ML20249B393

Responds to 980326 RAI Re Pressure/Temp License Amend Request, .Proposed Tech Specs Pages Re RCS Overpressure Protection,Rcs SRs & Eccs,Encl

ML20249B393
Person / Time
Site:	Catawba
Issue date:	06/15/1998
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20249B394	List: ML20249B393 ML20249B396
References
RTR-NUREG-1431 TAC-M99629, TAC-M99630, NUDOCS 9806230020
Download: ML20249B393 (8)

Text

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I g Duke Power CImpany LM -

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"**"F 526 South Church Street P.O. Box 1006 Charlotre, NC 28201-1006 M. S. Tuckman Executiw Vice hident (704)382-2200 omcr Nudear Generation (704) 382-4360 !^X June 15, 1998

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U.S. Nuclear Regulatory Commission I Attention: Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 I Docket Numbers 50-413 and 50-414 Reply to Staff Position and Request for Additional Information on Amendment Request Regarding Pressure / Temperature Limits TAC Numbers M99629 and M99630 I

Reference:

Letter from Peter S. Tam, NRC, to Gary R.

Peterson, Duke, same subject, dated March 26, 1998.

Duke Energy Corporation License Amendment Request Submittal, dated September 15, 1997.

Pursuant to 10CFR50.4 and 10CFR50.90, Duke Energy Corporation is hereby responding to Questions 1 and 2 of the NRC request for additional information contained in the March 26, 1998 reference. Duke's responses to Questions 3 and 4 of the subject request were previously provided via separate correspondence dated April 27, 1998.

The enclosed information contains a restatement of Questions 1 and 2, followed by Duke's response. This response includes, where applicable, revised proposed changes to the Technical Specifications.

The proposed changes contained in the enclosed License Amendment Request (LAR) apply to Technical Specifications 3.4.9.3, Reactor Coolant System Overpressure Protection; Proposed 4.4.9.3.3 and 4.4.9.3.4, Reactor Coolant System Surveillance Requirements; and 3.5.3, Emergency Core Cooling Systems. The proposed changes affect the requirements for low-temperature overpressure protection by adding: 1) more restrictive requirements for the accumulator discharge valves, 2) more restrictive requirements i 7

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June 15,)-1998-Page 2 ,

on pumps capable of injecting into the reactor coolant system,-

~3) thenlowest. reactor. coolant system temperature justified by the Low Temperature Overpressure Protection . (LTOP) analysis, and L4),more restrictive requirements on reactor coolant pump

. operation during LTOP. conditions. Also, the addition of surveillance requirements associated with the proposed changes are' included in this submittal package. Additionally, a footnote L

addressing the maximum number of operable charging pumps / safety

, injection pumps during-LTOP, conditions is revised by the proposed amendment.

The proposed mmendment for conversion of the current Catawba

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. Technical Specifications to~the Catawba Improved Technical Specifications was submitted to the NRC by Duke letter dated May 27, 1997. The' changes proposed in this' reply will apply to both

'the' current Catawba'Technica1' Specifications and the Catawba Improved Technical Specifications. Consequently, as described below,' this amendment package contains the affected pages from both versions of the. Technical Specifications.

The contents of this~ reply letter are as follows

,. Enclosure 1 is a restatement of the NRC request for additional information.for Questions 1 and 2, followed by Duke's reply and

[ technical justification forlthe additional proposed Technical

, Specifications.

. Attachments la and lb provide a marked copy of the affected

, current. Technical' Specifications pages for Catawba Units 1 and E 2, respectively, showing the proposed changes. Attachments 2a ,

'and 2b are reprinted pages of the affected current Technical '

r Specifications.pages,for Catawba Units 1 and 2 respectively.

l i Attachments 2a and 2b'also include'those reprinted pages that cy .

were part of'the original September 15, 1997 submittal package I f$~ referenced above.

,, ' Attachments-2c and 2d' provide a revised copy of the Improved

o. Technical Specifications submittal documentation for Catawba Li C

. Units'1 and 2,'respectively, showing the proposed changes.

, Included in! Attachments 2c and'2d are revised pages of the q current: Technical Specifications markups as included in the  ;

Improved Technical Specifications conversion submittal. Also included in' Attachments 2c and 2d'are revised pages of the

.affected. Improved Technical Specifications pages. Finally,

!. revised pages of the affected markups of NUREG-1431, Revision 1, i- Standard Technical Specifications, Westinghouse Plants, are also L

o c C___________1___________.________-__-----._____-.__.- - - - _ _ J

U.S. Nuclear Regulatory Commission June 15, 1998 ,

Page 3 included in Attachments 2c and 2d. Note that the original submittal for the pressure / temperature limits, overpressure

. protection, and reactor vessel material surveillance program, dated September 15, 1997, did not include revised marked-up pages for the current Technical Specifications markups and the

. NUREG-1431 markups. Consequently, this supplement includes revised markups for all changes proposed both in the September 11 5 , 1997 original request and in this supplement.

' Pursuant to 10CFR50.92,. Attachment 3 contains & supplemental No l Significant Hazards Consideration Determination for the proposed l additional changes.

1 Pursuant to 10CFR51.22 (c) (9) , Attachment 4 provides a supplemental basis for categorical exclusion from performing an L Environmental Assessment / Impact Statement.

l The enclosed additional proposed changes tx) the Catawba l

Technical Specifications are in reply to the NRC request for additional-information as contained in the Marcn 26, 1998 reference. They-are technically related to the proposed I Technical Specifications changes submitted by Duke's letter; dated September 15, 1997. In addition, the enclosed changes i represent additional controls not presently included in the

- existing Technical Specifications.

Implementation of this amendment to the-Catawba Facility Operating License and Technical Specifications will impact

.the Catawba Updated Final' Safety Analysis Report (UFSAR).

Necessary UFSAR changes will be submitted in accordance with 10CFR50.71(e).

Duke.is reque.iting.that this reply and our original ~ amendment request be.ap1. roved.at the earliest possible convenience to l

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~ support our replacement of the existing' Catawba heatup and cooldown curves with the. revised curves. The current Unit 1

, curves will expire in September of 1998 based on full power b . operation. NRC approval is needed to' ensure that a forced L shutdown is-not incurred at that time.

l l L .In accordance with Duke administrative procedures and the i

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Quality Assurance Program Topical. Report, this submittal has j been reviewed and approved by the Catawba Plant Operations l Review Committee and the Duke Corporate Nuclear Safety Review j Board.. J l

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l U.S. Nuclear Regulatory Commission 1 June 15, 1998 I Page 4 f

Pursuant to 10CFR50.91, a copy of this reply is being sent to the appropriate State of South Carolina official.

Inquiries on this matter should be directed to L.J. Rudy at (803) 831-3084.

Very truly yours, tt.3.fi;~.le,___ i l

M. S. Tuckman LJR/s i Enclosure and Attachments I xc (with enclosure and attachments): l L.A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II I Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 J l

D.J. Roberts j Senior Resident Inspector (CNS) l U.S. Nuclear Regulatory Commission {

Catawba Nuclear Station P.S. Tam NRC Senior Project Manager (CNS)

U.S. Nuclear Regulatory Commission  ;

Mail Stop O-14H25 l Washington, D.C. 20555-0001 M. Batavia, Chief Bureau of Radiological Health 2600 Bull St.

I Columbia, SC 29207 i

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I U.S. Nuclear Regulatory Commission l June 15, 1998 Page 5 AFFIDAVIT l M. S. Tuckman, being du.?y sworn, states that he is Executive Vice President of Duke EL'rgy Corporation; that he is authorized on the part of said corporation to sign and file with the {

Nuclear Regulatory Commission this amendment to the Catawba  !

Nuclear Station Facility Operating Licenses Numbers NPF-35 and {

NPF-52 and Technical Specifications; and that all statements and J matters set forth herein are true and correct to the best of his knowledge.

. . M  ;- --

M. S. Tuckman, Executive Vice President Subscribed and sworn to me: Mmg

/kr Date 0AM Notary Pu81ic My commission expires: bM 22 200/ y Date j 1

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l SEAL l

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Enclosure 1 Staff Position and Request for Additional Information Catawba Nuclear Station, Units 1 and 2 Proposed Amendment on Pressure Versus Temperature Limits Duke Response to Questions 1 and 2 and Technical Justification for Additional Proposed Technical Specifications

1. Regarding restrictions assumed in Duke Energy Corporation's (Duke's) low-temperature overpressure protection (LTOP) analyses, Duke's submittal of September 15, 1997, as supplemented by letter dated March 5, 1998, d.id not address such in the Catawba Technical Specifications. These are as follows:

a. Restrictions on accumulator discharge valves.

b. Restrictions on pumps capable of injecting into the reactor coolant system for the entire LTOP range.

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c. Lowest temperature justified per LTOP analysis.

It is the staff's position that the proposed amendment cannot be approved unless Duke also proposes LTOP requirements to reflect the above restrictions.

DUKE RESPONSE AND TECHNICAL JUSTIFICATION For items la, lb, and Ic above, Duke has proposed additional changes to the Catawba Technical Specifications requirements to

. address these issues. The three additional requirements represent controls not presently included in Technical Specifications. They therefore represent additional conservatism imposed upon plant operation by the Technical Specifications.

Items la and lb have already been included in Catawba's Improved i Technical Specifications (ITS) conversion submittal of May 27, 1997. The Technical Justification included in the ITS submittal i remains applicable to these changes. Note that Duke has also proposed to correct the erroneous footnote associated with Technical Specification 3/4.5.3 (ECCS Subsystems - Tavg < 350 F) by changing the designated "and" to an "or". This will make this footnote consistent with other LTOP requirements in the Technical Specifications and with the Catawba LTOP analysis.

For Item lc the proposed additional Technical Specifications provide protection against cold overpressure of the reactor

( coolant system based on the peak pressure from the limiting l

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steady state condition mass-addition transient from a single safety injection pump with no reactor coolant pumps running. This also highlights the lower reactor system temperature limits that l could be approached under extreme winter time outage conditions.

l This helps to ensure that the Appendix G limits are not exceeded.

The issues identified by Items la and lb are currently being addressed administratively by existing Duke procedures.

Consequently, the proposed additional Technical Specifications addressing Items la and lb represent no substantial change to current operating practices. The issue identified by Item lc will result in more conservative operational requirements in the Technical Specifications and in the resultant implementing station procedures.

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2. Does Duke's analysis depend on restrictions on the number of reactor coolant pumps operable during different temperature ranges? If so, it is the staff's position that appropriate l requirements must be added to the Technical Specifications.

DUKE RESPONSE AND TECHNICAL JUSTIFICATION Yes, the Appendix G curves are evaluated for the fracture toughness of the beltline region of the reactor vessel. The signals used to generate the pressure setpoint originate from wide range pressure transmitters NCPT5120 and NCPT5140 for pressurizer power operated relief valves (PORVs) NC34A and NC32B, respectively. These instruments are associated with the hot legs of the Reactor Coolant System. During startup and shutdown, the reactor coolant pumps are operating and their induced flows create a pressure drop across the vessel. This pressure drop along with the difference in elevation between the beltline region and the instrumentation locations are added to the indicated pressure to determine an accurate pressure for the reactor vessel beltline region.

The difference in elevation between the beltline region and the instrumentation locations is 4.6 psi and this system error correction is accounted for in the LTOP setpoint evaluation and is conservatively applied at all time regardless of the number of reactor coolant pumps in operation.

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l The pressure drop across the reactor vessel associated with the l Ieactor coolant pump is also accounted for in the LTOP setpoint evaluation. However, the value associated with this pressure drop is dependent on the number of pumps in operation.

Pumps Pressure Drop On (psid) )

4 56.9 3 34.7 2 16.8 1 4.8 0 1 Factored into these numbers as a conservatism is the flow dp effects of two trains of residual heat removal also in operation.

To realize the benefit of the pressure drop being dependent on the number of reactor coolant pumps in operation, the LTOP setpoint evaluation has accounted for this during different temperature regions. Plant operational procedures have been modified to adhere to the pump restriction as dictated by the LTOP evaluation.

Duke has proposed additional changes to the Catawba Technical Specifications to address this issue. The proposed reactor coolant pump operating restrictions are already being controlled administratively at Catawba. These proposed operating restrictions represent additional controls not presently contained within the Technical Specifications. The additional restrictions provided by the proposed addition of Table 3.4-3 to the technical specifications also provide protection against cold overpressure of the reactor coolant system based on the peak pressure from the limiting steady state condition mass addition and heat addition transients with various combinations of reactor coolant pumps running. This helps to ensure that the Appendix G limits are not exceeded.

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