Text

Supplement to License Amendment Request for Plants Technical Specification 3.4.15, RCS Leakage Detection Instrumentation
	ML061360319
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	05/04/2006
From:	Jamil D; Duke Energy Carolinas, Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML061360319 (64)
	v • d • e

!'

4 Duke D.M. JAMIL

¢- _Duke Vice President W Elnergy.

SS EnrgyeCatawba Nuclear Station 4800 Concord Rd. / CN01 VP York, SC 29745-9635 803 831 4251 803 831 3221 fax May 4, 2006 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555-0001

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Supplement to a License Amendment Request for McGuire and Catawba Technical Specification 3.4.15, RCS Leakage Detection Instrumentation.

Reference:

Letter from Duke Energy Corporation to the NRC, Dated July 27, 2005 In response to several telecoms between the NRC and Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) that occurred between November 8, 2005 and February 21, 2006, please find the attached revised License Amendment Request (LAR) for Technical Specification (TS) 3.4.15.

These Attachments 1, 2, and 3 replace the corresponding sections from the referenced July 27, 2005 LAR submittal.

Please note that no changes were necessary to Attachment 4, Environmental Assessment/Impact Statement, thus the original July 27, 2005 Attachment 4 remains valid, however for convenience, it is included again within this submittal package. is an addition to this LAR package and it provides a summary description of the results of the particulate radiation monitor response time calculation.

The July 27, 2005 submittal proposed deleting the 30-day shutdown requirement for the containment floor and equipment sump level monitors based on the monitors' low safety significance, not being modeled in the Probability Risk Assessment, no impact on initiating event frequency, no impact to mitigating system operation, as well as the diversity and redundancy of the other leakage detection instrumentation. However, based on feedback received from the NRC, Duke will reinstate the shutdown requirement within

.Aoc (

www. duke-energy. corn

U.S. Nuclear Regulatory Commission Page 2 May 4, 2006 Condition A, consistent with the current TS 3.4.15.

Other significant changes from the original July 27, 2005 LAR are limiting the Modes of applicability for the containment atmosphere particulate radioactivity monitor to Mode 1 and adding a new separate condition to apply to the incore instrument sump level alarm.

Pursuant to 10 CFR 50.91, a copy of this letter is being sent to the designated official of the State of North Carolina and the designated official of the State of South Carolina.

This letter and attachments do not contain any new NRC commitments.

Inquiries on this matter should be directed to G.K.

Strickland at (803) 831-3585 or J.S. Warren at (704) 875-5171.

Very truly yours, D.M. Jamil Attachments:

la. McGuire Units 1 and 2, Proposed Technical Specifications and Bases (Mark-up).

lb. Catawba Units 1 and 2, Proposed Technical Specifications and Bases (Mark-up).

2. Description of Proposed Changes and Technical Justification.

3. No Significant Hazards Consideration Determination.

4. Environmental Assessment/Impact Statement.

5. Summary Description of the Results of the Particulate Radiation Monitor Response Time Calculation.

U.S. Nuclear Regulatory Commission Page 3 May 4, 2006 xc (with attachment):

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

U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.B. Brady Senior Resident Inspector (MNS)

U.S. Nuclear Regulatory Commission McGuire Nuclear Station J.F. Stang (addressee only)

NRC Project Manager (MNS and CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 H4A 11555 Rockville Pike Rockville, MD 20852-2738 H.J. Porter Assistant Director Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 B.O. Hall Section Chief Radiation Protection Section 1645 Main Service Center Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission Page 4 May 4, 2006 D.M. Jamil 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.

I Subscribed and sworn to me:

5-4-D6 Date tar u

NotarydjPublic My commission expires:

'7- / -a AO/ -

Date

-C'

SEAL

Attachment la McGuire Units 1 and 2 Proposed Technical Specifications and Bases (Mark-up)

RCS Leakage Detection instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a.

The containment floor and equipment sump level mnoring cYctom monitors and the incore instrument sump level alarm;

b.

One The containment atmosphere Faees particulate radioactivity monitor; and

c.

Eithe The containment ventilation unit condensate drain tank level monitor or the contAinment atmoephere part1icateo r-adieoatiAit MeRit G.

APPLICABILITY:

MODES 1 for all instrumentationr2,43aPn14, MODES 2, 3, and 4 for all instrumentation except the containment atmosphere particulate radioactivity monitor.

ACTIONS NOTE -- - ------------

Separate Condition entry is allowed for each leakage detection instrument.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or both containment A.1 floor and equipment

- NOTE -

sump level moRnitering Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months syotem monitor(s) after establishment of inoperable.

steady state operation.

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months A.2 Restore inoperable 30 days containment floor and equipment sump level monitor(s) to OPERABLE status.

(continued)

McGuire Units 1 and 2 3.4.15-1 Amendment Nos 184/166

RCS Leakage Detection instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

Containment B.1 atmosphere gaseews

- NOTE -

particulate radioactivity Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months monitor inoperable.

after establishment of steady state operation Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR B.2 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

C.

Containment ventilation C.

unit condensate drain

- NOTE -

tank level monitor Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable.

after establishment of steady state operation Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR C.2 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

the containment atmosphere.

OR C.3 Perform SR 3.4.15.1.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

McGuire Units 1 and 2 3,4.15-2 Amendment Nos 4"4466

RCS Leakage Detection instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Containment D. I Restore containment 30 days atmosphere particulate atmosphere particulate radioactivity monitor radioactivity monitor to inoperable in MODE 1.

OPERABLE status.

AND OR Containment ventilation D.2 Restore containment unit condensate drain ventilation unit condensate 30 days tank level monitor drain tank level monitor to inoperable in MODE 1.

OPERABLE status.

E.

Incore instrument sump E.1 _

level alarm inoperable.

- NOTE -

Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months F.

Required Action and F. I Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND F.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G.

All required monitors G. 1 Enter LCO 3.0.3.

Immediately inoperable.

McGuire Units 1 and 2 3.4.15-3 Amendment Nos 1814466

RCS Leakage Detection instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the Fequire containment 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere particulate radioactivity monitor.

SR 3.4.15.2 Perform COT of the requiried containment atmosphere 92 days particulate radioactivity monitor.

SR 3.4.15.3 Perform CHANNEL CALIBRATION of the equiFed 18 months containment floor and equipment sump level moRitoring system monitors.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the equired 18 months containment atmosphere particulate radioactivity monitor.

SR 3.4.15.5 Perform CHANNEL CALIBRATION of the FequiFed 18 months containment ventilation unit condensate drain tank level monitor.

SR 3.4.15.6 Perform CHANNEL CALIBRATION of the incore 18 months instrument sump level alarm.

McGuire Units 1 and 2 3.4.15-4 Amendment Nos 184466

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

The primary method of detecting leakage into the Containment is measuremont of the Containment fleer and equipment sump level. There are small SumpS located on either side of tho containment outsido the crane wall. Any leakage would fall to the floor inside the cGane wall and Fru-by a sump drain; line to one of the t.o sumps. Any leakage outside the crane wall would fall into the floor and gravity drain to those sumps.

The sump level rate of change, 8-Ga.rulated by the plant computer, would indicate the leakage rate. This method of detection wV'ould indicate in the Control Room a water leak from either the Reactor Coolant System or the Main Steasm and Feodwater Systeme. A 4 gpm leak (cumulative i both sump A and B) ic detectable in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

One method of detecting leakage into the containment is the level instrumentation in containment floor and equipment (CFAE) sump A and CFAE sump B (Refs 3 and 7) and in the incore instrument sump (Ref 3).

The CFAE sumps are small sumps located on opposite sides of the containment and outside of the crane wall. Any leakage in the lower containment inside the crane wag that falls to the floor will drain through crane wall penetrations at floor level to one of the two sumps. Any leakage outside the crane wall would fall to the floor and gravity drain to these sumps. The sump level rate of change, as calculated by the plant computer, would indicate the input rate. This method of detection would indicate in the Control Room a leak from any liquid system including the Reactor Coolant System and the Main Steam and Feedwater Systems.

As leakage may go to either or both of the two CFAE sumps, a I gpm sump input (cumulative between sumps A and B) is detectable in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after leakage has reached the sumps (Ref 8). During periods of McGuire Units 1 and 2 B 3.4.15-1 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued) pump-down of the CFAE sumps, the CFAE level instrumentation remains operable since operating experience has shown that this process typically takes only minutes to complete. The incore instrument sump level alarm offers another means of detecting leakage into the containment (Ref 3).

The incore instrument sump level instrumentation provides a control room alarm and an alarm on the plant computer when the sump level increases to the Hi level. The incore instrument sump level instrumentation is capable of detecting I gpm input within four hours after leakage has reached the sump (Ref 8).

The environmental conditions during plant power operations and the physical configuration of lower containment will delay the total reactor coolant system leakage (including steam) from directly entering the CFAE sump and subsequently, will lengthen the sump's level response time.

Therefore, leakage detection by the CFAE sump will typically occur following other means of leakage detection. Operating experience with high enthalpy primary and secondary water leaks indicates that flashing of high temperature liquid produces steam and hot water mist that is readily absorbed in the containment air. Much of the hot water that initially reaches the containment floor will evaporate in a low relative humidity environment as it migrates towards a sump. Local low points along the containment floor provide areas for water to form shallow pools that increase transport time to one or more building sumps. The net effect is that only a fraction of any high enthalpy water leakage will eventually collect in a sump and early leak detection may rely on alternate methods.

The containment ventilation unit condensate drain tank (CVUCDT) level Ghange monitor offers another means of detecting leakage into the containment. An abnormal level increase would indicate removal of moisture from the containment by the containment air coolers. When the CVCDT is used as a leakage detection method, manual hourly logging of the CVCDT level and calculation of reactor coolant leakage (if CVCDT level shows 1 P gpm IRcreao) are rFequired to satisfy the ICon FequIhemeots.

The plant computer calculates the rate of change in level to detect a tank input of I gpm after condensate has reached the tank.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

Reactor coolant radioactivity levels will be low during initial reactor startup and for a few' qeeks thereaftFr, URN iectivatd o

poeducts have been formed and fission products appear from fuel element cladding contamination or cladding defects. Instrument sensitivities of I O-i/GG radioeacti'.it; for pawrticulate monitorine ad ef IOe pCL'c rFadirocti'ivy for McGuire Units 1 and 2 B 3.4.1 5-2 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued) gaseous monitoNng are practical for these loakago detection systems.

Radioeactivity deotocton ystoem aSro inluded for mneitoing beoth partficulate ansd gaeeous activitioe bocauge of their se;witivitioe and1 rapid rosponoes to RGS LEAKAGE. Wheon either the particulate or gaseous radieactivit'; menitor Os out of cerpice for aintinaenco or failure, both monitors may be affected bocause they chare common cample tubing and Dumn I

nd flow instrumentation.

U.S. NRC Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure boundary Leakage Detection Systems," (Ref. 2), describes acceptable methods of implementing the requirements for leakage detection systems. Although RG 1.45 is not a license condition, it is generally accepted for use to support licensing basis. RG 1.45 states that instrument sensitivities of 1I&9 pCi/cc radioactivity for air particulate monitoring are practical for leakage detection systems. The containment atmosphere particulate radioactivity monitor at McGuire meets or exceeds this accepted sensitivity.

RG 1.45 also states that detector systems should be able to respond to a one gpm leak, or its equivalent, in one hour or less. The containment atmosphere particulate radioactivity monitor at McGuire has demonstrated capabilities of detecting a 1.0 gpm leak within one hour at the sensitivity recommended in Regulatory Guide 1.45 using the RCS corrosion product activities from the UFSAR. Lower RCS activities will result in an increased detection time. Since the containment atmosphere particulate radioactivity monitor meets the specified 10 9 pCi/cc sensitivity, they are designed in accordance with RG 1.45.

The containment atmosphere particulate radioactivity monitor collects airborne particulate activity on a fixed filter monitored by a gross beta detector. The collected activity is referred to as background and is displayed as gross counts per minute (CPM). Background is a combination of collected beta activity from various sources that may include natural decay products, airborne contamination and any small RCS leakage. To detect changes in the containment airborne activity, the containment atmosphere particulate radioactivity monitor utilizes a differential algorithm that calculates an increasing accumulation of containment particulate activity. The control room readout module displays this increasing accumulation rate as counts per minute accumulating each minute (CMM). The alarm for leakage detection is based upon this positive accumulation rate above background activity on the fix filter.

The actual alarm setpoints are set as low as practicable, considering the actual concentration of radioactivity in the RCS and the containment McGuire Units 1 and 2 B 3.4.15-3 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued) background radiation concentration. As low as practicable alarm setpoint is a balance between sufficiently high enough above typical background radiation variations to preclude spurious alarms while sufficiently low enough to assure reasonable sensitivity for early detection of an RCS leak. The alarm setpoint is based upon detected increasing accumulate rate of containment particulate activity above background. Variations in background of containment radiation do occur, and the containment atmosphere particulate radioactivity monitor compensates for these changes once the background radiation reaches equilibrium. At the background threshold of collected containment particulate activity that affects detector operability, a failure alarm is actuated for high background on the detector. The alarm setpoint (for detector operability) will be less than or equal to the projected containment activity accumulation rate following a one gpm leak.

The operability of the containment atmosphere particulate radioactivity monitor is based upon an instrument sensitivity > 199 pC/cc, a Channel Check performed at a frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a Channel Operational Test performed at a frequency of every 92 days, and a Channel Calibration performed at a frequency of every 18 months.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE. A 1 OF increase in dew point is well within the sensitivity range of available instruments (Ref. 7). Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid level into the containment floor and equipment CFAE sumps and condensate level from the air coolers. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO.

Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO.

McGuire Units I and 2 B 3.4.15-4 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

The volume control tank (VCT) level change offers another means of detecting leakage into containment (Ref 3). This enhances the diversity of the leakage detection function as recommended in RG 1.45. The VCT level instrumentation is not required by, nor can be credited for, this LCO.

Once any alarm or indication of leakage is received from the RCS leakage detection instrumentation, control room operators quickly evaluate all available system parameters to assess RCS pressure boundary integrity. These include VCT and pressurizer level indications and, if appropriate, the RCS mass balance calculation. Response to RCS leakage is addressed by LCO 3.4.13, "RCS Operational LEAKA GE."

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY ANALYSES to the operators, and the ability to compare and verify with indications from other systems is necessary. The system response times and sensitivities are described in the UFSAR (Refs. 3 and 8). Multiple instrument locations are utilized, if needed, to ensure that the transport delay time of the leakage from its source to an instrument location yields an acceptable overall response time.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion I of 10 CFR 50.36 (Ref. 4).

LCO One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment floor and 6quipmont CFAE sump level maonitorrng cycattom and _ gaeoouc a iotyt; monItor In oRmbination with a containmont ventilation condoncate drain tank lotal monitor or particulate radioactivity Monitor monitors and the incore instrument sump McGuire Units 1 and 2 B 3.4.15-5 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES LCO (continued) level alarm, the containment atmosphere particulate radioactivity monitor, and the CVUCDT level monitor provide an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

Since RCS radioactivity level is significantly lower in MODES 2, 3, and 4, the containment atmosphere particulate radioactivity monitor is not a reliable means of detecting RCS leakage in these MODES. Thus the LCO applies to this monitor in MODE I only and leakage detection capability in MODES 2, 3, and 4 is accomplished by the diverse means provided by the CFAE sump level monitors, the incore instrument sump level alarm, and the CVUCDT level monitor.

In MODE 5 or 6, the temperature is to be < 2001F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A note has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry is allowed for each instrument. The Completion Time of the inoperable instrument will be tracked separately for each instrument starting from the time the Condition was entered for that instrument.

A.1 and A.2 With the containment floor and equipment sump level monitors inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere particulate radioactivity monitor will provide indications of changes in leakage.

Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Required Action A. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1.

McGuire Units 1 and 2 B 3.4.15-6 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

This Note allows exceeding the 24-hour completion time during non-steady state operation.

Restoration of the containment floor and equipment sump level monitorsing system to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitors failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

B.1 and B.2 With the gaseeus containment atmosphere particulate radioactivity monitoring inGtrumontation channels inoperable, alternative action is required. Either water inventory balances, in accordance with SR 3.4.13.1 must be performed, or grab samples of the containment atmosphere must be taken and analyzed, to provide alternate periodic information.

Required Action B. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1.

This Note allows exceeding the 24-hour completion time during non-steady state operation.

With a water inventory balance performed or grab samples obtained and analyzed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , continued operation is allowed since diverse indications of RCS LEAKAGEremain OPERABLE. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage.

C.1 a4 C.2, and C.3 With the CVUCDT level monitor inoperable, alternative action is again required. Either a water inventory balance, in accordance with SR 3.4.13.1; or grab samples obtained and analyzed at a frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or SR 3.4.15.1, CHANNEL CHECK, of the containment atmosphere particulate radioactivity monitor at 8-hour intervals, must be performed to provide alternate periodic information. Required Action C. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

Provided a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or grab samples taken and analyzed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or a CHANNEL CHECK of the containment atmosphere particulate radioactivity monitor is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , reactor operation may continue while awaiting restoration McGuire Units 1 and 2 B 3.4.15-7 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued) of the CVUCDT level monitor to OPERABLE status. The 24 and 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months intervals provide periodic information that is adequate to detect RCS LEAKAGE.

D.1 and D.2 With the containment atmosphere particulate radioactivity monitor inoperable in MODE I and the containment ventilation unit condensate drain tank level monitor inoperable in MODE 1, the only means of detecting leakage is the containment floor and equipment sump level monitors-sg ssteim and the incore sump level alarm. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

E. I With the incore sump level alarm inoperable, a water inventory balance, in accordance with SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide alternate periodic information that is adequate to detect leakage. Required Action E. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

F. 1 and F.2 If a Required Action of Condition A, B. Gr C, or D cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

McGuire Units 1 and 2 B 3.4.15-8 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

G.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. The required monitors during MODE I for LCO 3.0.3 entry are defined as the simultaneous inoperability of one CFAE level monitor, the containment atmosphere particulate radioactivity monitor, and the CVUCDT level monitor. The required monitors during MODES 2, 3, and 4 for LCO 3.0.3 entry are defined as the simultaneous inoperability of one CFAE level monitor and the CVUCDT level monitor.

This Condition does not apply to the incore instrument sump level alarm.

SURVEILLANCE REQUIREMENTS SR 3.4.15.1 SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the Fequired containment atmosphere particulate radioactivity monitor. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the containment atmosphere particulate radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3. SR 3.4.15.4. SR 3.4.15.5. and SR 3.4.15.6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

McGuire Units 1 and 2 B 3.4.15-9 Revision No.

RCS Leakage Detection Instrumentation B 3.4.15 S

BASE REFERENCES 1.

2.

3.

4.

5.

6.

10 CFR 50, Appendix A, Section IV, GDC 30.

Regulatory Guide 1.45.

UFSAR, Section 5.2.7.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

UFSAR, Table 18-1.

McGuire License Renewal Commitments MCS-1274.00-00-0016, Section 4.29, RCS Operational Leakage Monitoring Program.

McGuire Safety Evaluation Report, Section 5.2.5.

UFSAR, Table 5-30.

7.

8.

McGuire Units 1 and 2 B 3.4.15-1 0 Revision No.

Attachment lb Catawba Units 1 and 2 Proposed Technical Specifications and Bases (Mark-up)

RCS Leakage Detection instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a.

OnFe The containment floor and equipment sump level monitors and the incore instrument sump level alarm;

b.

One The containment atmosphere particulate radioactivity monitor; (gasoeus or particulato); and

c.

Oae The containment ventilation unit condensate drain tank level monitor.

APPLICABILITY:

MODES 1 2, 3, and 4, for all instrumentation MODES 2, 3, and 4 for all instrumentation except the containment atmosphere particulate radioactivity monitor.

ACTIONS VUj I

c Separate Condition entry is allowed for each leakage detection instrument.

CONDITION REQUIRED ACTION COMPLETION TIME A.

Required One or both A. I containment floor and

- NOTE -

equipment sump level Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months monitor(s) inoperable.

after establishment of steady state operation.

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND A.2 Restore equired inoperable 30 days containment floor and equipment sump level monitor(s) to OPERABLE status.

(continued)

Catawba Units I and 2 3.4.15-1 Amendment Nos. 213/207

RCS Leakage Detection instrumentation 3.4.15 CONDITION REQUIRED ACTION COMPLETION TIME B.

Requi~ed Containment B.1 atmosphere particulate

- NOTE-radioactivity monitor Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable.

after establishment of steady state operation Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR B.2 Analyze grab samples of the containment Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months atmosphere C.

RequiWed Containment C.1 ventilation unit

- NOTE -

condensate drain tank Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months level monitor inoperable.

after establishment of steady state operation Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR C.2 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

OR C.3 Perform SR 3.4.15.1.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

Catawba Units 1 and 2 3.4.15-2 Amendment Nos. 1731465

RCS Leakage Detection instrumentation 3.4.15 CONDITION REQUIRED ACTION COMPLETION TIME D.

RequiFed Containment D.1 Restore Feq4iFed 30 days atmosphere particulate containment atmosphere radioactivity monitor particulate radioactivity inoperable in MODE 1.

monitor to OPERABLE status.

AND OR Requi~ed Containment ventilation unit D.2 Restore FeqUired 30 days condensate drain tank containment ventilation unit level monitor inoperable condensate drain tank in MODE 1.

level monitor to OPERABLE status E.

Incore instrument sump E I level alarm inoperable.

- NOTE -

Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months F.

Required Action and F. I Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND F.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G.

All required monitors G. I Enter LCO 3.0.3.

Immediately inoperable.

Catawba Units 1 and 2 3.4.15-3 Amendment Nos. 173/165

RCS Leakage Detection instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the Feqoi~ed containment 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere particulate radioactivity monitor.

SR 3.4.15.2 Perform COT of the PIequied containment atmosphere 92 days particulate radioactivity monitor.

SR 3.4.15.3 Perform CHANNEL CALIBRATION of the requiFed 18 months containment floor and equipment sump level monitors.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the Fequi4ed 18 months containment atmosphere particulate radioactivity monitor.

SR 3.4.15.5 Perform CHANNEL CALIBRATION of the equIFed 18 months containment ventilation unit condensate drain tank level monitor.

SR 3.4.15.6 Perform CHANNEL CALIBRATION of the incore 18 months instrument sump level alarm.

Catawba Units I and 2 3.4.15-4 Amendment Nos. 1734165 I

I

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

The primaray method of detecting leakage into the Containment is measurement of the Containment floor and equipment sump level. There are esmall cumps located on either cide of the cnrta Iinen u teido the crane wall. Any leakage would fall to the floor inside the crane wall and run by a sump draiR line to oRe of the Woe sumps. ARy leakage eoutide the crane wall would fall to the floor-ad gravity draiR to these SumpE.

The sump level rate of change, as calculated by the plant computer, would indicate the leakage rate. Thi method of detection would indicate in the Control Room a water leak from either the Recntor ColRant cystem or the Main Steam and Feedwater Systems. A 1 gpm leak (cumulative in both rump A and B) as detectable in I hour.

One method of detecting leakage into the containment is the level instrumentation in containment floor and equipment (CFAE) sump A and CFAE sump B (Ref 3 and 5) and in the incore instrument sump (Ref 3).

The CFAE sumps are small sumps located on opposite sides of the containment and outside of the crane wall. Any leakage in the lower containment inside the crane wall would fall to the floor and run via embedded floor drains to one of the two CFAE sumps. Any leakage outside the crane wal would fall to the floor and gravity drain to these sumps. The sump level rate of change, as calculated by the plant computer, would indicate the input rate. This method of detection would indicate in the Control Room a leak from any liquid system including the Reactor Coolant System and the Main Steam and Feedwater Systems.

As leakage may go to either or both of the two CFAE sumps, a I gpm sump input (cumulative between sumps A and B) is detectable in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Catawba Units 1 and 2 B 3.4.15-1 Revision No-9

RCS Leakage Detection Instrumentation B 3.4.15 BASES after leakage has reached the sumps. During periods of pump down of the CFAE sumps, the CFAE level instrumentation remains operable since operating experience has shown that this process typically takes only minutes to complete. The incore instrument sump level alarm offers another means of detecting leakage into the containment (Ref 3 and 5).

The incore instrument sump level instrumentation provides an alarm on the plant computer when the sump level increases to the Hi level. The incore instrument sump level instrumentation is capable of detecting I gpm input within four hours after leakage has reached the sump.

The environmental conditions during plant power operations and the physical configuration of lower containment will delay the total reactor coolant system leakage (including steam) from directly entering the CFAE sump and subsequently, will lengthen the sump's level response time.

Therefore, leakage detection by the CFAE sump will typically occur following other means of leakage detection. Operating experience with high enthalpy primary and secondary water leaks indicates that flashing of high temperature liquid produces steam and hot water mist that is readily absorbed in the containment air. Much of the hot water that initially hits the containment floor will evaporate in a low relative humidity environment as it migrates towards a sump. Local low points along the containment floor provide areas for water to form shallow pools that increase transport time to one or more building sumps. The net effect is that only a fraction of any high enthalpy water leakage will eventually collect in a sump and early leak detection may rely on alternate methods.

The containment ventilation unit condensate drain tank (CVUCDT) level ryhaR~e monitor offers another means of detecting leakage into the containment. An abnormal level increase would indicate removal of moisture from the containment by the containment air coolers. The plant computer calculates the rate of change in level to detect a leak tank input of I gpm after condensate has reached the tank.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

Reactor coolant radioactivity levels will be low during initial reactor startup

,Anf af, few weeks, thereafter, until activatod co-ocioR products have been formed and fission products appear from fuel element cladding contamination or cladding defects. U.S. NRC Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure boundary Leakage Detection Systems, describes acceptable methods of implementing the requirements for leakage detection systems. Although RG 1.45 is not a license condition, it is generally accepted for use to support licensing basis. RG 1.45 states that instrument sensitivities of I OT9 pCicc radioactivity for air particulate monitoring are practical for leakage detection systems. The particulate monitor at Catawba meets or exceeds this accepted sensitivity.

RG 1.45 also states that detector systems should be able to respond to a Catawba Units 1 and 2 B 3.4.15-2 Revision No. 4-

RCS Leakage Detection Instrumentation B 3.4.15 BASES one gpm, or its equivalent, leakage increase in one hour or less. The particulate monitor at Catawba has demonstrated the capability of detecting a 1.0 gpm leak within one hour at the sensitivity recommended in Regulatory Guide 1.45 using the RCS corrosion product activities from the UFSAR. Lower RCS activities will result in an increased detection time. Since the particulate monitor meets the specified I a9,uCi/cc sensitivity, they are designed in accordance with RG 1.45.

The actual alarm setpoints are set as low as practicable, considering the actual concentration of radioactivity in the RCS and the containment background radiation concentration. The alarm setpoint (for detector operability) will be less than or equal to the projected containment activity indication following a one gpm leak from steady state conditions. An alarm setpoint administrative limit will be established close to background to provide a more responsive indication of RCS leakage. The administrative limit is approximately 1.5 times the background indication when the alarm adjustments are performed. The administrative limit may be increased based on operating history and the number of spurious alarms but must be maintained less than the operability limit. The alarm setpoint will be evaluated at least every 18 months.

The operability of the particulate monitor is based upon an instrument sensitivity > 10f uCi/cc, a Channel Check performed at a frequency of every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a Channel Operational Test performed at a frequency of every 92 days, and a Channel Calibration performed at a frequency of every 18 months.

instrument sensitivities of 1 e-Ci.'cc radioactivity for particulate monitoripg and of 10 7 PCi/cc radioactivity for gaseous monitoring are practical for thc lEage detection cystems. Radioactivity detection systems are included for moenitoring both particulate and gaseous.

activities because of their censitivities and rapid responses to RCS LEAKAGE.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE. A 1 OF increase in dew point is well within the sensitivity range of available instruments. Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid level into the containment floor and equipment cump CFAE and condensate level from air coolers. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO.

Air temperature and pressure monitoring methods may also be used to Catawba Units I and 2 B 3.4.15-3 Revision No. 4f

RCS Leakage Detection Instrumentation B 3.4.15 BASES infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO.

The volume control tank (VCT) level change offers another means of detecting leakage into containment (Ref 3). This enhances the diversity of the leakage detection function as recommended in Regulatory Guide 1.45 (Ref 2). The VCT level instrumentation is not required by, nor can be credited for, this LCO.

Once any alarm or indication of leakage is received from the RCS leakage detection instrumentation, control room operators quickly evaluate all available system parameters to assess RCS pressure boundary integrity.

These include VCT and pressurizer level indications and, if appropriate, the RCS mass balance calculation. Response to RCS leakage is addressed by LCO 3.4.13, `RCS Operational LEAKAGE.'

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY ANALYSES to the operators, and the ability to compare and verify with indications from other systems is necessary. The system response times and sensitivities are described in the UFSAR (Ref. 3 and 6). Multiple instrument locations are utilized, if needed, to ensure that the transport delay time of the leakage from its source to an instrument location yields an acceptable overall response time.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36 (Ref. 4).

LCO One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, Catawba Units 1 and 2 B 3.4.15-4 Revision No. 4-

RCS Leakage Detection Instrumentation B 3.4.15 BASES when RCS LEAKAGE indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment floor and equipment sump level monitors and the incore instrument sump level alarm, in combination with a gaseou or partirulate FdioactiVity roRnitor and a coRtainmeRn Yentilation unit condensate drain tank level monitor, provides an acceptable minimum. the particulate radioactivity monitor, and the CVUCDTlevel monitor provide an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

Since RCS radioactivity level is significantly lower in MODES 2, 3, and 4, the containment atmosphere particulate monitor is not a reliable means of detecting RCS leakage in these MODES. Thus the LCO applies to this monitor in MODE I only and leakage detection capability in MODES 2, 3, and 4 is accomplished by the diverse means provided by the CFAE sump level monitors, the incore instrument sump level alarm, and the CVUCDT level monitor.

In MODE 5 or 6, the temperature is to be < 200OF and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A Note has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry is allowed for each instrument. The Completion Time of the inoperable instrument will be tracked separately for each instrument starting from the time the Condition was entered for that instrument.

A.1 and A.2 With the required containment floor and equipment sump level monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere particulate radioactivity monitor will provide indications of changes in leakage.

Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Catawba Units 1 and 2 B 3.4.15-5 Revision No. 1-

RCS Leakage Detection Instrumentation B 3.4.15 BASES Required Action A. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1.

This Note allows exceeding the 24-hour completion time during non-steady state operation.

Restoration of the required containment floor and equipment sump level monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

B.1 and B.2 With both gaseous and the pariculate containment atmosphere particulate radioactivity monitor monitoring instrumentation channels inoperable, alternative action is required. Either water inventory balances, in accordance with SR 3.4.13.1, must be performed or grab samples of the containment atmosphere must be taken and analyzed eOFwate inveioto'; balances, in accordan.e.ith S.R 3.1.1 must be po~aFed to provide alternate periodic information.

Required Action B. I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1.

This Note allows exceeding the 24-hour completion time during non-steady state operation.

With a water inventory balance performed or grab samples obtained and analyzed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , continued operation is allowed since diverse indications of RCS LEAKAGE remains OPERABLE. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage.

With a sample obtained and analyzed or water inventory balance performed ever; 21 hourcs, cntnlued operatioR is allowed if the containment 'ventilation unit condensate drain tank level monitor is OPERABLE-The 24 heour inteo.al pro'ides pedoriodic informatioR that is adequate to detet

-eakagW.

Catawba Units 1 and 2 B 3.4.15-6 Revision No. 4

RCS Leakage Detection Instrumentation B 3.4.15 BASES C.1. C.2, and C.3 With the required containment ventilation unit condensate drain tank level r;monor i;n;oeperable, alternative actio is agin reauird. Either SR 3.4.15.1 must be performed or water inventor'y balances, in accerdance with SR 33.4.13.1, must be perfomed to pride aternate periodic information. Pro'.ided a CH4ANNEL= CHECK is perforee--d every 8 houar or ai rater invontory balaGnce is perforFmed evey 2 heous, rFeator operation may continue while awaiting restoration of the containment ventilation uRit condensate draiin tan leve monitor to (PERqALE e status.

With the CVUCDT level monitor inoperable, alternative action is again required. Either a water inventory balance, in accordance with SR 3.4.13.1; or grab samples obtained and analyzed at a frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or SR 3.4.15.1, CHANNEL CHECK, of the containment atmosphere particulate radioactivity monitor at 8-hour intervals, must be performed to provide alternate periodic information. Required Action C. 1 is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

Provided a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or grab samples taken and analyzed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or a CHANNEL CHECK of the containment atmosphere particulate radioactivity monitor is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , reactor operation may continue while awaiting restoration of the CVUCDT level monitor to OPERABLE status. The 24 and 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months intervals provide periodic information that is adequate to detect RCS LEAKAGE.

The 21 hour2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months iRterval proevides periodic inrFomatinef thats adequate to detect RCS LEAKAGE.

D.1 and D.2 With the required containment atmosphere particulate radioactivity monitor inoperable in MODE I and the Fequired containment ventilation unit condensate drain tank level monitor inoperable in MODE 1, the only means of detecting leakage is the containment floor and equipment sump level monitor and incore instrument sump level alarm. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

Catawba Units I and 2 B 3.4.15-7 Revision No. 4-

RCS Leakage Detection Instrumentation B 3.4.15 BASES E.1 With the incore sump level alarm inoperable, a water inventory balance, in accordance with SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide alternate periodic information that is adequate to detect leakage. Required Action E I is modified by a Note that states the RCS water inventory balance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation in accordance with SR 3.4.13.1. This Note allows exceeding the 24-hour completion time during non-steady state operation.

F.1 and F.2 If a Required Action of Condition A, B, C, or D cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

G.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. The required monitors during MODE I for LCO 3.0.3 entry are defined as the simultaneous inoperability of one CFAE level monitor, the containment atmosphere particulate radioactivity monitor, and the CVUCDTlevel monitor. The required monitors during MODES 2, 3, and 4 for LCO 3.0.3 entry are defined as the simultaneous inoperability of one CFAE level monitor and the CVUCDT level monitor.

This condition does not apply to the incore instrument sump level alarm.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the Fequired containment atmosphere particulate radioactivity monitor. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

Catawba Units 1 and 2 B 3.4.15-8 Revision No. 1

RCS Leakage Detection Instrumentation B 3.4.15 BASES SR 3.4.15.2 SR 3.1.15.2 requires the performance of a COT on the required ontai nt atmosphere radioacti.'ity; monitor. The test en sures that the monitor can perfoem its function in the desired manner. The test verifies the alarm setpeint and rI ccucy of the instmment etring. The COT is relative to the detection of radioactivity indicative of a 1 gpm RCS leak, within one hour of leakage onset. The COT doe; not; erif,'

automatic actions associated with high radioactivity on the applicable channels. The Frequency of 92 days considers instrument reliability, and operating oxperienec has shown that it is proper for deteg degradation SR 3.4.15.2 requires the performance of a COT on the containment atmosphere particulate radioactivity monitor. The test ensures that a signal from the monitor can generate the appropriate alarm associated with the detection of a minimum I gpm RCS leak. The desired alarm is derived from a digital database. Database manipulation concurrent with a signal supplied from the detector verifies the operability of the required alarm. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3. SR 3.4.15.4. andSR 3.4.15.5. and SR 3.4.15.6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

REFERENCES

1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45.

3.

UFSAR, Section 5.2.5.

4.

10 CFR 50.36, Technical Specifications, (cX2)(ii).

5.

Catawba Safety Evaluation Report, Section 5.2.5

6.

UFSAR, Table 5-10 Catawba Units 1 and 2 B 3.4.15-9 Revision No. 4 Description of Proposed Changes and Technical Justification CONTENTS

1.0 DESCRIPTION

1.1 Introduction 1.2 McGuire and Catawba TS and Bases Changes 1.3 Discussion of Proposed Changes 2.0 TECHNICAL JUSTIFICATION

2.1 Background

2.2 Containment Sump Monitors 2.3 Containment Atmosphere Radioactivity Monitors 2.4 Diverse Means of Detecting Reactor Coolant Leakage 2.5 Applicable Regulatory Criteria 2.6 Leak-Before-Break 2.7 Precedent Licensing Actions

3.0 CONCLUSION

4.0 REFERENCES

Rev. 1 1

Description of Proposed Changes and Technical Justification 1.0 DESCRPTION 1.1 Introduction Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) is submitting a license amendment request (LAR) applicable to the Technical Specifications and Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station, Units 1 and 2, respectively; and NPF-35 and NPF-52 for Catawba Nuclear Station, Units 1 and 2, respectively.

For McGuire, this LAR revises TS 3.4.15, RCS Leakage Detection Instrumentation, and its associated Bases; and Updated Final Safety Analysis Reports (UFSAR) Sections 1.7, Division 1 Regulatory Guides; 5.2.7, Reactor Coolant Pressure Boundary Leakage Detection System (and Table 5-30); and 11.4.2.2.4', Containment Airborne Monitor.

For Catawba, this LAR revises TS 3.4.15, RCS Leakage Detection Instrumentation, and its associated Bases; and UFSAR Sections 1.7.1, Regulatory Guides, 5.2.5, Detection of Leakage Through Reactor Coolant Pressure Boundary (and Table 5-10); and 11.5.1.2.2.2, Containment Airborne Monitor.

Appropriate changes to the plants' UFSARs will be submitted to the NRC later in accordance with 10 CFR 50.71(e) and these changes will note the exceptions being taken to RG 1.45.

1.2 McGuire and Catawba TS and Bases Changes Currently McGuire LCO 3.4.15 contains the following:

"The following RCS leakage detection instrumentation shall be OPERABLE:

a.

The containment floor and equipment sump level monitoring system;

b.

One containment atmosphere gaseous radioactivity monitor; and Rev. 1 2

Description of Proposed Changes and Technical Justification

c.

Either the containment ventilation condensate drain tank level monitor or the containment atmosphere particulate radioactivity monitor."

This LAR revises McGuire LCO 3.4.15 to state:

"The following RCS leakage detection instrumentation shall be OPERABLE:

a.

The containment floor and equipment sump level monitors and the incore instrument sump level alarm;

b.

The containment atmosphere particulate radioactivity monitor; and

c.

The containment ventilation unit condensate drain tank level monitor."

Currently Catawba LCO 3.4.15 contains the following:

"The following RCS leakage detection instrumentation shall be OPERABLE:

a.

One containment floor and equipment sump level monitor;

b.

One containment atmosphere radioactivity monitor (gaseous or particulate); and

c.

One containment ventilation unit condensate drain tank level monitor."

This LAR revises Catawba LCO 3.4.15 to state:

"The following RCS leakage detection instrumentation shall be OPERABLE:

a.

The containment floor and equipment sump level monitors and the incore instrument sump level alarm; Rev. 1 3

Description of Proposed Changes and Technical Justification

b.

The containment atmosphere particulate radioactivity monitor; and

c.

The containment ventilation unit condensate drain tank level monitor.

The APPLICABILITY, of the LCO to the containment atmosphere particulate radioactivity monitor is being changed to MODE 1 only, and a NOTE is added to the actions allowing separate condition entry for each leakage detection instrument.

In Required Action A.l, a Note is added to state that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

This is because the RCS water inventory balance must be performed with the reactor at steady state operating conditions and near operating pressure.

The allowance of the proposed Note is consistent with NUREG-1431, "Standard Technical Specifications Westinghouse Plants," (STS) and SR 3.4.13 itself.

For clarification, the Bases states this Note allows exceeding the 24-hour completion time during non-steady state operation.

Condition B for McGuire and Catawba is being changed to be applicable to the containment atmosphere particulate radioactivity monitor instead of the containment atmosphere gaseous radioactivity monitor which is being removed from the TS.

The same Note for SR 3.4.13.1 is being added to Required Action B.1.

Condition C for Catawba is being changed to delete "required," since there is only one containment ventilation unit condensate drain tank monitor.

The same Note for SR 3.4.13.1 is being added to Required Action C.1.

For consistency at McGuire, this requires the addition of a new CONDITION C along with Required Actions and Completion Times, as shown below.

Rev. 1 4

Description of Proposed Changes and Technical Justification CONDITION REQUIRED ACTION COMPLETION TIME C.

Containment ventilation C.1

NOTE--

unit condensate drain Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months tank level monitor after establishment of inoperable.

steady state operation.

Perform SR 3.4.13.1 Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR C.2 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

OR C.3 Perform SR 3.4.15.1.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Condition D for McGuire and Catawba is being changed to delete "required" (Catawba only) and to specify the containment atmosphere particulate radioactivity monitor.

New Condition E is added for McGuire and Catawba to specify the performance of a water inventory balance (SR 3.4.13.1) and appropriate Completion Time when the incore instrument sump level alarm is inoperable.

Surveillance Requirements (SR) 3.4.15.1, 3.4.15.2, and 3.4.15.4 are being clarified to indicate that they now apply to the containment atmosphere particulate radioactivity monitor.

SR 3.4.15.1, 3.4.15.2, 3.4.15.3, 3.4.15.4, and 3.4.15.5 are being revised to remove "required," since there is only one each of the applicable leakage detection instrumentation subsystems.

A new SR 3.4.15.6, Channel Calibration, is being added to apply to the incore instrument sump level alarm.

The associated Rev. 1 5

Description of Proposed Changes and Technical Justification Bases are being adjusted to conform with the above changes.

The Catawba Bases for SR 3.4.15.2 is also being clarified to add a description of the test to demonstrate the alarm operability.

Following approval and implementation of the changes contained in this LAR, TS 3.4.15 will be consistent at McGuire and Catawba.

1.3 Discussion of Proposed Changes The current McGuire and Catawba TS 3.4.15 do not include either the incore instrument sump level alarm or the volume control tank (VCT) level instrumentation as subsystems of the RCS Leakage Detection Instrumentation.

In regard to RCS leakage detection, neither of these subsystems are discussed in the associated Bases for TS 3.4.15, nor is there a detailed discussion of the incore instrument sump in the UFSAR.

This LAR adds these two subsystems to the TS 3.4.15 Bases as additional diverse means of detecting reactor coolant system leakage and addresses the compliance with the applicable regulatory document, Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," (RG 1.45).

Additionally, the incore instrument sump level alarm is being added as part of LCO 3.4.15.a and is also addressed by new Condition E.

Specifically, within this LAR, Duke is proposing to address the design basis considerations listed below.

Add the incore instrument sump level alarm to LCO 3.4.15.a with a new Condition E, a new Required Action E.1, Completion Time, a new SR 3.4.15.6, and discuss these in the Bases.

The surveillance frequency of 18 months is consistent with that for the containment floor and equipment (CFAE) sump level monitoring instrumentation.

The Bases discussion and the forthcoming UFSAR revisions include this subsystem's degree of compliance with RG 1.45 as a diverse means of leakage detection.

Rev. 1 6

Description of Proposed Changes and Technical Justification

Remove the option to use the containment atmosphere gaseous radioactivity monitor for RCS leakage detection instrumentation.

These current TS requirements are being transferred to the containment atmosphere particulate radioactivity monitor.

The Bases discussion and the forthcoming UFSAR revisions include this subsystem's degree of compliance with RG 1.45 as a diverse means of leakage detection.

Add a VCT level change subsystem description to the Bases, with a statement that this system enhances the diversity of the leakage detection function as recommended in RG 1.45.

This subsystem is not to be required by the LCO, similar to the current status of instrumentation for containment humidity, temperature, and pressure.

Add to the Bases, a discussion of the containment environmental conditions during plant power operations and the physical configuration of lower containment in regard to the total reactor coolant system leakage (including steam) flow into the CFAE and incore instrument sumps, since this phenomenon lengthens the leakage detection response time.

Also clarify that these conditions mean that reactor coolant system pressure boundary leakage detection by the CFAE and incore instrument sumps will typically occur following other means of leakage detection.

Add to the Bases, a discussion of control room operator actions following an alarm or indication of RCS leakage.

2.0 TECHNICAL JUSTIFICATION

2.1 Background

Current TS 3.4.15 requires that the CFAE sump level monitoring instrumentation be operable to meet the TS requirements for the RCS leakage detection instrumentation.

The Bases for this TS states that measurement of CFAE sump level serves as the primary method of detecting leakage Rev. 1 7

Description of Proposed Changes and Technical Justification into the containment. Additionally for McGuire, the current TS 3.4.15 requires that one containment atmosphere gaseous radioactivity monitor and either the containment ventilation condensate drain tank level monitor or the containment atmosphere particulate radioactivity monitor be operable as well.

For Catawba, this LCO requires that one containment atmosphere radioactivity monitor (gaseous or particulate) and one containment ventilation unit condensate drain tank (CVUCDT) level monitor be operable as well.

This LAR proposes changes to the current McGuire and Catawba TS requirements for each of the RCS leakage detection instrumentation subsystems.

The revised TS places emphasis on providing diverse means to detect leakage rather than identifying a primary means as is currently the case with the CFAE sump monitoring system.

Also, this LAR clarifies the role of additional diverse means (beyond the LCO requirements) that are available to the plant operators to detect RCS leakage.

The incore instrument sump level alarm has not been considered part of the operability requirements for TS 3.4.15.

The McGuire UFSAR Section 5.2.7 and Catawba UFSAR Section 5.2.5 identify design features for detecting leakage inside containment.

However, in describing the leakage detection systems, the UFSARs do not discuss the incore instrument area in detail, since leakage into the area is not expected under normal operating conditions-and actual operating experience confirms this.

This LAR enhances the McGuire and Catawba licensing basis by adding the incore sump level instrumentation to each plant's TS and Bases.

In 1973, the NRC provided guidance in Regulatory Guide 1.45 for detecting RCS leakage using containment atmosphere radiation monitors.

Subsequent to the RG 1.45 guidance, the NRC has published clarification that instruments with a sensitivity of 10-9 pCi/cc for air particulate monitoring are designed in accordance with RG 1.45 position even for situations wherein the monitor's response exceeds the RG 1.45 position C.5 for a response time of 1 gpm within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (reference NRC enclosure dated July 18, 2002, ML021750004).

Both McGuire and Catawba radiation particulate monitors meet or exceed the RG 1.45 sensitivity Rev. 1 8

Description of Proposed Changes and Technical Justification recommendation of 10-9,Ci/cc and, therefore, an exception is requested to the RG 1.45 recommendation to respond to a 1 gpm leak within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This LAR revises the TS, Bases, and UFSARs to accurately reflect the capabilities of the containment atmosphere radioactivity monitors in regard to RG 1.45 and the applicable plant operating MODEs, as well as emphasize this subsystem's role in providing diverse means to detect RCS leakage.

2.2 Containment Sump Level Monitors Several references are in this document that use the term "incore."

For the purpose of this amendment, the incore instrument sump is in the corner of the incore instrument area and is located under the reactor vessel.

This sump contains the incore instrument sump level instrumentation.

The incore instrument room is outside the crane wall at the seal table.

The incore instrument tunnel is the sloped space between the incore instrument area and the incore instrument room.

One method of detecting leakage into the containment is by measurement of the CFAE sump level.

Sumps (A and B) are located on opposite sides of the containment outside the crane wall.

Any leakage that falls to the floor inside the crane wall will drain through crane wall penetrations at floor level (at McGuire) or run through embedded floor drains (at Catawba) to one of the two sumps.

Any leakage outside the crane wall that falls onto the floor will gravity drain to these sumps.

The sump level rate of change, as calculated by the operator aid computer (OAC),

would indicate the leakage rate.

This method of detection would indicate in the control room and may represent a water leak from either the Reactor Coolant System or the Main Steam and Feedwater Systems.

A 1 gpm leak (cumulative in both sump A and B) is detectable within a time period of one hour after leakage has reached the sump.

Duke has determined that the existing level instrumentation in the incore instrument sump would not detect a 1 gpm leak within a one hour time period.

Thus, the current incore instrument sump level alarm does not meet the requirements of RG 1.45, Position C.5.

Neither does the instrumentation Rev. 1 9

Description of Proposed Changes and Technical Justification meet Position C.7 for indication in the control room, Position C.8 for testing during plant operation, nor prior to approval of this LAR, Position C.9 for inclusion in the plants' Technical Specifications.

These exceptions are discussed further below.

However, the existing instrumentation does provide detection of leakage as discussed in Position C.3.

This LAR addresses these issues by adding the incore instrument sump level alarm to LCO 3.4.15.a, a new Condition E with Required Action and Completion Time, adding a discussion of the incore instrument sump level alarm to the TS 3.4.15 Bases, and by revising McGuire UFSAR Section 5.2.7 and Table 5-30 and Catawba UFSAR Section 5.2.5 and Table 5-10 to agree with the license bases changes contained in this LAR.

The TS and Bases changes are included within this LAR submittal package.

Appropriate changes to the plants' UFSARs will be submitted to the NRC in accordance with 10 CFR 50.71(e) and these changes will note the exceptions being taken to RG 1.45.

The Bases for TS 3.4.15 specifically discusses level instruments associated with the two CFAE sumps.

RG 1.45 permits the use of various instrumentation to detect RCS leakage, with a sensitivity equivalent to 1 gpm within a one hour period.

This is true for the CFAE sump level instrumentation, but not for the incore instrument sump level alarm.

Although the incore instrument sump level alarm is not as sensitive as that of the CFAE sumps, a 1 gpm leak detection capability within less than three hours (once leakage has reached the sump) is available.

In order to provide some margin, the McGuire and Catawba licensing bases are being changed to state a four-hour response time.

The ability of the incore instrument sump subsystem to detect a primary system pressure boundary leak is not a current TS requirement.

This LAR adds it to LCO 3.4.15.a and the Bases and forthcoming UFSAR revisions will discuss the exceptions in its capabilities to meet the RG 1.45 criteria.

These exceptions are also identified within this LAR submittal document.

The incore instrument sump alarm subsystem enhances the diversity of the RCS leakage detection function as permitted by RG 1.45.

Rev. 1 10 Description of Proposed Changes and Technical Justification For both McGuire and Catawba, the incore instrument sump level will alarm at a level of approximately 11" above the sump floor, and thus is capable of detecting a leak of approximately 170 gallons or a sump input rate of 1 gpm in approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 50 minutes, once leakage has reached the sump.

The incore instrument sump level alarm provides a level indication alarm in the control room.

Although leakage in this area is not typical, there are potential reactor coolant leak locations that would be indicated by the incore instrument sump level.

The alarm response for this leakage refers operators to TS 3.4.13, RCS Qperational Leakage, for limiting conditions for operations with unidentified leakage.

This sump level instrumentation will now be required by TS and will provide a means of detecting leakage into the incore instrument sump and an additional means of detecting reactor coolant system leakage.

When accumulated liquid volume in the incore instrument sump reaches the alarm level, leakage would be detectable by means of the level instrumentation as described above.

As described above, the incore instrument sump level alarm cannot detect a one gpm leak within one hour and is an exception to position C.5 of Regulatory Guide 1.45.

The incore instrument sump level alarm does not provide indication to the control room for converting to a common leakage equivalent, and is likewise an exception to position C.7.

The incore instrument sump level alarm is located under the reactor vessel where radiation levels restrict all personnel access for testing of operability and calibration during plant operation, and thereby is an exception to position C.8.

Based on the latter limitation, the surveillance frequency for the incore instrument sump alarm is being proposed as 18 months, coinciding with refueling outages and consistent with that for the CFAE sump level monitoring instrumentation.

In that leakage into the incore instrument area under the reactor vessel is not expected during normal plant operation, and that TS-controlled diverse means remain available for detection of leakage by means of the CFAE sump level monitors, the CVUCDT level monitor, and the containment atmosphere particulate radioactivity monitor, plus additional non-TS diverse means, these exceptions to the recommendations of Regulatory Guide 1.45 do not prevent the timely Rev. 1

.11 Description of Proposed Changes and Technical Justification identification of any postulated reactor coolant pressure boundary leakage.

2.3 Containment Atmosphere Radioactivity Monitors TS LCO 3.4.15 allows use of either the gaseous or the particulate monitor to satisfy the requirements for one containment atmosphere radioactivity monitor.

Due to improved fuel integrity and resulting reduced RCS radioactivity levels, the gaseous channel of the containment atmosphere radiation monitor has become less effective for RCS leakage detection.

Therefore, the gaseous monitor is being proposed for deletion from the TS.

Following approval of this LAR, the containment atmosphere radioactivity monitoring requirement of LCO 3.4.15 will be fulfilled by the particulate channel.

The containment atmosphere gaseous monitor will continue to be maintained and available at both McGuire and Catawba in accordance with normal non-TS equipment practices and procedures to provide additional diverse means of detecting a RCS leak to containment.

Regulatory Guide 1.45 states that instrument sensitivities of 10-9 pCi/cc radioactivity for air particulate monitoring are practical for leakage detection systems.

As both McGuire and Catawba meet or exceed this accepted sensitivity, Duke proposes the operability of the particulate monitors to be based upon the following conditions:

Instrument sensitivity > 10-9 pCi/cc

Channel Check frequency every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

Channel Operational Test frequency every 92 days

Channel Calibration frequency every 18 months RG 1.45 also states that detector systems should respond to a one gpm, or its equivalent, leakage increase in one hour or less.

The containment atmosphere particulate radioactivity monitors at both McGuire and Catawba have demonstrated capabilities of detecting a 1.0 gpm leak within one hour at the sensitivity recommended in Regulatory Guide 1.45 using the RCS corrosion product activities as provided in the UFSAR.

However, recently Rev. 1 12 Description of Proposed Changes and Technical Justification measured RCS activities are significantly lower than those provided in the USFAR.

Lower RCS activities will result in an increased detection time.

This LAR requests an exemption from the 1 gpm in one hour detection capability recommendation for the containment atmosphere particulate radioactivity monitors as stated in RG 1.45.

Analyses based on measured RCS radioactivity concentrations from February 2005, current background levels in containment, and conservative particulate transmission assumptions, have been conducted.

Based on probable operating conditions, the estimated time it would take for the containment atmosphere particulate monitor to detect a 1 gpm leak ranges from 1 to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , which corresponds to 100% power and hot zero power operating conditions.

The 100% power condition is the most probable power level based on operating history.

Thus, the applicability of LCO 3.4.15 is being limited to MODE 1 for this instrument.

A description of the analyses conducted to estimate the time it would take for the particulate monitors to detect and signal a 1 gpm leak of RCS to containment is provided in Attachment 5.

Industry operating experience has shown particulate monitors to be effective in detecting primary system leakage and the current containment atmosphere particulate radioactivity monitors at McGuire and Catawba meet or exceed the accepted 10 9 pCi/cc sensitivity as stated in RG 1.45.

Since the monitors meet the specified 10 9 pCi/cc sensitivity, they are designed in accordance with RG 1.45.

Therefore, Duke requests an exemption from the response time objective of 1 gpm in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as stated in RG 1.45 and proposes that the instrument operability requirements be based on the conditions discussed above.

Following deletion of the gaseous channel from the LCO, as discussed above, additional diverse means of leakage detection will continue to be available to provide RCS leakage detection capability at both McGuire and Catawba.

Rev. 1 13 Description of Proposed Changes and Technical Justification 2.4 Diverse Means of Detecting Reactor Coolant Leakage The proposed changes to TS LCO 3.4.15 specify three diverse means of detecting RCS leakage: 1) the CFAE sump level monitors and the incore instrument sump level alarm, 2) the containment atmosphere particulate radioactivity monitor, and 3) the CVUCDT level monitor.

As itemized below, there are other existing considerations which contribute to the diverse capability the plant operators have to detect RCS leakage.

McGuire and Catawba operating experience indicates that high temperature primary and secondary water leaks produce steam and hot water mist that is readily absorbed in the containment atmosphere.

Much of the hot water that 'reaches the containment floor will evaporate in the low-humidity environment as it migrates to the containment sumps.

The net effect is that any high enthalpy/high temperature system leakage is detectable in part by the containment atmosphere radioactivity monitor, the CVUCDT, and the CFAE and incore instrument sumps.

Forced ventilation serves the incore instrument area under the reactor vessel for McGuire and Catawba.

This ventilation is supplied to the area under the reactor vessel from the lower containment ventilation system.

By maintaining forced ventilation, the air volume of the incore instrument area is replaced at a frequent rate.

This provides for transportation of moisture and/or radioactivity with the return air to lower containment from any postulated reactor coolant system leak within this area, and the detection of leakage by either the CVUCDT monitor or the containment atmosphere radioactivity monitors.

VCT level monitoring provides an additional diverse means for detection of reactor coolant pressure boundary leakage.

A change in VCT level rate-of-change is detectable by control room operators as a potential leak in the reactor coolant pressure boundary.

Rev. 1 14 Description of Proposed Changes and Technical Justification The function of the CVUCDT in regard to RCS leakage detection is being clarified within this LAR to state that the leakage is detectable within the required response time after condensate has reached the tank, and for McGuire, strengthened by the addition of a new TS Condition, Required Actions, and Completion Time.

Requirements for the containment atmosphere particulate radioactivity channel will remain in LCO 3.4.15 and these include the requirement to analyze grab samples or perform an RCS mass balance calculation (SR 3.4.13.1, which along with SR 3.4.15.1, Channel Check, will also now be required for an inoperable CVUCDT) once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in case of inoperability.

The mass balance calculation can provide the control room operators with indication of a 1 gpm leak.

Further, there are other non-TS containment temperature and pressure instrumentation indications available in the control room and these contribute to the operators' ability to detect RCS leakage.

2.5 Applicable Regulatory Criteria General Design Criteria (GDC) 30, "Quality of Reactor Coolant Pressure Boundary", contained in Appendix A to 10 CFR 50, "General Design Criteria of Nuclear Power Plants",

requires that a means be provided for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage.

RG 1.45 describes acceptable methods of implementing this requirement with regard to the selection of leakage detection systems for the reactor coolant pressure boundary.

RG 1.45 is a-part of the McGuire and Catawba licensing bases.

The TS Bases states that RG 1.45 describes acceptable methods for selecting leakage detection systems, and both of the McGuire and Catawba UFSARs state that RG 1.45 was adopted with comment, the comment being related to seismic qualification and unrelated to the issue of instrumentation sensitivity.

RG 1.45 emphasizes the importance of early leak detection in the prevention of accidents and encourages improvements in leak detection techniques.

The RG describes various acceptable methods of detecting RCS leakage including sump Rev. 1 15 Description of Proposed Changes and Technical Justification level, tank level, and gaseous and particulate radiation monitors.

Although the RG does not attempt to describe all possible floor drain/sump arrangements, it is reasonable to conclude that the RG intends for the sump level instrumentation to reflect the cumulative leakage to the floor throughout the Containment Building.

This would include the area inside the crane wall, the pipe chase, and the incore instrument area.

RG 1.45 further recognizes that some methods, such as radiation monitors may be ineffective during certain periods of operation.

The RG recognizes that other detection methods may be developed although it does not explicitly suggest substitution of alternate methods in lieu of the recommended methods.

The exceptions taken to RG 1.45 that are related to this LAR are summarized in Table 1 which follows.

Rev. 1 16 Description of Proposed Changes and Technical Justification Table 1 C. Regulatory Position Exception / Clarification

2. Leakage to the primary reactor Incore sump alarm will detect a 1 gpm input within 4 containment from unidentified sources hours of leakage reaching the sump.

should be collected and the flow rate monitored with an accuracy of one gallon per minute or better.

5. The sensitivity and response time of Exception taken for containment particulate radiation each leakage detection system in monitor and incore sump level alarm.

regulatory position 3 above employed for unidentified leakage should be The particulate radiation monitor sensitivity will adequate to detect a leakage rate, or be 10-9 uCi/cc. The particulate monitor alarm its equivalent, of one gpm in less than setting will be as low as practicable based on one hour.

background and sufficiently high enough to prevent spurious alarms. Operability will be based on the sensitivity and surveillance testing.

The incore sump alarm will actuate within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of leakage reaching the sump Clarified CFAE and CVUCDT sensitivity of lgpm after leakage has reached the sump / tank.

7. Indicators and alarms for each Exception taken for incore sump indication in the control leakage detection system should be room - alarm only.

provided in the main control room.

Procedures for converting various The particulate radiation monitor and incore sump will indications to a common leakage alarm during the presence of a leak but are not equivalent should be available to the converted to a leakage equivalent (e.g. gpm).

operators. The calibration of the indicators should account for needed independent variables.

8. The leakage detection systems Exception taken for incore sump level alarm for testing should be equipped with provisions to and calibration during plant operation.

readily permit testing for operability and calibration during plant operation.

Rev.

1 17 Description of Proposed Changes and Technical Justification Following NRC approval, the above exceptions and clarifications will establish the revised McGuire and Catawba licensing basis for RCS Leakage Detection Instrumentation correlated to RG 1.45 recommendations.

These changes will not impact the basis or results of the Leak-Before-Break analysis.

10 CFR 50.36 is the NRC regulation that addresses the content of TS at nuclear power plants.

Following review of this regulation, Duke has determined that the incore instrument sump level alarm should be included in the McGuire and Catawba TS LCO 3.4.15.a with a new Condition and appropriate Required Action and Completion Time and discussed in the associated Bases, since it contributes to ensuring the integrity of the reactor coolant pressure boundary.

The applicable section of the NRC Safety Evaluation Report for McGuire and Catawba is Section 5.2.5, Reactor Coolant Pressure Boundary Leakage Detection System.

Appropriate discussions that reflect the changes contained in this LAR will be added to the McGuire and Catawba UFSARs in accordance with 10 CFR 50.71(e).

2.6 Leak-Before-Break In light of the RCS leakage detection capabilities of the containment incore instrument sump level alarm and the containment atmosphere-radioactivity monitors, the technical bases for applying the leak-before-break concept to McGuire and Catawba were reviewed.

The leak-before-break analysis (LBB) for large diameter primary piping for McGuire was submitted by Reference 1 and approved by the NRC in Reference 2, and submitted' for Catawba in References 3 and 4 and approved by the NRC in References 5 and 6. Each of these analyses calculated a leak through a postulated leakage flaw that is large relative to the sensitivity of the plants' leak detection systems, consistent with RG 1.45.

That is, the capability of the incore instrument sump level alarm to detect a 1 gpm Rev. 1 18 Description of Proposed Changes and Technical Justification leak in four hours and the capability of the containment atmosphere particulate radioactivity monitor, as described above, is adequate to ensure identification of a leak bounded by the LBB methodology, since sufficient margin in initial leakage and flaw stability has been demonstrated.

The current structural design basis for the McGuire reactor coolant system (RCS) primary loops requires that pipe breaks be postulated as defined in the approved Westinghouse WCAP-8082 (Reference 7).

The postulated pipe break locations for the main coolant loop are identified in UFSAR Table 3-21.

The leak rate predictions of Enclosure A of Reference 1, WCAP-10585 (Reference 8), which is McGuire's LBB analysis, identifies a critical flaw size of 29.33 inches long in the hot leg piping (2.31 inches thick) and establishes a postulated leak rate of 96 gpm using an initial through wall crack of 7.5 inches long.

This provides an adequate margin between the critical flaw size and the postulated leakage flaw size, as well as between the postulated leak rate and the present leak detection capability identified as McGuire's licensing basis (i.e.,

the ability to detect leakage of 1 gpm within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as recommended by RG 1.45).

The current structural design basis for the Catawba reactor coolant system (RCS) primary loops requires that pipe breaks be'postulated as defined in the approved Westinghouse WCAP-8082 (Reference 7).

The postulated pipe break locations for the main coolant loop are identified in UFSAR Table 3-20.

The leak rate predictions of Enclosure A of Reference 4, Westinghouse Topical Report WCAP-10546 (Reference 9), which is Catawba's LBB analysis, identifies a critical flaw size of 32.5 inches long in the cross over piping (2.61 inches thick) and establishes a postulated leak rate of 10 gpm using an initial through wall crack of 7.5 inches long.

This provides an adequate margin between the critical flaw size and the postulated leakage flaw size, as well as between the postulated leak rate and the present leak detection capability identified as Catawba's licensing basis (i.e., the ability to detect leakage of 1 gpm within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months as recommended by RG 1.45).

Rev. 1 19 Description of Proposed Changes and Technical Justification The underlying technical basis for LBB is based on a leak rate alone.

Extension of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months timeframe discussed in RG 1.45 and the McGuire and Catawba LBB analyses does not affect the technical basis for the fracture mechanics analyses demonstrating LBB.

There is no credible failure mechanism associated with the RCS piping/components that would lead to crack propagation from the reference leakage crack size of 7.5 in. to the critical flaw size in a short period of time.

Fatigue, intergranular stress corrosion cracking, and primary water stress corrosion cracking are relatively slow failure mode processes.

Therefore, a crack producing a leak rate as predicted by the LBB analyses would not grow measurably under any of these individual or collective failure modes in a short period of time.

Furthermore, the LBB analyses indicate that given the leakage crack size associated with a referenced leak, the crack is stable under the worst case design load combination of deadweight, pressure, thermal expansion, and seismic (SSE) loads.

2.7 Precedent Licensing Actions Table 2, which follows, summarizes previous approvals for leak detection response times for radioactivity monitors.

Table 2 Plant Date Monitor response Assumption Byron and January 14, 2005 1 gpm detection in 7.3 realistic activity levels Braidwood SER hours (particulate)

NRC response to July 18, 2002 1 OV pCi/cc sensitivity for N/A 3 questions RG 1.45 compliance ML021750004 (particulate)

Indian Point 3 January 30, 2002 1 gpm detection in 4 to 7 Realistic activity levels SER and hours (particulate) and 70 October 25, 2001 hours0.0232 days 0.556 hours 0.00331 weeks 7.613805e-4 months (gaseous) letter Rev. 1 20 Description of Proposed Changes and Technical Justification Table 2 (continued)

Plant Date Monitor response Assumption Crystal River June 14, 1999 1 gpm detection in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 0.1 % failed fuel from plant SER (particulate) and 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months environmental report (gaseous)

St Lucie May 27, 1999 1 gpm detection in 18.1 0.1% failed fuel Safety hours (particulate) and Assessment 15.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (gaseous)

Turkey Point May 27, 1999 1 gpm detection in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1% failed fuel Safety (particulate) and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Assessment (gaseous)

3.0 CONCLUSION

Based on the above discussion, an effective RCS leakage detection system must depend on diverse methods of detection and these diverse methods must be able to detect significant RCS pressure boundary degradation as soon after occurrence as practical to minimize the potential for gross boundary failure.

This LAR clarifies the alternate and diverse means available for RCS leakage detection at McGuire and Catawba.

RG 1.45 recommends that the sensitivity and response time of each leakage detection system be adequate to detect a leakage rate, or its equivalent, of 1 gpm in less than one hour.

The RG recognizes that variables exist that make some methods of leakage detection ineffective and untimely under certain operating conditions so that diverse detection methods and consideration of delay time are appropriate and required.

The design of the McGuire and Catawba RCS leakage detection system incorporates diverse methods of detection as currently required by TS 3.4.15 and emphasized by this LAR.

Additionally other diverse methods of leakage detection are available, such as containment humidity, air temperature, and pressure monitoring.

Further, the current UFSARs describe an additional method for leakage detection via changes in the VCT level, which uses as its basis, the makeup demand for the RCS.

The VCT level change trend is very useful to the control room operators but is not required by the TS LCO 3.4.15.

21 Rev. 1 1

21 Description of Proposed Changes and Technical Justification The incore instrument sump level instrumentation is not currently covered by the TS, nor discussed in detail in the UFSARs, in regard to reactor coolant leakage detection, but it is concluded that it should be controlled by TS and included in the McGuire and Catawba licensing bases since it serves as a diverse means of detecting RCS leakage and contributes to ensuring the integrity of the reactor coolant pressure boundary.

The changes proposed in this LAR enhance the McGuire and Catawba TS and licensing bases.

While the proposed amendment eliminates the gaseous channel of the containment atmosphere radioactivity monitors from LCO 3.4.15, it results in a more restrictive requirement in the LCO for the containment atmosphere radioactivity monitor for the particulate channel.

This LAR proposes additions that strengthen the TS controls for the McGuire and Catawba RCS leakage detection instrumentation.

Following implementation of this LAR, the TS will continue to require diverse means of leakage detection with the capability to detect RCS leakage such that adequate margin is maintained with the NRC-approved LBB analyses for both McGuire and Catawba.

4.0 REFERENCES

1.

Letter, H. B. Tucker, Duke Power Company to H. R.

Denton, U. S. Nuclear Regulatory Commission,

SUBJECT:

McGuire Nuclear Station, Docket Nos. 50-369 and 50-370, Pipe Break Criteria Relief for Reactor Coolant Loop, Dated August 30, 1985.

2.

Letter, B. J. Youngblood, U. S. Nuclear Regulatory Commission, to H. B. Tucker, Duke Power Company,

SUBJECT:

McGuire Nuclear Station -

Elimination of Large Primary Loop Pipe Ruptures, Dated May 8, 1986.

3.

Letter, H. B. Tucker, Duke Power Company, to H. R.

Denton, U. S. Nuclear Regulatory Commission,

SUBJECT:

Catawba Nuclear Station, Docket Nos. 50-413 and 50-414, Dated May 11, 1984.

Rev. 1 22 Description of Proposed Changes and Technical Justification

4.

Letter, H. B. Tucker, Duke Power Company to H. R.

Denton, U. S. Nuclear Regulatory Commission,

SUBJECT:

Catawba Nuclear Station, Unit 1, Docket No. 50-413, Pipe Break Criteria Relief for Reactor Coolant Loop, Dated November 27, 1985.

5.

Letter, E. G. Adensam, U. S. Nuclear Regulatory Commission, to H. B. Tucker, Duke Power Company,

SUBJECT:

Request for Exemption from a Portion of General Design Criterion 4 of Appendix A to 10 CFR Part 50 Regarding the Need to Analyze Large Primary Loop Pipe Ruptures as a Structural Design Basis for Catawba Nuclear Station, Unit 2, Dated April 23, 1985.

6.

Letter, K. H. Jabbour, U. S. Nuclear Regulatory Commission, to H. B. Tucker, Duke Power Company,

SUBJECT:

Catawba Nuclear Station -

Elimination of Large Primary Loop Pipe Ruptures, Dated April 7, 1987.

7.

WCAP-8082 P-A, "Pipe Breaks for the LOCA Analysis of the Westinghouse Primary Coolant Loop," Class 2, January 1975.

8.

WCAP-10585, "Technical Bases for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for McGuire Units 1 and 2," (Westinghouse Proprietary Class 2), June 1984.

9.

Westinghouse Topical Report, WCAP-10546, "Technical Bases for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for Catawba Units 1 and 2," (Westinghouse Proprietary Class 2), April 1984.

Rev. 1 23 No Significant Hazards Consideration Determination Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) has made the determination that this license amendment request (LAR) involves No Significant Hazards Consideration through the application of the standards established by the NRC's regulations in 10 CFR 50.92.

These three standards are discussed below.

1. Would implementation of the changes proposed in this LAR involve a significant increase in the probability or consequences of an accident previously evaluated?

No.

The changes contained in this LAR have been evaluated and determined to not increase the probability or consequences of an accident previously evaluated.

The proposed changes do not make any hardware changes and do not alter the configuration of any plant structure, system, or component.

The proposed LAR: 1) removes the containment atmosphere gaseous radioactivity monitor as an option for meeting the operability requirements of TS 3.4.15 and replaces it with the containment atmosphere particulate radioactivity monitor, 2) clarifies the applicability of the TS to the containment atmosphere particulate radioactivity monitor, 3) adds the incore instrument sump and its level instrumentation to the McGuire and Catawba licensing basis contained in the TS, the Bases, and the Updated Final Safety Analysis Reports, and 4) makes other low risk changes to TS 3.4.15.

None of the containment Reactor Coolant System (RCS) leakage detection instrumentation systems are initiators of any accident; therefore, the probability of occurrence of an accident is not increased.

The McGuire and Catawba licensing bases will continue to require diverse means of detecting reactor coolant system (RCS) leakage, thus ensuring that leakage due to cracks would continue to be identified prior to breakage and the plant would be shutdown accordingly.

Therefore the consequences of an accident are not increased.

Rev. 1 1

No Significant Hazards Consideration Determination

2. Would implementation of the changes proposed in this LAR create the possibility of a new or different kind of accident from any accident previously evaluated?

No.

The changes proposed in this LAR do not involve the use or installation of any equipment that is less conservative than that already installed and in use.

No new or different system interactions are created and no new processes are introduced.

The proposed changes will not introduce any new failure mechanisms, malfunctions, or accident initiators not already considered in the design and licensing basis.

The proposed changes do not affect any structure, system, or component associated with an accident initiator.

Based on these considerations, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Would implementation of the changes proposed in this LAR involve a significant reduction in a margin of safety?

No.

The changes proposed in this LAR do not make any alteration to any RCS leakage detection components.

The proposed changes only remove the containment atmosphere gaseous radioactivity monitors as an option for meeting the operability requirements for TS 3.4.15 and replace it with the more responsive containment atmosphere particulate radioactivity monitor.

Since the level of radioactivity in the McGuire and Catawba reactor coolant has become much lower than what was assumed in the original licensing bases, the gaseous channel can no longer detect a small RCS leak consistent with the plants' leak-before-break (LBB) analyses.

A conservative addition is being made to TS 3.4.15 in order to include controls for the incore instrument sump level instrumentation.

The changes contained in the LAR are not risk significant since the RCS leakage detection instrumentation is not credited in the McGuire and Catawba probabilistic risk assessments.

The proposed amendment continues to require diverse means of leakage Rev. 1 2

No Significant Hazards Consideration Determination detection equipment with the capability to promptly detect RCS leakage well within the margin of the LBB analyses.

Based on this evaluation, the proposed changes do not involve a significant reduction in a margin of safety.

Conclusion Based upon the preceding discussion, Duke has concluded that this LAR does not involve a significant hazards consideration.

Rev. 1 3

Environmental Assessment/Impact Statement A review of this license amendment request has determined it would change a requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20.

However, the proposed changes do not involve: (i) a significant hazards consideration (see Attachment 3), (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with this license amendment request.

1 Summary Description of the Results of the Particulate Radiation Monitor Response Time Calculation Introduction U.S. NRC Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," describes acceptable methods of implementing the requirements for reactor coolant leakage detection systems.

RG 1.45 states that instrument sensitivities of 10-9 pCi/cc radioactivity for air particulate monitoring are practical for leakage detection systems.

Subsequent to the RG 1.45 guidance, the NRC has published clarification that instruments with a sensitivity of 10-9 microcuries per cubic centimeter (pCi/cc) for air particulate monitoring are designed in accordance with the RG 1.45 position, even for situations wherein the monitor's response exceeds the RG 1.45 Position C.5 for a response time of 1 gpm within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (reference NRC enclosure dated July 18, 2002, ML021750004).

The particulate monitors at both Catawba and McGuire meet or exceed this accepted sensitivity.

Analyses have been performed to estimate the time it would take for the particulate atmosphere containment monitors to detect a one gpm RCS leak into containment.

The analyses are based on RCS activity concentration from February 2005, containment background radiation levels and particulate transmission factors.

Details of the analyses are presented below.

Analytical Method The estimated time it would take for the particulate monitors to detect a step change in leakage of one gpm is calculated by estimating the buildup of radioactivity over time on the particulate filter paper (in pCi) and multiplying by the detector response sensitivity (in cpm/pCi).

The build up of activity in containment from a one gpm leak and the subsequent build up of activity on the filter paper, based on the monitor flow rate, is modeled by linear differential equations.

The differential equations also considered radioactive decay and particulate transmission factors.

A computer spreadsheet is used to perform the analytical model in one minute time increments.

1 The following table summarizes the design of the Catawba and McGuire atmosphere particulate radioactivity monitors:

[

DETECTOR INFORMATION Catawba McGuire Manufacturer General Atomic Model General Atomic Model MauatrrRD-36 RD54-30 Detector Plastic Beta Plastic Beta type Scintillator/GM tube Scintillator Sensitivity at least 10-' pCi/cc at least 10-9 lci/cc Filter Paper Roll Filter Paper which Fixed filter replaced Mode advances 0.6 inches approximately every 30 every 40 minutes days The isotopes and respective concentrations assumed in the analyses are summarized in the table below.

ISOTOPIC CONCENTRATION (pCi/cc)

F-18 1.2E-01*

Fe-59 3.OE-05 Co-60 7.OE-05

[Zr-95 2.OE-04 F-18 concentration is included in the 100% power analysis -

Case II.

Because F-18 is a water activation product, no credit is taken for F-18 for hot-zero power conditions -

Case I.

The isotopes were limited to the four mentioned above because they consist of long lived corrosion products and a dominant activation product.

The isotopic concentrations in the table above were determined by averaging all February 2005 sample data for Catawba (both units) and McGuire (both units) and selecting the lowest site-average isotopic concentration between the two plants. Several other beta emitting isotopes that were present in RCS sample data were conservatively not included in the analyses.

Chemistry staff determined that the sample data for the aforementioned isotopes were in close agreement between the units at both plants and representative numbers to characterize

'normal' RCS concentrations were selected.

The calculations assume that the particulate monitors are set to the lowest sample flow rate of 3 SCFM.

Various sample locations are monitored within containment, including one location in upper containment and two sample locations in lower containment.

The total flow rate to the detector through the three samples 2

line is 3 SCFM, however the analyses credit flow only through the sample lines located in lower containment. As a result, the flow rate is assumed to be 2 SCFM.

The analyses also assume instantaneous homogeneous mixing of RCS activity into the total volume of lower containment.

In February 2005, using the new methodology for alarm setpoint

~as low as practicable, the monitor alarm setpoint would have

'been 39 cpm above background at Catawba and 10 cpm/min for Case I or 50 cpm/min for Case II at McGuire.

The alarm setpoints are changed periodically based on changes in the average background.

The setpoints are set as low as practicable to prevent spurious nuisance alarms.

Case I - hot zero power conditions Empirical studies have been preformed to determine the particulate transmission in the particulate monitor sample lines.

The longest particulate monitor sample line at Catawba was chosen as being the most conservative testing location.

Two different particle counters were used to determine the concentration of particles in the sample line.

One counter sampled air from inside containment and the other from the sample line just before entering the particulate monitor.

The test was also performed at two different flow rates in order to determine flow rate effect on particle transmission.

The lowest tested particulate transmission factor (PTF) of the various flow rates and particle sizes that were tested was determined to be 0.11, rounded down to 0.1 in the analyses.

The tested particulate transmission factor (PTF) described above is conservatively assumed to be applied only to the sample line.

Other reduction factors as provided in the table below are also considered in the analysis.

FACTORS AFFECTING PARTICULATE TRANSMISSION Density Correction (g/cc) 0.7 Tested Particulate Transmission Factor (PTF) 0.1 Flashing Fraction 0.4 Filter Efficiency 0.5 Containment Release 0.9 Total Product of Transmission Factors 0.01 3

Conservatism was also applied to determine the transmission factors listed in the table above.

As shown in the table above, the total product of the transmission factors is 0.01.

Case II 100% power conditions

!The contribution of F-18 was included with this analysis.

Transmission factor is assumed at 0.0001.

Analytical Results The analyses evaluate the time it would take for the detector count rate to exceed the alarm setpoint as described in the previous section.

The results of the analyses described are listed below.

CASE 1 TIME TO REACH ALARM SETPOINT AT HOT ZERO POWER Catawba McGuire Alarm Times

< 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

< 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months CASE 2 -

TIME TO REACH ALARM SETPOINT AT 100% POWER ICatawba JMcGuire Alarm Times

< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months j< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 4

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2.1 Background

3.0 CONCLUSION

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