CNS-14-128, License Amendment Request for Changes to Technical Specification 3.3.2, Engineered Safety Feature Actuation System Instrumentation and TS 3.3.5, Loss of Power Diesel Generator Start Instrumentation Resolution of Operable.

License Amendment Request for Changes to Technical Specification 3.3.2, Engineered Safety Feature Actuation System Instrumentation and TS 3.3.5, Loss of Power Diesel Generator Start Instrumentation Resolution of Operable.

ML14330A327
Person / Time
Site:	Catawba
Issue date:	11/24/2014
From:	Henderson K Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-14-128
Download: ML14330A327 (21)

Text

Kelvin Henderson DUKE Vice President ENERGY. Catawba Nuclear Station Duke Energy CNS-14-128 CNOIVP 1 4800 Concord Road York, SC 29745 o: 803.701.4251 November 24, 2014 f: 803.701.3221 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) for Changes to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation" and TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation" Resolution of Operable But Degraded Condition Due to Non-Conservative TS In accordance with the provisions of 10 CFR 50.90, Duke Energy is submitting this LAR for the Renewed Facility Operating Licenses (FOLs) NPF-35 and NPF-52 for Catawba Nuclear Station, Units 1 and 2, respectively. Specifically, Duke Energy requests NRC review and approval to revise the Allowable Value parameter for the TS 3.3.2 Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation" function for Auxiliary Feedwater Loss of Offsite Power (Function 6.d.) and for the TS 3.3.5 Loss of Voltage function in Surveillance Requirement (SR) 3.3.5.2 in order to make this parameter more restrictive. The existing parameter was determined to be non-conservative and this parameter is presently classified as Operable But Degraded in the Catawba Corrective Action Program. In addition, the Nominal Trip Setpoint parameter for this function is being slightly lowered in order to gain additional margin to what is known as a "double sequencing event". Finally, as part of this LAR, applicable footnotes are also being added to the affected TS 3.3.2 function in accordance with TS Task Force Traveler TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions".

The enclosure to this letter provides Duke Energy's evaluation of the LAR which contains a description of the proposed changes, the technical analysis, the determination that this LAR contains No Significant Hazards Consideration, and the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement. Attachment 1 to the enclosure contains marked-up copies of the affected TS pages. The reprinted copies of the affected TS pages will be provided to the NRC prior to issuance of the approved amendments. Attachment 2 to the enclosure contains marked-up copies of the affected TS Bases pages. Attachment 2 is being provided to the NRC for information only, as the changes to the affected TS Bases pages will be made pursuant to Catawba's TS Bases Control Program subsequent to issuance of the approved amendments.

A ct www.duke-energy.com

U.S. Nuclear Regulatory Commission Page 2 November 24, 2014 Duke Energy is requesting that the NRC review and approve this LAR within one year from the date of submittal so that the above Operable But Degraded condition may be resolved. Duke Energy is also requesting a 60-day implementation period in conjunction with this LAR.

Future revision to the Catawba Updated Final Safety Analysis Report (UFSAR) necessary to reflect approval of this LAR will be made in accordance with 10 CFR 50.71(e), with approved exemptions.

In accordance with Duke Energy administrative procedures and the Quality Assurance Program Topical Report, this LAR has been previously reviewed and approved by the Catawba Plant Operations Review Committee.

Pursuant to 10 CFR 50.91, a copy of this LAR has been forwarded to the appropriate State of South Carolina official.

There are no regulatory commitments contained in this letter or its enclosure.

If you have any questions or need additional information on this matter, please contact L.J.

Rudy at (803) 701-3084.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 24, 2014.

Very truly yours, Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Enclosure

U.S. Nuclear Regulatory Commission Page 3 November 24, 2014 xc (with enclosure):

V.M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G.A. Hutto, III Senior Resident Inspector U.S. Nuclear Regulatory Commission Catawba Nuclear Station G.E. Miller (addressee only)

NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 S.E. Jenkins Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

Enclosure LICENSEE EVALUATION

Subject:

License Amendment Request (LAR) for Changes to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation" and TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation" Resolution of Operable But Degraded Condition Due to Non-Conservative TS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

Page 1 of 8

Enclosure LICENSEE EVALUATION 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Duke Energy is submitting this License Amendment Request (LAR) for the Renewed Facility Operating Licenses (FOLs) NPF-35 and NPF-52 for Catawba Nuclear Station, Units 1 and 2, respectively. Specifically, Duke Energy requests NRC review and approval to revise the Allowable Value parameter for the TS 3.3.2 Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation" function for Auxiliary Feedwater Loss of Offsite Power (Function 6.d.) and for the TS 3.3.5 Loss of Voltage function in Surveillance Requirement (SR) 3.3.5.2 in order to make this parameter more restrictive. The existing parameter was determined to be non-conservative and this parameter is presently classified as Operable But Degraded in the Catawba Corrective Action Program. In addition, the Nominal Trip Setpoint parameter for this function is being slightly lowered in order to gain additional margin to what is known as a "double sequencing event". Finally, as part of this LAR, applicable footnotes are also being added to the affected TS 3.3.2 function in accordance with TS Task Force Traveler TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions".

2.0 DETAILED DESCRIPTION The Catawba 4160 Volt AC Essential Auxiliary Power System supplies power to those Class 1 E loads required to safely shut down the unit following a design basis accident. The system is divided into two completely redundant and independent trains, designated A and B, each consisting of one 4160 volt switchgear assembly, three 4160/600 volt transformers, two 600 volt load centers, and associated loads.

Normally each Class 1 E 4160 volt switchgear is powered from its associated non-Class 1 E train of the 6900 Volt AC Normal Auxiliary Power System. Additionally, an alternate source of power to each 4160 volt essential switchgear is provided from the 6900 volt system via two separate and independent 6900/4160 volt transformers. These transformers are shared between units and provide the capability to supply an alternate source of preferred power to each unit's 4160 volt essential switchgear from either unit's 6900 volt system. A key interlock scheme is provided to preclude the possibility of connecting the two units together at either the 6900 volt level or the 4160 volt level.

Each train of the 4160 Volt AC Essential Auxiliary Power System is also provided with a separate and independent emergency diesel generator (DG) to supply the Class 1 E loads required to safely shut down the unit following a design basis accident.

Each of the redundant 4160 volt essential buses is provided with two levels of undervoltage protection to monitor bus voltage. Each level is provided with a separate set of three undervoltage relays which are utilized in a two-out-of-three logic scheme.

The first level of undervoltage relays detect a loss of voltage on the 4160 volt essential bus.

The relay setting calculation calls for the relay to drop out if voltage falls below 3500 volts (84.1% of normal bus voltage) and remains there for approximately 10 cycles. The 10 cycle time delay prevents false DG starting due to power system transients. The voltage setpoint was selected such that relay operation will not be initiated during normal motor starting; however, these relays will detect loss of voltage and initiate action in a time consistent with the accident analysis.

Page 2 of 8

Enclosure The second level provides degraded voltage protection. The relay setting calculation specifies a dropout greater than or equal to 3766 volts (approximately 90.5% of normal bus voltage). This second level employs two time delays: the first (5 seconds) establishes the existence of a sustained degraded voltage condition and provides an annunciator alarm in the control room; the second (10 minutes) permits corrective operator action prior to separating the Class 1E and offsite power systems. The occurrence of a safety injection signal subsequent to the first time delay will immediately separate the Class 1 E and offsite power systems. In the event of a degraded voltage condition, the first time delay may be defeated such that the Class 1E and offsite power systems will be separated immediately upon occurrence of a safety injection signal. This is procedurally controlled and the first time delay feature is restored when the degraded voltage condition is exited.

In 2011, a concern was documented in Catawba's Corrective Action Program associated with the potential for tripping of the 4160 volt loss of voltage relays during a Loss of Coolant Accident (LOCA) loading of the essential buses. This potential condition exists if the LOCA load sequencer were to actuate with a pre-existing degraded voltage condition on the essential buses. This condition could cause the 4160 volt bus voltage to drop below the loss of voltage relay setpoint as loads are being added, and result in what is known as a "double sequencing event". The existing analysis indicated that this event was possible due to the large uncertainty in the loss of voltage relay setpoint calculation. An evaluation of this issue, in combination with industry evaluation of degraded voltage analysis, has led Catawba to conclude that the existing setting for the Allowable Value was non-conservative. A reanalysis of the loss of voltage relay uncertainty calculation was performed and it was determined that the existing value resulted in a larger than necessary tolerance. The revised calculation demonstrated that the loss of voltage setpoint would not be challenged; however, a small margin to the loss of voltage setpoint exists for each unit in the double sequencing event scenario. The loss of voltage relay setpoint uncertainty is the basis for the Allowable Value (i.e., the Allowable Value is determined by taking the Nominal Trip Setpoint and applying the uncertainty) and this revised value results in an Operable But Degraded condition. As documented in the Catawba Corrective Action Program, a change to TS 3.3.2 and TS 3.3.5 is therefore required to revise the Allowable Value. In response to the Operable But Degraded condition, procedural revisions have been made and are currently in place to address this issue pending NRC approval of this LAR.

Description of Proposed TS Changes The following TS changes are being proposed in this LAR. Refer to Attachment 1 of this enclosure.

• In TS 3.3.2, Table 3.3.2-1, Function 6.d., the Allowable Value is changed from 3242 V to 3396 V.

• In TS 3.3.2, Table 3.3.2-1, Function 6.d., the Nominal Trip Setpoint is changed from 3500 V to 3450 V.

• In TS 3.3.2, Table 3.3.2-1, Function 6.d., TSTF-493, Revision 4 footnotes (f) and (g) are added to SR 3.3.2.3 (Trip Actuating Device Operational Test (TADOT)) and SR 3.3.2.9 (Channel Calibration).

" In TS 3.3.5, SR 3.3.5.2, item a., the Allowable Value is changed from 3242 V to 3396 V.

• In TS 3.3.5, SR 3.3.5.2, item a., the Nominal Trip Setpoint is changed from 3500 V to 3450 V.

Page 3 of 8

Enclosure Corresponding TS Bases changes are also being proposed commensurate with the above proposed TS changes. Refer to Attachment 2 of this enclosure.

3.0 TECHNICAL EVALUATION

The concern or condition that could cause tripping the loss of voltage relays involves a LOCA actuation of the DG sequencers with pre-existing 4160 volt essential bus voltage at the degraded voltage lower limit (i.e., the Allowable Value). In this scenario, calculations model that the essential bus voltage could drop to 3563 volts on Unit 1 and to 3557 volts on Unit 2. The loss of voltage Nominal Trip Setpoint is presently 3500 volts and the uncertainty was documented in calculation CNC-1381.05-00-0017, Revision 16, "Class 1E Diesel Protective Relaying and Sequencer Undervoltage Relay Settings". The calculation included an overly conservative application of the calibration dial setting. The loss of voltage relays are calibrated by adjusting and measuring the actual dropout voltage of the relays. The factory calibration dial markings have no effect on the setting of the relays and the corresponding tolerance in the relay instruction book should not have been used in the calculation. Removing this tolerance was the major contributor to reducing the uncertainty for the loss of voltage relays. The revised relay settings calculation (Revision 17) includes new information provided in the latest vendor documentation for the relays and was performed in accordance with ISA-67.04, "Setpoints for Nuclear Safety-Related Instrumentation".

A review of the loss of voltage relay vendor information, ISA 67.04, and the similar uncertainty calculation for the degraded voltage relays (CNC-1 381.05-00-0012, "4160 Volt Essential Auxiliary Power System Switchgear Relay Settings") was performed. Per the vendor instruction book for the loss of voltage relays, using the method of calibration that Catawba uses, the only relay accuracy terms necessary to include are the voltage variation and temperature variation terms. Combining these two terms with the potential transformer (PT) and measuring and test equipment (M&TE) terms resulted in a significantly lower uncertainty. The uncertainty was reduced from 7.4% to 1.6% (i.e., from 258 volts to 56 volts). The current Allowable Value stated in TS 3.3.2 and TS 3.3.5 for the loss of voltage relays is 3500 volts - 258 volts = 3242 volts.

The new Allowable Value (based on the revised relay settings calculation) is 3500 volts - 56 volts = 3444 volts. Therefore, the value currently in TS is non-conservative and was declared Operable But Degraded. Revising the Allowable Value for the loss of voltage relays is required and is the reason for this LAR. This LAR is being tracked in the Catawba Corrective Action Program.

Revisions were performed to the Unit 1 and Unit 2 safety related voltage analysis calculations.

These revisions were performed at the lowest value for the degraded voltage relays. This indicated that the lowest voltage during a LOCA sequence was 3563 volts and 3557 volts for Unit 1 and Unit 2, respectively. Adding the new uncertainty (56 volts) to the existing loss of voltage Nominal Trip Setpoint results in a maximum loss of voltage trip of 3556 volts. Thus, the margin to tripping the loss of voltage relays during a LOCA loading of the essential buses was 7 volts on Unit 1 and 1 volt on Unit 2. Although the current settings meet all required operating conditions, it is desirable to have additional margin to account for any future loading changes.

Since the Allowable Value required a change, it was decided to also revise the Nominal Trip Setpoint to gain this additional margin. Review and evaluation by the Catawba Design Electrical Group and the General Office Electrical Analysis Group determined that a reduction of 50 volts in the loss of voltage Nominal Trip Setpoint would add appropriate margin and also would continue to meet other required loading conditions. A determination was made to lower the loss of voltage Nominal Trip Setpoint to 3450 volts. By lowering the Nominal Trip Setpoint, the uncertainty value is also reduced to 54 volts per calculation CNC-1 381.05-00-0017, Revision Page 4 of 8

Enclosure 17, thus making the Allowable Value 3396 volts. Adding the uncertainty to the new loss of voltage Nominal Trip Setpoint results in a maximum loss of voltage trip of 3504 volts (3450 volts

+ 54 volts = 3504 volts). This will increase the margin to tripping the loss of voltage relays during LOCA loading to 59 volts for Unit 1 and to 53 volts for Unit 2. Revising the Nominal Trip Setpoint for the loss of voltage relays is conservative.

As documented in calculation CNC-1381.05-00-0017, Revision 17, the loss of voltage Nominal Trip Setpoint is selected to be above the 80% rated starting voltage capabilities of the 4160 volt essential motors. The nominal rating of the 4160 volt motors is 4000 volts. 80% of 4000 volts is 3200 volts. The existing loss of voltage Nominal Trip Setpoint is 3500 volts. This was selected for two reasons: 1) the setpoint is > 3200 volts, and 2) the potential transformers feeding the relays have a ratio of 35/1, making the setpoint exactly on the 100 volt fixed tap of the transformer. The revised loss of voltage Nominal Trip Setpoint of 3450 volts is still in the acceptable range and will require a slight adjustment, as the setpoint will no longer be on the fixed tap. Discussion with the General Office Safety Analysis Group verified that this setpoint is not explicitly used in the safety analysis. For events where loss of power is important, the loss of power is assumed to occur at the initiation of the event. A setpoint in the 80% - 90% range will have no significant impact to the safety analyses.

The Catawba Updated Final Safety Analysis Report (UFSAR) states that the setpoint is 3500 volts and is chosen so that relay operation will not be initiated during normal motor starting.

Therefore, as shown above, lowering the loss of voltage Nominal Trip Setpoint to 3450 volts does not adversely affect this statement. A UFSAR revision will be required to incorporate the new setting.

ChanQes Related to TSTF-493 Included in the scope of the proposed changes is the addition of new lettered footnotes applicable to the affected Surveillance Requirements. These footnotes are consistent with TS Task Force Traveler TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions".

The first new lettered footnote requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service.

The second new lettered footnote requires that the as-left setting for the channel be returned to within the as-left tolerance of the Nominal Trip Setpoint. Where a setpoint more conservative than the Nominal Trip Setpoint is used in the plant surveillance procedures, the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the Nominal Trip Setpoint, then the channel shall be declared inoperable. This footnote also requires that the methodologies for calculating the as-left and the as-found tolerances be in the UFSAR.

Page 5 of 8

Enclosure These new footnotes enhance safety by ensuring that unexpected as-found conditions are evaluated prior to returning the channel to service, and ensuring that as-left settings provide sufficient margin for uncertainties. These changes will have no adverse effect on plant safety.

The NRC has previously approved two limited scope applications of TSTF-493 for Catawba as documented in the following amendments:

" Catawba Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Technical Specification Changes to Allow Manual Operation of the CSS (TAC Nos. MD9752 and MD9753), June 28, 2010 (ADAMS Accession Number ML092530088)

• Catawba Nuclear Station, Units 1 and 2, Issuance of Amendments Regarding Replacement of Source Range and Intermediate Range Excore Detection Systems with Equivalent Neutron Monitoring Systems Using Fission Chamber Detectors (TAC Nos. ME1747 and ME1748), August 2, 2010 (ADAMS Accession Number ML101950353)

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements pertaining to this LAR are defined in 10 CFR 50, Appendix A, Criterion 17, "Electric Power Systems" and Criterion 20, "Protection System Functions". This LAR is being submitted in accordance with 10 CFR 50.90.

4.2 Precedent On December 29, 1998, the NRC issued Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety". This administrative letter was issued to address situations where licensees determine that specific values or required actions in TS may not assure safety. When this occurs, licensees are to conduct an evaluation and, if necessary, institute administrative controls to maintain a more restrictive value for a particular parameter or to take a more conservative required action. Following the discovery of the issue described in this LAR, Duke Energy implemented appropriate administrative controls via procedural requirements, performed the necessary analytical work, and developed and submitted this LAR to formally revise the affected TS parameters.

4.3 Significant Hazards Consideration Duke Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Page 6 of 8

Enclosure Duke Energy requests NRC review and approval to revise the Allowable Value parameter for the Technical Specification (TS) 3.3.2 Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation" function for Auxiliary Feedwater Loss of Offsite Power (Function 6.d.) and for the TS 3.3.5 Loss of Voltage function in Surveillance Requirement (SR) 3.3.5.2 in order to make this parameter more restrictive. The existing parameter was determined to be non-conservative and this parameter is presently classified as Operable But Degraded in the Catawba Corrective Action Program. In addition, the Nominal Trip Setpoint parameter for this function is being slightly lowered in order to gain additional margin. Finally, as part of this License Amendment Request (LAR),

applicable footnotes are also being added to the affected TS 3.3.2 function in accordance with TS Task Force Traveler TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions". The more restrictive Allowable Value will preclude the potential for a double sequencing event to occur under the condition of a Loss of Coolant Accident (LOCA) load sequencer actuation with a pre-existing degraded voltage condition on the essential buses.

These proposed changes will not increase the probability of occurrence of any design basis accident since the affected function, in and of itself, cannot initiate an accident. Should a LOCA occur, the proposed changes will ensure that the sequencer operates properly in order to mitigate the consequences of the event.

Appropriate calculations were developed to substantiate the revised TS parameters proposed in this LAR. There will be no impact on the source term or pathways assumed in accidents previously evaluated. No analysis assumptions will be violated and there will be no adverse effects on onsite or offsite doses as the result of an accident. Adoption of the TSTF-493 footnotes for the respective SRs will ensure that the function's channels will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology.

Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendments do not change the methods governing normal plant operation; nor are the methods utilized to respond to plant transients altered. In addition. the proposed changes to the affected TS parameters and the adoption of the TSTF-493 footnotes will not create the potential for any new initiating events or transients to occur in the actual physical plant.

Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Page 7 of 8

Enclosure Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident.

These barriers include the fuel cladding, the reactor coolant system, and the containment system. The proposed changes will assure the acceptable operation of the affected function under all postulated transient and accident conditions. This will ensure that all applicable design and safety limits are satisfied such that the fission product barriers will continue to perform their design functions.

Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.

Based on the preceding discussion, Duke Energy concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.22(b), an evaluation of this LAR has been performed to determine whether or not it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) of the regulations. Implementation of this amendment will have no adverse impact upon the Catawba units; neither will it contribute to any additional quantity or type of effluent being available for adverse environmental impact or personnel exposure.

It has been determined there is:

1. No significant hazards consideration;

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

3. No significant increase in individual or cumulative occupational radiation exposure.

Therefore, these proposed amendments to the Catawba Nuclear Station Renewed FOLs meet the criteria of 10 CFR 51.22(c)(9) for categorical exclusion from an environmental impact statement.

Page 8 of 8

Enclosure ATTACHMENT 1 Marked-Up TS Pages

ESFAS Instrumentation Table 3.3.2-1 (page 4 of 5) 3.3.2 Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER 9

SPECIFIED REQUIRED NOMINAL FUNCTION CONDITIONS SURVEILLANCE ALLOWABLE CHANNELS CONDITIONS TRIP REQUIREMENTS VALUE SETPOINT (2) SG Water 1,2(e),3(e) 4 perSG D SR 3.3.2.1 Level- High S85.6%

SR 3.3.2.2 83.9%

High (P-14) (Unit 1) (Unit 1)

SR 3.3.2.4 .< 78.9%

SR 77.1%

3.3.2.5 (Unit 2)

SIR (Unit 2) 3.3.2.6 SR 3.3.2.9 SR 3.3.2.10 (3) Safety Refer to Function 1 (Safety Injection) for Injection all initiation functions and requirements.

Item 5.b.(1) for Applicable MODES. See (4) Tavg-Low 1,2(e) 4 J SR 3.3.2.1 Ž 561IF SR 3.3.2.5 564°F SR 3.3.2.9 coincident with Refer to Function 8.a (Reactor Trip, P-4)

Reacior Trip, P-4 for all initiation functions and requirements.

(5) Doghouse 3 per train SR 3.3.2.8 WaterLevel - 5 12 Inches 11 inches per SR 3.3.2.9 High High above 577 ft above 577 doghouse SR 3.3.2.12 floor level ftfloor level

6. Auxiliary Feedwater

a. Automatic 1,2,3 Actuation Logic 2 trains H SR 3.3.2.2 NA NA and Actuation SR 3.3.2.4 Relays SR 3.3.2.6

b. SG Water Level 1,2,3 4 per SG D

- Low Low SR 3.3.2.1 ?9% 10.7%

SR 3.3.2.5 SR (IUnit 1) (Unit 1) 3.3.2.9 35.1% 36.8%

SR 3.3.2.10 (IUnit 2)

c. Safety Injection (Unit 2)

Refer to Function I (Safety Injection) for all initiation functions and requirements.

d. Loss of Offsite 1,2,3 3 per bus D SR 3,3.2.9_?,.T Power ý SR 3 .3.2. 9 t+)(1)

SIR 3.3.2;10 5N1 b NADO

e. Trip of all Main 1,2 3 per pump K SR 3.3.2.8 Feedwater NA SR 3.3.2.10 NA Pumps

f. Auxiliary 1,2,3 Feedwater Pump 3 per train M SR 3.3.2.8 A) _Ž9.5 psig A) 10.5 Train A and SR 3.3.2.10 psig Train B Suction Transfer on B) ->5.2 psig B) 6.2 psig Suction (Unit 1) (Unit 1)

Pressure - Low > 5.0 psig 6.0 psig (Unit 2) (Unit 2)

(a) Except when all MFIVs, MFCVs, and associated bypass valves are closed and de-activated (continued) or isolated by a closed manual valve.

Mlgepr IA Catawba Units 1 and 2 3.3,2-16 Amendment Nos. ý

LOP DG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SIR 3.3.5.1 Testing shall consist of voltage sensor relay testing excluding actuation of load shedding diesel start, and time delay times.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2 Perform CHANNEL CALIBRATION with NOMINAL TRIP In accordance with SETPOINT and Allowable Value as follows: the Surveillance Frequency Control

a. Loss of voltage Allowable Value _> 2.. Program Loss of voltage NOMINAL TRIP SETPOINT =

3Lt ST

b. Degraded voltage Allowable Value > 3738 V.

Degraded voltage NOMINAL TRIP SETPOINT =

3766 V.

Amendment Nos.

Catawba Units 1 and 2 3.3.5-2

Enclosure INSERT 1 (f) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(g) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and the as-left tolerances are specified in the UFSAR.

Enclosure ATTACHMENT 2 Marked-Up TS Bases Pages

ESFAS Instrumentation BASES B 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested. for each protection function. In addition, the master relay coil is pulse tested for continuity.

This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils.

The Surveillance Frequency is based on operating experience, equipment plant risk and is controlled under the Surveillance Frequency reliability, and Program. Control S R 3.3.2.3 SR 3.3.2.3 is the performance of a TADOT. This test is Loss of Offsite Power Function. Each Function is tested a check of the up to, and including, the master transfer relay coils.

This test also includes trip devices that provide actuation signals directly to the SSPS. The SR is modified by a Note that excludes of pumps and valves to minimize plant upsets that would final actuation occur. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.4 SR 3.3.2.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity.

The time allowed for the testing (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) is justified in Reference 7. The Surveillance Frequency is based on.operating experience, equipment plant risk and is controlled under the Surveillance reliability, and Frequency Control Program.

S R 3.3.2.5 SR 3.3.2.5 is the performance of a COT.

A COT is performed on each required channel to ensure the channel will perform the intended Function. The tested portion of the loop must trip within the Allowable Values specified in Table 3.3.2-1.

Catawba Units I and 2 B 3.3.2-43 Revision No.

LOP DG Start Instrumentation B 3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation BASES BACKGROUND The DGs provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit operation.

Undervoltage protection will generate an LOP start if a loss of voltage or degraded voltage condition occurs at the 4.16 kV switchgear. There are two LOP start signals, one for each 4.16 kV vital bus.

Each of the redundant 4160V essential buses is provided with two levels of undervoltage protection to monitor bus voltage. Each level is provided with a separate set of three under voltage relays which are utilized in a two-out-of-three logic scheme.

The first level of undervoltage relays detect a loss of voltage on the 4160V AC essential bus. The relays are set to drop out if voltage falls Q'L be Io-w (./o of normal bus voltage) and remains there for approximately_0 cycles. The 10 cycle time delay prevents false diesel starting due to power system transients. The voltage setpoint was selected such that relay operation will not be initiated during normal motor starting; however, these relays will detect loss of voltage and initiate action in a time consistent with the accident analysis.

The second level provides degraded voltage protection. The relays are set to drop out at greater than or equal to 3766V (approximately 90.5% of normal bus voltage). This second level employs two time delays: the first (5 seconds) establishes the existence of a sustained degraded voltage condition and provides an annunciator alarm in the control room; the second (10 minutes) permits corrective operator action prior to separating the Class 1 E and offsite power systems. The occurrence of a safety injection signal subsequent to the first time delay will immediately separate the Class .1E and offsite power systems.

The LOP start actuation is described in UFSAR, Section 8.3 (Ref. 1).

p Catawba Units 1 and 2 B 3.3.5-1 Revision No.0*

LOP DG Start Instrumentation BASES B 3.3.5

)ACTIONS (continued)

B. 1 Condition B applies when more than one loss of voltage or more than one degraded voltage channel on a single bus is inoperable.

Required Action B.1 requires restoring all but one channel to OPERABLE status. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time should allow ample most failures and takes into account the low probability time to repair of an event requiring an LOP start occurring during this interval.

C.1 Condition C applies to each of the LOP DG start Functions when the Required Action and associated Completion Time for Condition A or B are not met.

In these circumstances the Conditions specified in LCO 3.8.1, "AC Sources-Operating," or LCO 3.8.2, "AC Sources-Shutdown,"

DG made inoperable by failure of the LOP DG for the start instrumentation are required to be entered immediately. The actions of those LCOs provide for adequate compensatory actions to assure unit safety.

SURVEILLANCE SR 3.3.5.1 REQUIREMENTS SR 3.3.5.1 is the performance of a TADOT.

The test checks trip devices that provide actuation signals directly, bypassing the'analog process control equipment. For these tests, the relay Trip Setpoints are verified and adjusted as necessary-,^The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Testing consists of voltage sensor relay testing only. Actuation of load shedding and time delay timers is not required.

Catawba Units 1 and 2 B 3.3.5-5 Revision No.(*)ý

LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.2 SR 3.3.5.2 is the performance of a CHANNEL CALIBRATION.

The setpoints, as well as the response to a loss of voltage and a degraded voltage test, shall include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

IA'SEkT P, The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 8.3.

2. UFSAR, Chapter 15.

3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

Catawba Units 1 and 2 B 3.3.5-6 Revision No.(0

Enclosure INSERT 1 For Functions for which TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions" has been implemented, this SR is modified by two Notes as identified in Table 3.3.2-

1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program.

Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NOMINAL TRIP SETPOINT (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in the UFSAR.

INSERT 2 There is a plant specific program which verifies that the instrument channel functions as required by verifying the as-left and as-found setting are consistent with those established by the setpoint methodology.