ML20217E973

Provides Responses to Comments on Sections 1.0,2.0,3.0 & 4.0.Changes Denoted by Rev Bars to Facilitate Staff Review

ML20217E973
Person / Time
Site:	Catawba
Issue date:	04/20/1998
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217E978	List: ML20217E973 ML20217E983
References
TAC-M95298, TAC-M95299, NUDOCS 9804280017
Download: ML20217E973 (5)

Text

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p 4-Duke Power Company A Ekke Ewy Cenepny EC07H wwww 526 South Church Street PO. Ilox 1006 Charlotte, NC 28201-1006 M. S. Takman hecutiw We hident (7M)382-2200 omct Nudrar Generation (7M) 382-4360 nx April 20, 1998 U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555 Attention:

Document Control Desk

Subject:

Catawba Nuclear Station Docket Numbers 50-413, and -414 Improved Technical Specifications, Supplement 3 TAC Nos. M95298 and M95299 By letter dated March 27, 1998, the NRC transmitted a L

request for additional information related to Sections 1.0, 2.0, 3.0, and 4.0 of the proposed Improved Technical Specifications (ITS) submitted by Duke Energy May 27, 1997. of this letter provides responses to the comments on this section.

Immediately following each staff comment (or group of comments) are changes to the ITS submittal necessary to resolve the staff's comment and supplement the initial ITS submittal.

Changes are denoted by revision bars to facilitate staff review.

1 i

Attachments 5 and 6 of the initial ITS submittal identified changes to the current license which were in addition to changes solely necessary to convert to the improved technical specification format.

Upon discussion with the j

staff, the proposed change to the definition of Dose Equivalent Iodine-131 is being withdrawn from consideration at this time.

The revised pages are provided in Enclosure 2 along with revised Attachments 5 and 6 which include removal of this item and identifies additional beyond scope changes I

included in ITS Supplements 1 and 2.

The pages provided in Enclosures 1 and 2 in this response replace the corresponding pages in the May 27, 1997 submittal, Supplement 1 provided March 9, 1998, and Supplement 2 provided March 20, 1998.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, this response to 9804280017 980420

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S. Nuclear Regulatory Commission April 20, 1998 Page 2 the request for information has been discussed with representatives of the Catawba Plant Operations Review Committee and the Nuclear Safety Review Board and determined to be within the scope of the original review.

Pursuant to 10 CFR 50.91(b) (1), a copy of this amendment has been provided to the appropriate State of South Carolina officials.

If any additional information is needed, please call Lee A.

Keller at 704-382-5826.

Very truly yours,

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• A' -

M.

S. Tuckran Enclosures xc:

w/ enclosures Mr.

L. A.

Reyes Administrator, Region II U.

S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, GA 30303 Mr.

P.

S. Tam U.

S. Nuclear Regulatory Commission Mail Stop O-14 H25 Washington, DC 20555 Mr.

D.

J.

Roberts Senior Resident Inspector Catawba Nuclear Station Max Batavia, Chief Bureau of Radiological Health S.

C.

Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29207 l

4 U.

S. Nuclear Regulatory Commission April 20, 1998 Page 3 M.

S. Tuckman, being duly sworn, states that he is Executive Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission revisions to the Facility Operating Licenses of Catawba Nuclear Station; and that all the statements and matters set forth herein are true and correct

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to the best of his knowledge.

X. S. fik M.

S. Tuckman, Executive Vice President Subscribed and sworn to before me this 20Y day of Mr> Al i 1998 i

L Nota'ry hublic My Commission Expires:

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i ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SECTIONS 1.0, 2.0, 3.0, and 4.0 l

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C Catawba and McGuire Improved TS Review Comments Section 1.0, Use and Application 1.0-01 JFD 5 Definition of Channel Calibration Definition of Channel Operational Test (COT)

Definition of Trip Actuating Device Operational Test (TADOT)

The ITS definitions of Channel Calibration, COT, and TADOT omit " display" from the list ofitems encompassed by these surveillances. Although this is consistent with the CTS definitions, the display should be included. For example, the post-I accident monitoring instrumentation channels are display only; the proposed definitions would not seem to apply to those instruments. Comment: Revise the two definitions to adopt the word " display" consistent with the STS. Also note that the proposed definitions, if accepted, may require other changes in Section 3.3 and associated Bases.

DEC Response:

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i The CTS definition is revised to include required displays within the scope of CHANNEL CALIBRATION. The majority of CTS channels which require a calibration are those that perform trip or actuation functions. For those channels, a display is not required to perform the required function, and the display is not required to be calibrated to meet the requirements for OPERABILITY of the channel. However, CTS 4.3.3.6 requires a calibration of the post accident monitoring channels. These required channels are the display portions of the instrument loop only, therefore, the inclusion of required displays within the ITS definition of CHANNEL CALIBRATION is an administrative clarification consistent with current requirements and practices.

The COT and TADOT demonstrate the functional ability of actuation devices which change state in response to a change in a monitored parameter, e.g.

interlocks, bistables, and or alarms. A display provides indication only information and performs no " actuation" function, therefore, the inclusion of displays within these tests is inappropriate and inconsistent with current technical specifications and current practice. Displays which are required operable by Technical Specifications (e.g. post accident monitoring indicators) are calibrated to ensure their functional ability to display required information.

i The NUREG specifications related to displays or indicators are those associated l

with Post Accident Monitoring and Remote Shutdown. These specifications do not require the performance of a COT. A TADOT is specified by the NUREG for reactor trip breaker indication, but was not adopted by the ITS because it is not part of the current requirements and an indication performs no " actuation" function. Therefore, there are no ITS Bases revisions required by maintaining the current license basis definitions of COT and TADOT.

mc3_cr_1.0 1

April 20,1998