987 to the Technical Specifications for Facility Operating License Nos. NPF-35 and NPF-52 for

' Catawba Units-1.and 2.

The attachment request involves the addition of Technical Specification requirements for the undervoltage and shunt trip attachments to the Reactor Trip Breakers and for the Bypas's Trip Breakers (BTBs). Duke continues to believe that BTBs surveillance need not be included in Technical Specifications.

The only apparent reason for' inclusion of BTBs surveillance in the. Technical' i

Specifications is to provide added assurance that maintenance'is' performed on the breakers; no. Action Statements or Limiting Conditions for Operation were proposed

'in Generic Letter 85-09.

The use of Technical Specifications solely to require surveillance is contrary to industry efforts to optimize the content of Technical Specifications. However, in the interest of resolving the outstanding items of Generic Letters 83-28 and 85-09, Duke agrees to include BTBs in the Technical Specifications.

The revised attachment contains the proposed change and a discussion of the l

justification and safety analysis. The analysis is included pursuant to 10 CFR 50.91 and it has been concluded that the proposed amendment does not involve significant hazards considerations, l

Pursuant to 10 CFR 50.91 (b) (1) the appropriate South Carolina State Official is j

being provided a copy of this revision to other previous amendment request, l

.Very truly yours, Ial B. Tucker o

V RWO22.D1/lcs Attachment 9

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'U. S. Nuclear Regulatory Commission March 10, 1989 1

Page Two

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Mr. S. D. Ebneter, Regional' Administrator i

U. S. Nuclear Regulatory Commission Region II 10.1 Marietta Street, NW, Suite 2900 i

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 c/o Dottie 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 INPO Records Center Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 M r. W. T. Orders NRC Resident Inspector Catawba lluclear Station

m U. S. Nuclear Regulatory Commission March 10, 1989 I

Page Three q

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A. V. Carr l

T. W. Deese R. C. Futrell E. M. Goddle R. L. Gill-G. W. Hallman I

R. M. Glover R. A. Jones P. G. LeRoy T. B. Owen J. M. McGarry L. T. Burba l

D. L. Rehn l'

A. M. Rose J. E. Thomas J. G. Torre D. L. Ward j

NC MPA-1

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NCEMC PHPA SREC

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Group File: CN-801.01

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Attaciunent I Safety Analysis.and Determination of No Significant' Hazards Considerations I

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SAFETY ANALYSIS AND DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS The proposed changes were initiated by the NRC Staff in Generic Letter 85-09.

The changes are expected to provide added assurance that the Reactor Trip Bypass Breakers (BTBs) will operate as expected, by assuring that maintenance and testing are performed regularly.

In a practical sense, no effect will be created by this amendment because the testing and maintenance are currently being performed. No safety concerns are raised by this amendment, because the amendment formalizes additional test requirements with the goal of improving safety.

The proposed change to Table 3.3-1, item 19 adds ACTION Statement 12 to the Reactor Trip Breakers. ACTION 12 is verbatim from Generic Letter 85-09 with the additional clarification of ACTION requirements when a breaker is bypassed.

Item 21 - Reactor Trip Bypass Breakers, has been added to maintain consistency throughout the Reactor l

Trip System tables. ACTION 13 for item 21 calls for verifying the operability of the reactor trip bypass breaker and if inoperable return it to OPERABLE status prior to placing it in service. No further requirements are necessary for item 21.

The proposed change to Table 4.3-1, item 1 is taken directly from the guidance provided in the Generic Letter.

Item 21 is also from the Generic Letter with the addition of the applicability of Table Notation (7) to the monthly TRIP ACTUATING DEVICE OPERATIONAL TEST. This note was added to ensure that the proper testing scheme is clearly identified for item 21.

Table Notation (11) is being modified to require the undervoltage and shunt trips be tested monthly as_ opposed to the current 18 month requirement. This is in accordance with the Generic Letter.

This test is to be done on a STAGGERED TEST BASIS in accordance with Table Notation I

(7). Table Notation (15) was modified to show that required testing is to be i

performed on a STAGGERED TEST BASIS. Table Notations (14), (15) and (16) are adopted directly from the Generic Letter.

This amendment does not involve a Significant Hazards Consideration as determined l

using the criteria of 10 CFR 50.92.

The proposed amendment will not increase the probability or consequences of any accident previously evaluated in the FSAR, or create the possibility of any new accident not previously evaluated. No hardware l

or procedure changes are being made, so no accident analysis or safety margin will be affected.

The commission provided examples of proposed amendments that are considered not likely to involve Significant Hazards Considerations (see 48 FR 14870).

This proposed amendment is similar to example (ii), a change that constitutes an additional limitation, restriction or control not presently included in the technical specifications:

for example, a more stringent surveillance requirement.

Environmental Impact The proposed Technical Specification change has been reviewed against the criteria l

10 10CFR51.22 for the environmental considerations. As shown above, the proposed 1

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SAFETY ANALYSIS AND DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS change does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or

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cumulative occupational radiation exposures.

Based on the foregoing, the proposed Technical Specification change meets the criteria given in 10CFR 51.22(c)(9) for a categorical exclusion from the. requirements for an Environmental Impact Statement.

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'1 Attachment II Proposed Technical Specification Change l

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