ML063420125

Proposed Amendment to Facility Operating License FOL Condition Regarding Extension of Time Limit to Complete Emergency Core Cooling Systems Sump Modification

ML063420125
Person / Time
Site:	Catawba
Issue date:	11/22/2006
From:	Morris J Duke Energy Carolinas, Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML063420125 (18)

Text

P Duke JAMES R. MORRIS Vice President Energy. Catawba Nuclear Station 4800 Concord Rd. / CNOI VP York, SC 29745-9635 803 831 4251 803 831 3221 fax November 22, 2006 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke)

Catawba Nuclear Station, Unit 1 Docket Number 50-413 Proposed Amendment to Facility Operating License (FOL)

FOL Condition Regarding Extension of Time Limit to Complete Emergency Core Cooling Systems (ECCS) Sump Modification

Reference:

Letter from Dhiaa M. Jamil (Duke) to NRC, dated November 1, 2006 In accordance with the provisions of 10 CFR 50.90, Duke proposes to revise the Catawba Unit 1 FOL to provide for an extension of the time limit to complete the required modification to the ECCS sump. Our commitment to submit this amendment to the Catawba Unit 1 FOL was transmitted to the NRC via the reference letter.

In this submittal, Duke is proposing to modify the Catawba Unit 1 FOL to add a license condition which requires that 1) Unit 1 will enter Mode 5 for the outage to install the sump strainer modification no later than May 19, 2008 and that 2) the Unit 1 sump strainer modification will be completed prior to entry into Mode 4 after May 19, 2008.

The contents of this amendment request package are as follows:

Attachment 1 provides a marked copy of the affected FOL pages for Catawba Unit 1, showing the proposed change. Attachment 2 provides a reprinted copy of the affected FOL pages for Catawba Unit 1, incorporating the proposed change. Attachment 3 provides a description of the proposed change and justification for the change. Pursuant to 10 CFR 50.92, Attachment 4 documents the determination that the amendment contains No Significant Hazards www.duke-energy. corn 40DI

U.S. Nuclear Regulatory Commission Page 2 November 22, 2006 Considerations. Pursuant to 10 CFR 51.22(c) (9), Attachment 5 provides the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement.

Amendment implementation will be accomplished within 30 days of NRC approval and in any event, no later than December 31, 2007, which is the existing commitment date for resolution of Generic Safety Issue (GSI)-191 for Catawba Unit 1.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, this proposed amendment has been previously reviewed and approved by representatives of the Catawba Plant Operations Review Committee and the Duke Nuclear Safety Review Board.

Pursuant to 10 CFR 50.91, a copy of this proposed amendment is being sent to the appropriate state official.

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

Very truly yours, James R. Morris LJR/s Attachments

U.S. Nuclear Regulatory Commission Page 3 November 22, 2006 James R. Morris affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

JamdyR. Morris, Vice President Subscribed and sworn to me:

Date My commission expires: 7---/o- 1 Date SEAL

U.S. Nuclear Regulatory Commission Page 4 November 22, 2006 xc (with attachments):

W.D. Travers U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 A.T. Sabisch Senior Resident Inspector (CNS)

U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.F. Stang, Jr. (addressee only)

NRC Project Manager (CNS)

U.S. Nuclear Regulatory Commission Mail Stop 8 H4A Washington, D.C. 20555-0001 H.J. Porter, Assistant Director Division of Radioactive Waste Management Bureau of Land and Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

ATTACHMENT 1 MAKED-UP FOL PAGES FOR CATAWBA

(6) Additional Conditions The Additional Coqntions contained InAppendix B, as revised through Amendment No. V are hereby incorporated Into this renewed operating license. Duke Power Company LLC shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of Appendix J to 10 CFR Part 50, as delineated below and pursuant to evaluations contained in the referenced SER and SSERs. These Include, (a) partial exemption from the requirement of paragraph IILD.2(b)(ii) of Appendix J, the testing of containment airlocks at times when the containment integrity is not required (Section 6.2.6 of the SER, and SSERs

1. 3 and #4), (b) exemption from the requirement of paragraph Ill.A.(d) of Appendix J, Insofar as it requires the venting and draining of lines for type Atests (Section 6.2.6 of SSER #3), and (c) partial exemption from the requirements of paragraph 111.B of Appendix J, as it relates to bellows testing (Section 6.2.6 of the SER and SSER #3).

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. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, In conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. Physical Protection Duke Power Company LLC shall fully Implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans Including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p). The combined set of plans, which contains safeguards Information protected under 10 CFR 73.21, is entitled: "Duke Energy Physical Security Plan" submitted by letter dated September 8, 2004, and supplemented on September 30, 2004, October 15, 2004, October 21, 2004 and October 27, 2004.

F. ReportinatotheCommission Deleted by Amendment No.230 -

II Renewed License No. NPF-5 Amendment No.

APPENDIX B rG 1';rG;U1AT10HI 0iN ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-35 Duke Power Company LLC shall comply with the following conditions on the schedules I noted below:

Amendment Implementation Number Additional Condition Date 159 This amendment requires the licensee to use Immediately administrative controls, as described in the upon issuance licensee's letter of March 7, 1997, and of the evaluated in the staff's safety amendment evaluation dated April 29, 1997, to restrict the dose-equivalent iodine levels to 0.46 microCurie per gram (in lieu of the limit in TS Section 3.4.8.a), and to 26 microCurie per gram (in lieu of the limit of TS Figure 3.4-1),

until this license condition is removed by a future amendment.

173 The licensee Is authorized to relocate certain All relocation to be requirements included in appendix A to completed by licensee-controlled documents. January 31, 1999.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents as described in the licensee's letters dated May 27, 1997, as amended by letters dated March 9, March 20, April 20, June 3, June 24, July 7, July 21, August 5, September 8, and September 15, 1998, and evaluated in the NRC staff's Safety Evaluation associated with this amendment.

Renewed License No. NPF-35 Amendment No. 229

-I-

Amendment Implementation Number Additional Condition Date 173 The schedule for the performance of new and By January 31, 1999 revised surveillance requirements shall be as follows:

For surveillance requirements (SRs) that are new in Amendment No. 173 the first performance Is due at the end of the first surveillance interval that begins at implementation of Amendment No. 173. For SRs that existing prior to Amendment No.

173, including SRs with modified acceptance criteria and SRs who Intervals of performance are being extended, the first performance is due at the end of the first surveillance Interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 173. For SRs that existed prior to Amendment No. 173, whose intervals of performance are being reduced, the first reduced surveillance Interval begins upon completion of the first surveillance performed after implementation of Amendment No. 173 180 The maximum rod average bumup for any rod Within 30 days of shall be limited to 60 GWd/mtU until the date of amendment.

completion of an NRC environmental assessment supporting an increased limit.

a-Amendment No.

INSERT for Catawba Unit 1 FOL page:

In association with the ECCS sump strainer modification and Generic Safety Issue (GSI)-191 requirements:

1. Unit 1 shall enter Mode 5 for the outage to install the sump strainer modification no later than May 19, 2008 and

2. The Unit 1 sump strainer modification shall be completed prior to entry into Mode 4 after May 19, 2008.

ATTACHMENT 2 REPRINTED FOL PAGES FOR CATAWBA

Amendment Implementation Number Additional Condition Date 173 The schedule for the performance of new and By January 31, 1999 revised surveillance requirements shall be as follows:

For surveillance requirements (SRs) that are new in Amendment No. 173 the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment No. 173. For SRs that existing prior to Amendment No. 173, including SRs with modified acceptance criteria and SRs who intervals of performance are being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 173. For SRs that existed prior to Amendment No. 173, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of Amendment No. 173 180 The maximum rod average bumup for any rod Within 30 days of shall be limited to 60 GWd/mtU until the date of amendment.

completion of an NRC environmental assessment supporting an increased limit.

In association with the ECCS sump strainer Within 30 days of modification and Generic Safety Issue (GSI)- date of amendment 191 requirements: and no later than December 31, 2007

1. Unit 1 shall enter Mode 5 for the outage to install the sump strainer modification no later than May 19, 2008 and

2. The Unit 1 sump strainer modification shall be completed prior to entry into Mode 4 after May 19, 2008.

Amendment No.

ATTACHMENT 3 DESCRIPTION OF PROPOSED CHANGE AND JUSTIFICATION

Description of Proposed Change The Catawba Unit 1 FOL is marked up to add a new license condition as follows:

"In association with the ECCS sump strainer modification and Generic Safety Issue (GSI)-191 requirements:

1. Unit 1 shall enter Mode 5 for the outage to install the sump strainer modification no later than May 19, 2008 and

2. The Unit 1 sump strainer modification shall be completed prior to entry into Mode 4 after May 19, 2008."

Justification On November 1, 2006, Duke provided a letter to the NRC which summarized Catawba's plans for installing the ECCS sump strainer modification on Unit 1 in response to the requirements of Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors." This letter discussed in detail Duke's request for a delay in implementing the modification on Unit 1 and provided information concerning final design issues and delays, material delivery delays, ALARA concerns, and a recovery plan. The letter provided the technical justification for the proposed extension to the time limit for implementing the requirements of this GL. The letter also stated Duke's commitment to submit a proposed condition into the Unit 1 FOL to incorporate the proposed modification completion date. The commitment stated that the FOL condition would be submitted no later than November 30, 2006.

This submittal fulfills Duke's commitment to propose the Unit 1 FOL condition. Since no new technical information is being submitted in conjunction with the proposed FOL condition, this submittal is considered administrative in nature.

Following NRC approval of the proposed FOL condition, implementation will be accomplished within 30 days of approval and in any event, no later than December 31, 2007, which is the existing commitment date for resolution of GSI-191 for Catawba Unit 1.

Attachment 3 Page 1

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

No Siqnificant Hazards Consideration Determination As required by 10 CFR 50.91(a) (1), this discussion is provided to demonstrate that the proposed license amendment involves no significant hazards consideration.

Conformance of the proposed amendment to the standards for a determination of no significant hazards as defined in 10 CFR 50.92 is shown in the following:

1) The proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed license amendment delineates a new Unit 1 FOL condition to implement a completion date associated with the ECCS sump strainer modification. The proposed license amendment is administrative in nature and is being submitted to fulfill a commitment made in previous Duke licensing correspondence. Therefore, the proposed license amendment has no effect upon either the probability or consequences of an accident previously evaluated.

2) The proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

As stated above, the proposed license amendment is administrative in nature and does not change the manner in which Unit 1 is designed or operated. Therefore, the proposed license amendment cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed license amendment does not involve a significant reduction in a margin of safety.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their intended functions. These barriers include the fuel cladding, the reactor coolant system, and the containment. The performance of these barriers will not be affected by the addition of the proposed FOL condition. Being administrative in nature, the proposed license amendment therefore does not involve a significant reduction in any safety margin.

Attachment 4 Page 1

Based on the preceding discussion, it is concluded that the proposed license amendment does not involve a significant hazards consideration finding as defined in 10 CFR 50.92.

Attachment 4 Page 2

ATTACHMENT 5 ENVIRONMENTAL A~NALYSI S

Environmental Analysis Pursuant to 10 CFR 51.22(b), an evaluation of this license amendment request has been performed to determine whether or not it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c) (9) of the regulations.

Implementation of this amendment will have no adverse impact upon Catawba Unit 1; neither will it contribute to any additional quantity or type of effluent being available for adverse environmental impact or personnel exposure.

It has been determined there is:

1. No significant hazards consideration,

2. No significant change in the types, or significant increase in the amounts, of any effluents that may be released offsite, and

3. No significant increase in individual or cumulative occupational radiation exposures involved.

Therefore, this amendment to the Catawba Unit 1 FOL meets the criteria of 10 CFR 51.22(c) (9) for categorical exclusion from an environmental impact statement.

Attachment 5 Page 1