RA-17-0029, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers

Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers

ML17159A460
Person / Time
Site:	Catawba
Issue date:	06/08/2017
From:	Simril T Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-17-0029
Download: ML17159A460 (7)

Text

(_~ DUKE Tom Simril Vice President ENERGY9 Catawba Nuclear Station Duke Energy CN01VP I 4800 Concord Rd York, SC29745 o: 803.701.3340 Serial: RA-17-0029 10 CFR 50.90 June 8, 2017 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 I Renewed License Nos. NPF-35 and NPF-52

SUBJECT:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT MULTIPLE TECHNICAL SPECIFICATION TASK FORCE TRAVELERS

REFERENCES:

1. Duke Energy letter RA-16-0028, Catawba Nuclear Station, Units 1 and 2, Application to Revise Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers, dated December 15, 2016 {ADAMS Accession No. ML16350A422)

2. NRC email M. Mahoney to Duke Energy A. Zaremba, Request for Additional Information

-Catawba TSTF-197, dated May 12, 2017 By letter dated December 15, 2016 {Reference 1), Duke Energy Carolinas, LLC, referred to henceforth as "Duke Energy," submitted a request for amendments to the Technical Specifications {TSs) for Catawba Nuclear Station, Units 1 and 2 {CNS). In Reference 2, the NRC staff provided a Request for Additional Information {RAI) regarding the December 15, 2016, license amendment application, applicable to CNS. The Attachment provides Duke Energy's response to this RAI.

The information provided in this letter does not affect the conclusions of the significant hazards consideration or the environmental considerations included in the December 15, 2016, license amendment application.

This submittal contains no new regulatory commitments. In accordance with 10 CFR 50.91, Duke Energy is transmitting a copy of this letter and attachment to the designated State Officials.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at {980) 373-2062.

U.S. Nuclear Regulatory Commission RA-17-0029 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on

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Sincerely, Tom Simril Vice President - Catawba Nuclear Station NOE

Attachment:

Response to NRC Request for Additional Information cc (with Attachment):

C. Haney, USNRC Region II - Regional Administrator J. D. Austin, USNRC Senior Resident Inspector - CNS M. Mahoney, NRR Project Manager - CNS S. E. Jenkins, Manager, Radioactive & Infectious Waste Management, Division of Waste Management SC Dept. of Health and Environmental Control

Attachment RA-17-0029 Page 1of5 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION NRC Comment: By letter dated December 15, 2016, (Agencywide Documents Access Management System (ADAMS) Accession No. ML16350A422), Duke Energy (the licensee),

submitted an application to revise Catawba Nuclear Station, Units 1 and 2 (CNS) Technical Specifications (TS) to adopt multiple Technical Specification Task Force (TSTF) Travelers, specifically TSTF-197-A, Revision 2, "Require containment closure when shutdown cooling requirements are not met." (CAC Nos. MF8971 and MF8972)

In order to complete its review, the U.S. Nuclear Regulatory Commission staff requests the following additional information. Please provide your response to the attached request for additional information within 30 days of the date of this correspondence.

RAl-1 The Improved Standard TS markups for TS 3.9.5 Required Action A.6.2 and TS 3.9.6 Required Action B.5.2, as included in TSTF-197-A for NUREG-1431, are proposed to read: "Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System." The LAR proposes the new CNS TS 3.9.4 Required Action A.6.2 and TS 3.9.5 Required Action B.5.2 to deviate from the TSTF-197-A language, as follows: "Verify each penetration is capable of being closed on a high containment radiation signal." The LAR notes the relevant containment purge valve closure signal in Mode 6 is the high containment activity signal.

It is stated, in part, in the LAR, "CNS has a Containment Purge Exhaust System. At CNS, as described in Updated Safety Analysis Report (UFSAR) Sections 6.2.4 and 9.4.5, the containment purge isolation valves close on a Phase A Containment Isolation Signal (SI) or a high containment activity signal." Further, TS LCO 3.9.3c states, "Each penetration providing direct access from the containment atmosphere to the outside atmosphere either: 1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or 2. exhausting through an OPERABLE Containment Purge Exhaust System (CPES) HEPA filter and carbon absorber."

Please explain why the proposed new CNS Required Actions A.6.2 and B.5.2 require verification that each penetration is capable of being closed on a high containment radiation signal, and not by the Containment Purge and Exhaust System.

Duke Energy Response:

Page 8 of Enclosure 1 of the December 15, 2016 license amendment application states, in part:

At CNS, as described in UFSAR Sections 6.2.4 and 9.4.5, the containment purge isolation valves close on a Phase A Containment Isolation Signal (SI) or a high containment activity signal. Also note that per TS Table 3.3.2-1. Safety Injection (SI) is required to be operable only in Modes 1 through 4, whereas TS 3.9.4 and TS 3.9.5 are applicable in Mode 6. Therefore, the relevant containment purge valve closure signal in Mode 6 is the high containment activity signal. The containment high radiation monitor is addressed in SLC 16.7.10, "Radiation Monitoring for Plant Operations", but not in TS.

Note that there is a typographical error in the license amendment application. SLC 16. 7 .10 is actually SLC 16.7-10.

Attachment RA-17-0029 Page 2of5 CNS UFSAR Section 6.2.4 discusses the containment isolation system. UFSAR Section 6.2.4.1 states, in part:

Phase A Containment isolation is initiated by means of a Containment High Pressure Signal (ST). An ST occurs on a containment pressure of 1 psig as sensed by two out of four containment high pressure sensors or upon receipt of a Safety Injection Signal (SS). Phase B Containment isolation occurs on a Containment High-High Pressure Signal (SP). An SP occurs on a containment pressure of 3 psig as sensed by the same instrumentation mentioned above.

CNS UFSAR Section 6.2.4.4 notes that Phase A containment isolation testing of the Containment Purge Ventilation System is not performed since these valves are sealed closed in Modes 1-4.

CNS UFSAR Section 9.4.5 describes the Containment Purge Ventilation System. UFSAR Section 9.4.5.1 states, in part:

The Containment Purge Ventilation System is designed to maintain the environment of the containment within acceptable limits for personnel access during inspection, testing, maintenance and refueling operations; and to limit the release of any contamination to the environment.

Each containment penetration for the Purge Ventilation Supply and Exhaust Subsystems is provided with two isolation valves, one on each side of the containment wall. This meets the single failure criterion.

The Containment Purge Ventilation System is not an Engineered Safety Feature.

As stated in UFSAR Section 9.4.5.2, the "Containment Purge Supply System" and the "Containment Purge Exhaust System" are both subsystems of the Containment Purge and Ventilation System.

UFSAR Section 9.4.5.3 states, in part:

Each Containment Purge Ventilation System supply and exhaust penetration through the containment vessel is equipped with two normally closed isolation valves, each connected to separate control trains. A failure in one train will not prevent the remaining isolation valve from providing the required isolation capability. The isolation valves and containment penetrations are the only portions of the Containment Purge Ventilation System that are engineered safety features, and are discussed in Section 6.2.4. Design specifications for the purge system isolation valves are presented in Table 9-29.

The containment purge exhaust system is isolated on a high radiation signal.

A fuel handling accident inside the containment has been analyzed assuming the Purge System is in operation during refueling operations. This analysis is described in Section 15. 7 .4.

TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," Function 3.a.

Attachment RA-17-0029 Page 3 of 5 provides the requirements for the Phase A containment isolation instrumentation, including the requirement for manual initiation capability in Modes 1 through 4, and automatic initiation upon a Safety Injection signal (referencing Function 1). However, there is a footnote to Function 3 stating that the requirements of this function are not applicable to the Containment Purge Ventilation System since the system containment isolation valves are sealed closed in Modes 1 through 4. Function 1 of TS Table 3.3.2-1 provides the requirements for the Safety Injection instrumentation, including the same footnote as applicable to Function 3. As noted in the license amendment application, the containment high radiation monitor is addressed in SLC 16.7-10 "Radiation Monitoring for Plant Operations." The same radiation monitor is also addressed in SLC 16.11-7, "Radioactive Gaseous Effluent Monitoring Instrumentation." The SLC requirements for this radiation monitor apply in Modes 1 through 6. Although the containment purge penetrations receive an automatic isolation signal on a Phase A Containment Isolation Signal or a high containment activity signal, the Phase A signal is only applicable in Modes 1 through 4, and TS 3.9.4 and 3.9.5, are only applicable in Mode 6.

Accordingly, only the high containment activity signal is relevant to TS 3.9.4 and 3.9.5.

Use of the "Containment Purge and Exhaust Isolation System" terminology in TSTF-197 is consistent with Standard TS (STS) 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation." The CNS TS previously included the corresponding TS 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation," however, this TS was renamed via license amendments 196 and 189 on March 20, 2002 (ADAMS Accession Nos. ML020800871 and ML020810471), and this terminology is no longer in use in the CNS TS. Specifically, the amendments changed the nomenclature from "Containment Purge and Exhaust" system to "Containment Air Release and Addition" system as applicable, such that TS 3.3.6 is only applicable to the Containment Air Release and Addition System Isolation Instrumentation. The purpose of the Containment Air Release and Addition System is to maintain containment pressure between the TS low and high limits during normal plant operation. The Containment Air Release and Addition System is described in UFSAR Section 9.5.10, and this system is separate from the Containment Purge and Ventilation System.

TS LCO 3.9.3.c is applicable during movement of recently irradiated fuel assemblies within containment, and requires that each penetration providing direct access from the containment atmosphere to the outside atmosphere either: 1) be closed by a manual or automatic isolation valve, blind flange, or equivalent; or 2) be exhausting through an operable Containment Purge Exhaust System (CPES) HEPA filter and carbon adsorber. However, this LCO does not describe the means by which automatic isolation occurs. Additional information on the CPES, including filter trains, is provided in UFSAR Section 9.4.5.2.

In summary, use of the "Containment Purge and Exhaust Isolation System" terminology is outdated for CNS. Instrumentation is provided which performs the function of sending a signal to isolate the containment purge penetrations, and this instrumentation, as described in UFSAR Section 6.2.4.1, UFSAR Section 9.4.5.3, and TS Table 3.3.2-1, includes the Phase A Containment Isolation Signal and the high containment activity signal. The Phase A Containment Isolation Signal is only applicable in Modes 1 through 4, whereas the high containment activity signal is applicable in Modes 1 through 6. The proposed changes related to TSTF-197 involve CNS TS 3.9.4 and 3.9.5, both of which apply only in Mode 6. Therefore, the relevant containment purge valve closure signal is the high containment activity signal, and the proposed changes regarding TS 3.9.4 Required Action A.6.2 and TS 3.9.5 Required Action 8.5.2 are worded appropriately.

Attachment RA-17-0029 Page 4 of 5 RAl-2 TS 3.9.4, Condition A, Required Action A.4 and TS 3.9.5, Condition B, Required Action B.3 are proposed to be revised. Part of the proposed changes are to add new Required Actions A.6.2 and B.5.2. Required Actions A.6.2 and B.5.2 are proposed to state, "Verify each penetration is capable of being closed on a high containment radiation signal," with a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Further, according to the licensee, the containment high radiation monitor is addressed in Selected Licensee Commitment (SLC) 16.7.10, "Radiation Monitoring for Plant Operations",

but not in TS.

Since the containment high radiation monitors are not addressed in TSs, explain how each penetration is verified as being capable of being closed on a high containment radiation signal in MODE 6 and how it is ensured that a high containment radiation signal is available and capable of performing its intended safety function.

Duke Energy Response:

The containment high radiation monitor is addressed in SLC 16.7-10, "Radiation Monitoring for Plant Operations." The same radiation monitor is also addressed in SLC 16.11-7, "Radioactive Gaseous Effluent Monitoring Instrumentation." As background, the CNS SLC Manual is designated as Chapter 16 of the UFSAR and contains previous technical specification requirements which did not meet the criteria for inclusion in the technical specifications and hence, were relocated to this manual, as well as additional operational related commitments.

Changes to the SLCs are considered a change in an NRC commitment and shall be made only in accordance with the requirements of an administrative procedure, which includes use of the 10 CFR 50.59 process. The intent of the SLCs is to provide information regarding systems that are a part of the licensing basis, as described in the UFSAR, but are not of such a level of importance that they need to be under the rigorous control provided by technical specifications.

1 Most of the industry uses the term 'Technical Requirements Manual (TRM)" rather than the term 11 SLC".

SLC 16.11-7 includes requirements for a collection of radiation monitoring instrumentation, including the Containment Purge System - Noble Gas Activity Monitor (EMF-39.. Low Range).

The radioactive gaseous effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. When the high radiation setpoint for the monitor is exceeded, a signal is provided to both trains of Solid State Protection System (SSPS) to initiate a Containment Purge Ventilation (VP) system isolation. The SLC requires purging to be suspended immediately if this monitor is non-functional.

SLC 16. 7-10 includes requirements for a collection of radiation monitoring instrumentation used during plant operations, including the High Gaseous Radioactivity Monitor (EMF-39-Low Range). If the High Gaseous Radioactivity (EMF-39-Low Range) channel is non-functional, the SLC requires immediate verification that the Containment Purge Exhaust System (CPES) valves are maintained closed.

The SLCs include appropriate testing requirements (TRs ). TR 16.11-7-8 and TR 16. 7-10-2 require that a Channel Operational Test (COT) be performed every 18 months, which includes demonstration of the automatic isolation of the containment purge pathway.

Attachment RA-17-0029 Page 5 of 5 In summary, SLC 16. 7-10 and SLC 16.11-7 include the appropriate requirements to ensure that each containment purge penetration is capable of being closed in Mode 6 by a functional high containment radiation signal.