Text

Proposed Technical Specifications and Bases Amendment, TS and Bases Administrative Changes
	ML082880098
Person / Time
Site:	Catawba
Issue date:	10/08/2008
From:	Morris J; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML082880098 (55)
	v • d • e

Duke JAMES R. MORRIS, VICE PRESIDENT fEnergy. Duke Energy Carolinas,LLC Carolinas Catawba Nuclear Station 4800 Concord Road! CN01 VP York, SC 29745 803-701-4251 803-701-3221 fax October 8, 2008 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Proposed Technical Specifications (TS) and Bases Amendment TS and Bases Administrative changes Pursuant to 10 CFR 50.90, Duke is requesting amendments to the-Catawba Facility Operating Licenses and TS. This request modifies the subject TS and Bases by changing several portions which are out of date, as there are obsolete footnotes and outdated references.

The contents of this amendment request package are as

.follows:

Attachment 1 provides the technical and regulatory evaluations of the proposed changes. Attachment 2 contains a marked-up version of the affected TS and Bases pages.

Reprinted (clean) TS and Bases pages will be provided to the NRC prior to issuance of the approved amendments. This amendment request contains no NRC commitments as discussed in Attachment 3.

Duke requests NRC approval of these proposed changes as soon as reasonably possible.

Duke is requesting a 30-day implementation period in

conjunction with these amendments. Implementation of the approved amendments will not require changes to the Catawba Updated Final Safety Analysis Report (UFSAR).

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, these proposed amendments have been reviewed and approved by the Catawba www.duke-energy.comr

U.S. Nuclear Regulatory Commission Page 2 October 8, 2008 Plant Operations Review Committee and by the Corporate Nuclear Safety Review Board.

Pursuant to 10 CFR 50.91, a copy of these proposed amendments is being sent to the designated official of the State of South Carolina.

Inquiries on this matter should be directed to M.J. Sawicki at (803) 701-5191.

Very truly yours, James R. Morris Attachments

U.S. Nuclear Regulatory Commission Page 3 October 8, 2008 James R. Morris affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

James ris, Vice President Subscribed and sworn to me: 16A Date

/3 /

Notary P& ic My commission expires:

. Z-014 Dat S.40 NO0TARY pUBIC %

'AY COMMWISSIONv FX ~ ,

JUO A4 Ol.SOMT GO~

U.S. Nuclear Regulatory Commission Page 4 October 8, 2008 xc (with attachments):

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

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

NRC Senior Project Manager (CNS)

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

Columbia, SC 29201

U.S. Nuclear Regulatory Commission Page 5 October 8, 2008 bxc (with attachments):

R.D. Hart (CN01RC)

M.J. Sawicki (CN01RC)

R.L. Gill, Jr. (EC05O)

NCMPA-1 NCEMC PMPA SREC Document Control File 801.01 RGC File ELL-EC050

ATTACHMENT 1 TECHNICAL AND'REGULATORY EVALUATIONS Attachment 1, Page 1

Subject:

Application for License Amendment for Administrative Changes

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES Attachment 1, Page 2

1.

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating Licenses NFP-35 (Catawba Nuclear Station Unit- 1) and NFP-52 (Catawba Nuclear Station Unit 2).

Catawba proposes to delete all out-dated, obsolete, and unwarranted data from TS and TS Bases with this license amendment request. Most of these data revisions are due to changes within our organization, or else due to emergency TS changes which have since expired. There are also several pages in both TS and bases which require revision due to the diesel generator battery modification from the nickel cadmium type to the lead acid variety. This changealso corrects editorial errors associated with the conversion to Standard TS in two such instances in Appendix B of both the Unit 1 and Unit 2 FOL. The final type of change comes from an inconsistency which was found in TS 5.6.5, which should not make reference to TS 3.9.2 for it is unnecessary.

Duke requests that theNRC approve the proposed amendments based on the improvements to maintaining the TS as current and up-to-date as possible/which shall result from the administrativecleanup.

Attachment 1, Page 3

2. DETAILED DESCRIPTION The following is a description for the identification of each Technical Specification change page, as well as the justification as to why it is to be made.

Facility Operating License, Catawba Unit 1, Appendix B, "Additional Conditions", Amendment #159, which incorrectly cites TS Section 3.4.8.a (should be replaced with TS Section 3.4.16.a) and Figure 3.4-1 (to be replaced with Figure 3.4.16-1).

Facility Operating License, Catawba Unit 2, Appendix B, "Additional Conditions", Amendment #151, which incorrectly cites TS Section 3.4.8.a (should be replaced with TS Section 3.4.16.a) and Figure 3.4-1 (to be replaced with Figure 3.4.16-1).

3.5.2 ECCS- Operating, page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired January 10, 2008.

3.6.6 Containment Spray System, page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.6.9 Hydrogen Ignition System (HIS), page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6-9 Hydrogen Ignition System, page 2 Surveillance Requirements, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6.17 Containment Valve Injection Water Systems (CVIWS),

page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.7.5 Auxiliary Feedwater (AFW) System, page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.7.7 Component Cooling Water (CCW) System, page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

Attachment 1, Page 4

3.7.10 Control Room Area Ventilation System (CRAVS), page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.7.12 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES), page 1, which containsan obsolete emergency Tech Spec Change as a note on the bottom of the page which expired January 10, 2008.

3.8.1 AC Sources-Operating, page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.8.1 AC Sources-Operating, page 3, Actions, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired December 31, 2006.

3.8.4 DC Sources-Operating, page 2 Surveillance Requirements, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.4 DC Sources-Operating, page 3 Surveillance Requirements, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters-, page 1, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 2 Actions, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented. in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 3 Actions(continued),

which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

Attachment 1, Page 5

3.8.6 Battery.Cell Parameters, page 4 Surveillance Requirements, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

5.2 Organization, section 5.2.1 "Onsite and Offsite Organizations", which contains the organizational title change from "Executive Vice President Nuclear Generation Department" to "Chief Nuclear Officer."

5.6 Reporting Requirements, section 5.6.5 "CORE OPERATING LIMITS REPORT (COLR)", which is deleting the error of having Tech Spec 3.9.2 referenced.

Appropriate changes are also being proposed to the TS Bases for this function, consistent with the above proposed TS changes.

Bases 3.6.9 Hydrogen Ignition Systems (HIS), page 1, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6.9 Hydrogen Ignition Systems (HIS), page 2, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6.9 Hydrogen Ignition Systems (HIS), page 3, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6.9 Hydrogen Ignition Systems (HIS), page 4, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.6.9 Hydrogen Ignition Systems (HIS), page 5, which contains an obsolete one-time Tech Spec Change as a note on the bottom of the page which expired with Unit 2 entry into Mode 5 following Cycle 11.

3.8.4 DC Sources-Operating, page 5, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Attachment 1, Page 6

Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004. N 3.8.4 DC Sources-Operating, page 6, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.4 DC Sources-Operating, page 7, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.4 DC Sources-Operating, page 8, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery notbeing used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 1, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 2, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 3, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

3.8.6 Battery Cell Parameters, page 4, which contains obsolete information in regard to the Diesel Generator Nickel Cadmium Battery not being used after being replaced with Lead Acid Batteries, as documented in the license amendment request dated July 19, 2004.

Attachment 1, Page 7

3. TECHNICAL EVALUATION A technical evaluation is unnecessary as this license amendment request only contains administrative changes. Due to the non-technical nature of these changes a review is not required.

Attachment 1, Page 8

4. REGULATORY EVALUATION Duke has evaluated whether or not a significant hazard consideration is involved with the proposed changes by analyzing the three standards set forth in 10 CFR 50.92(c) as discussed below:

Criterion 1:

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

Response: No.

The proposed changes are administrative in nature and therefore they do not involve any change in the design, configuration, or operation of the nuclear units. All Limiting Conditions for Operation, Limiting Safety System Settings and Safety Limits specified in the Technical Specifications remain unchanged. The Physical Security and related plans, Operator Training and Requalification Programs, Quality Assurance Programs, and the Emergency Plans will not be materially changed by the proposed license amendment due to its administrative nature.

The technical qualifications of the operating licensee will not be reduced. Personnel engaged in operation, maintenance, engineering, assessment, training, and other related services will not be changed. Duke officers and executives currently responsible for the overall safe operation of the nuclear plants are expected to continue in the same capacity.

Therefore, the proposed amendment does not involve an increase in the probability or consequences of an accident previously analyzed.

Criterion 2:

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

Response: No.

Attachment 1, Page 9

The proposed changes are administrative in nature and therefore they do not involve any change in the design, configuration, or operation of the nuclear plant. The current plant safety analyses, therefore, remain complete and accurate in addressing the design basis events and in analyzing plant response and consequences.

The Limiting Conditions for Operations, Limiting Safety System Settings and Safety Limits specified in the Technical Specifications are not affected by the proposed changes. As such, the plant conditions for which the design basis accident analyses were performed remain valid.

The amendment does not introduce a new. mode of plant operation or new accident precursors, does not involve any physical alterations to plant configurations or make changes to system set points that could initiate a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility Of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

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

Response: No.

The proposed changes are administrative in nature and therefore they do not involve a change in the design, configuration, or operation of the nuclear plants. The change does not affect either the way in-which the plant, structures, systems, and components perform their safety function or their design and licensing bases.

Plant safety margins are established through Limiting Conditions for Operation, Limiting Safety System Settings and Safety Limits specified in the Technical Specifications.

Because there is no change to the physical design of the plant, there is no change to any of these margins.

Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

Attachment 1, Page 10

4.4 Conclusions Due to the nature of administrative changes, all discussions relating to accidents and safety marginsare not applicable in this case. Therefore 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.

Attachment 1, Page 11

5. ENVIRONMENTAL CONSIDERATION The requested conforming license amendment is exempt from environmental review because this action falls within the categorical exclusion contained in 10 CFR 51.22 (c) (2), for which neither an Environmental Assessment nor an Environmental Impact Statement is required. Moreover, the license amendment will not directly affect the actual operation of Catawba Nuclear Station in any substantive way.

The proposed administrative change does not involve an increase in the amounts, or a change in the types of any radiological effluents that may be allowed to be released off-site, and it does not involve an increase in the amounts, or change in the types of non-radiological effluents that may be released off-site. Furthermore, there is no increase in the individual or cumulative operational radiation exposure and the proposed transfer has no environmental impact. Accordingly, pursuant to .10 CFR 51.21, 51.32, and 51.35, a finding of no significant environmental impact can be concluded.

Attachment 1, Page 12

6. REFERENCES

1. Catawba Nuclear Station Technical Specifications, Units 1 and 2, through Amendments 243/237.

Attachment 1, Page 13

ATTACHMENT 2 MARKED-UP TS AND BASES PAGES Attachment 2, Page 1

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

Amendment Implementation Number Additional Condition Date 159 This amendment requires the licensee to use Immediately administrative controls, as described in the upon issuance licensee's letter of March 7, 1997, and of the evaluated in the staffs safety amendment evaluation dated April 29, 1997, to restrict the dose-equivalent iodine levels to 0.46 microCurie per gram (in lieu of the limit in TS Secre, andto 26 microCurie per C J gram (in lieu of the limit of TS Figure 31-),

until this license condition is removed by a future amendment.

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

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

Renewed License No. NPF-35 Amendment No. 229

-I-

APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-52 Duke Energy Carolinas, LLC shall comply with the following conditions on the schedules noted below:

Amendment Implementation Number Additional Condition Date 151 This amendment requires the licensee to use Immediately administrative controls, as described in the upon issuance licensee's letter of March 7, 1997, and of the evaluated in the staffs safety amendment.

evaluation dated April 29, 1997, to restrict the dose-equivalent iodine levels to 0.46 microCurie per gram (in lieu of the limit in TS Section 3-4.-.), and to 26 microCurie per w gram (in lieu of the limit of TS Figure.44--1 -,

until this license condition is removed by a 3,'-/d -/

future amendment.

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

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

Renewed License No. NPF-52 Amendment No. 2 3 5 ECCS - Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS-- Operating LCO 3.5.2 Two ECCS trains shall be OPERABLLO APPLICABILITY: MODES 1, 2, and 3.

NOTE --------------------------------------------

In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 3.4.14.1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains inoperable.

A.1 Restore train(s) to OPERABLE status.

72 houro\~ t I AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.

B. Required Action and B.1 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 B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

[ýJ&

For Unit 1 only, the Completion Time that the 1B ECCS train can be inoperable as specified by Required Action A. 1 may be extended beyond the "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " up to a total of 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months as part of the 1B centrif ugal charging pump repair. Upon completion of the repair and restoration, this footnote is no longer applicable Catawba Units 1 and 2 3.5.2-1 Amendment Nos( Z32J"

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System e 44e LCO 3.6.6 Two containment spray trains shall be OPERABL I APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION. COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hour0-. t[>efkc i train inoperable. train to OPERABLE status.

B. Required Action and B.1 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 B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power operated, 31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

(continued)

For each Unit, the Completion Time that one Containment Spray System train can be inoperable as specified by Required Action A.1 may be extended beyond the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months up to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system upgrades. System upgrades include maintenance activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or replacement. Upon completion of the system upgrades and system restoration, this footnote is no longer applicable and ifnot used, will expire at midnight on December 31 200 . .. ......... ...... ....

Catawba Units 1 and 2 3.6.6-1 Amendment Nos (228;/ýI23)

HIS 3.6.9 3.6 CONTAINMENT SYSTEMS 3.6.9 Hydrogen Ignition System (HIS)

LCO 3.6.9 Two HIS trains shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One HIS train A.1 Restore HIS train to 7 days inoperable.0 OPERABLE status.

OR A.2 Perform SR 3.6.9.1 on the Once per 7 days OPERABLE train.

B. One containment region B.1 Restore one hydrogen 7 days with no OPERABLE ignitor in the affected hydrogen ignitorEý containment region to

-[ e. OPERABLE status.

C. Required Action and C.1 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.

Fo nt2 yl 1 operation only, or until the next Unit 2 entry into MODE 5 which allows' (hedmyb

!affected ig nito r nreplaemeewtt heatchetrqain'is igni tor l~oatthdsbeneath thohe reactor ves sel m issiley Catawba Units 1 and 2 3.6.9-1 Amendment Nos.(!PK7ýj

HIS 3.6.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.9.1 Energize each HIS train power supply breaker and verify 92 days

> 34 (Unit 1) or 39(Unit 2) ignitors are energized in each train. I SIR 3.6.9.2 Verify at least one hydrogen i nitor is OPERABLE in each 92 days containment regior. 0060-=. I SR 3.6.9.3 Energize each hydrogen ignitor and verify temperature is 18 months

> 17OOoF bt .

IFor Unit 2 Cycle 11 operation only, or until the next Unit 2 entry. into MODE 5 which allows missile shield.

eator vesselctrvs f affected ignitor replacement, this SR is not applicable to each train's ignitor located beneath the Catawba Units 1 and 2 3.6.9-2 Amendmwt INOS -(I j7;?78ý

CVIWS 3.6.17 3.6 CONTAINMENT SYSTEMS 3.6.17 Containment Valve Injection Water System (CVIWS)

LCO 3.6.17 Two CVIWS trains shall be OPERABLEr.*'A I APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Restore CVIWS train to 7 day'r-t*

A. One CVIWS train inoperable.

A.1 OPERABLE status.

I B. Required Action and B.1 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 B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.17.1 Verify system surge tanks pressure is > 36.4 psig. 31 days SR 3.6.17.2 Verify valve injection flow rate is < 1.29 gpm (Unit 1) 18 months

< 1.21 gpm (Unit 2) for Train A and < 1.16 gpm for Train B with a surge tank pressure > 36.4 psig.

SR 3.6.17.3 Verify each automatic valve actuates to its correct 18 months position on an actual or simulated actuation signal.Le,7ýAfee For each Unit, the Completion Time that one CVIWS train can be inoperable as specified by Required Action A.1 may be extended beyond the 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months up to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system upgrades. System upgrades Include maintenance activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or

ýeplacement. Upon Pompletion of the systern upgrades and system restoration, this.footnote is no longer applicable and-Knot, used-, will expire at midnight on -December3-1, 2-0-0 Catawba Units 1.and 2 3.6.17-1 Amendment Nos 22 3

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System BLIer-W 41 LCO 3.7.5 Three AFW trains shall be OPERA

--------------- ....---------- NOTE --.. .....---------------......----- w.-....- ---

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

. . .. .. ... . .. ... ..-.. . . . .. l '*

i-..____-------- ------------ - ---------------- - ----- --------

LCO 3.0.4.b is not applicable when entering MODE 1.

CONDITION REQUIRED ACTION COMPLETION TIME A. One steam supply to A.1 Restore steam supply to 7 days turbine driven AFW OPERABLE status.

pump inoperable. AND 10 days from discovery of failure to meet the LCO B. One AFW train B. 1 Restore AFW train to 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months "\

inoperable in MODE 1, 2 OPERABLE status.

or 3 for reasons other AND Dtt than Condition A. 10 dayl"m discovery of failure to meet the LCO (continued)

S*For each Unit, the Completion Time that one AFW train can be inoo~erable as specified by Required "

{Action B.1I may be extended beyond the "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days from discovery of failure to meet the LCO" Sup to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system upgrades. System upgrades include maintenance activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or replacement. Uponj completion of the system. upgrades and system restoration, this footnote is no longer applicable and i o U

Used, Will ekpire at midnight on December 31, 2006.

Catawba Units 1 and 2 3.7.5-1 Amendment Nos.(*Pt~*23)

CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABL I APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train A.1 -NOTE N.E.... .....

inoperable. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4,"

for residual heat removal loops made inoperable by CCW.

Restore CCW train to 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ? l- I OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met, B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

For each Unit, the Completion Time that one COW train can be inoperable as specified by Reýquired Action A.1 may be extended beyond the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months up to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system upgrades.

System upgrades include maintenance activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or replacement. Upon completion of the system upgrades and system

restoration, this footnote is no longer applicable and if not used, will expire at midnight on December 31, 2006.

C.atawba-Units-1 and 2

...-........... -r" 317.7 W*ndrý.e_h t- N6 S."(20

CRAVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Area Ventilation System (CRAVS)

LCO 3.7.10 Two CRAVS trains shall be OPERABLE I NOTE ---------.. ....................

The control room pressure boundary may be opened intermittently under administrative controls.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRAVS train A.1 Restore CRAVS train to 7 dayer-c ei I inoperable in MODES OPERABLE status.

1,2,3,4,5, and 6.

B. Two CRAVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to pressure boundary to inoperable control room OPERABLE status.

pressure boundary in MODES 1, 2, 3, or 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

associated Completion.

Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

______________________ ~(~e.(continued)

For each CRAVS train, the Completion Time that one CRAVS train can be inoperable as specified by Required Action A.1 may be extended beyond the 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months up to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system upgrades. System upgrades include maintenance- activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or replacement. Upon completion of the system upgrades and system restoration, this footnote is no longer applicable and ifnot used, will expire at midnight on December 31, 2006.

Catawba Units 1 and 2 3.7.10-1 Amendment tNos. 2 3

ABFVES 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)

LCO 3.7.12 Two ABFVES trains shall be OPERABL* /eh

NOTE --------------------------------------------------

The ECCS pump rooms pressure boundary may be opened intermittently under administrative controls.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ABFVES train A.1 Restore ABFVES train to 7 days inoperable. OPERABLE status.

B. Two ABFVES trains B.1 Restore ECCS pump 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - ie

'le inoperable due to rooms pressure boundary inoperable ECCS pump to OPERABLE status.

rooms pressure boundary.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. One or more ABFVES D.1 Restore ABFVES train(s) 7 days train(s) heater heater to OPERABLE inoperable, status.

OR D.2 Initiate action in 7 days accordance with Specification 5.6.6. aT'.e-k Fc Unit 1 onl1y, the Compleion Time thttwo ABVStrains can be inoperaT-fr~-+rerable EOCS

!0r pmp rooms pressure boundary as specified by Required Action B.1 may be extended beyond the "24 hurs" up to a total of 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months as part of the 1B centrifugal charging pump repair. Upon completion of te8.repair and restoration,_lan2 this footnote is no l37121onger applicable and will expire mnmuiat 0130 on Januaryii *10, -

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3 R 1* AC V*Vf WI* Sources-Conprting

l VVV LCO 3.8. i The following AC electrical sources shallbe OPERABL

a. Two qualified circuits between the offsite transmission network and the Onsite Essential Auxiliary Power System; and

b. Two diesel generators (DGs) capable of supplying the Onsite Essential Auxiliary Power Systems; AND The automatic load sequencers for Train A and Train B shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS k 1f*T*r-UIr I I -----------------------------------------------------

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE offsite circuit.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no available inoperable when offsite power to one its redundant required train concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

. . .. . .. AN_ _

(continued)

/f*Foreach Unit, the completion Time. that one EDG can be inoperable as specified by Required Action e.4 may be extended **

[ beyond the "72hours and 6 days from discovery of failure to meet the LCO" up to 336 hours0.00389 days 0.0933 hours 5.555556e-4 weeks 1.27848e-4 months as part of the NSWS system

, upgrades. System upgrades include maintenance activities associated with cleaning of NSWS piping-, weld coating, and necessary

,repairs and/or replacement. Upon completion of the system upgrades and system restoration, this footnote Is no longer applicable C.*and 7Ifnot used, Will expire at 7midnight on Decembe~r 3_1,2006. _ . *".,,'

Catawba Units 1 and 2 8.8.1-1 Amendment Wos. f'2*/'2

AC Sources - Operating 3.8.1 ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B..4 Restore DG to OPERABLE 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , status.

AND 3.Teflej 6 day rom discovery of failure to meet LCO C. Two offsite circuits C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable, inoperable when its discovery of redundant required Condition C feature(s) is inoperable, concurrent with inoperability of redundant required features AND C.2 Restore one offsite circuit 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to OPERABLE status.

(continued)

For each Unit, the Completion Time that one ED G can be inoperable as specified by Required Action BB.44 may be extended beyond the "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 days from discovery of failure to meet the LCO" up to336 hours as part of the NSWS system upgrades. System upgrades include maintenance activities associated with cleaning of NSWS piping; weld coating, and necessary repairs and/or replacement. Upon completion of the system upgrades and system restoration, this foot.note is no longer applicable and If not used, will expire at midnight on December 31, 2006.

Catawba Units 1 and 2 3.8.1-3 Amendment Nos

DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. A and/or D channel of D.1 Enter applicable Immediately DC electrical power Condition(s) and Required subsystem inoperable. Action(s) of LCO 3.8.9, "Distribution Systems-AND Operating", for the associated train of DC Associated train of DG electrical power distribution DC electrical power subsystem made subsystem inoperable, inoperable.

SURVEILLANCE REQUIREMENTS.

SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify DC channel and DG battery terminal voltage is 7 days

> 125 V on float charge.'*

SR 3.8.4.2 Verify nickel cadmiu battery cell volt e > 1.36 V on flo charge.

SR 3.8.4.3 Verify no visible corrosion at the DC channel and DG 92 days battery terminals and connectors.

OR (Fo he DC *annel ar DG bat ries utili ing lead cid c o erify battery connection resis ance of these items is < 1.5 E-4 ohm.

(continued)

Catawba Units 1 and 2 3.8.4-2 Amendment Nos. ez4

II DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Verify DC channel and DG battery cells, cell plates, and 18 months racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

SR 3.8.4.5 Remove visible terminal corrosion, verify DC channel and 18 months DG battery cell to cell and terminal connections are clean and tight, and are coated with anti-corrosion material.

SR 3.8.4.6 Verify DC channel and DGa attery connection 18 months I resistance is < 1.5 E-4 ohm.

SR 3.8.4.7 Verify each DC channel battery charger supplies 18 months

> 200 amps and the DG battery charger supplies > 75 amps with each charger at > 125 V for > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SR 3.8.4.8 ----------------- NOTES.------

1. The modified performance discharge test in SR 3.8.4.9 may be performed in lieu of the service test in SR 3.8.4.8.

2. This Surveillance shall not be performed for the DG batteries in MODE 1, 2, 3, or 4.

Verify DC channel and DG battery capacity is adequate 18 months to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

(continued)

Catawba Units I and 2 3.8.4-3 Amendment Nos. Ezb

Battery Cell Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Parameters LCO 3.8.6 a. Battery cell parameters for the channels of DC batteries shall be within the limits of Table 3.8.6-1;

b. Battery cell parameters for the Diesel Generator (DG) Train A and Train B batteries bottcrccs utilizing lead acid cGlls shall be within the limits of Table 3.8.6-1;1-a44-G. Sattor-' co1l paramoetor. for the DG TinAnd Traion B batter APPLICABILITY: When associated DC electrical power subsystems are requiredto be OPERABLE.

Catawba-Units 1 and 2 3.8.6-1 Amendment Nos.

.9 .*

Battery Cell Parameters 3.8.6 ACTIONS Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A.1 Verify pilot cells electrolyte 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (channel(s) of DC level and float voltage batteries, DG batteries meet Table 3.8.6-1 lead cid-ls* Category C limits.

or toth) with one or more battery cell AND parameters not within Category A or B limits. A.2 Verify battery cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months parameters meet Table 3.8.6-1 Category C AND limits.

Once per 7 days thereafter AND A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1.

(continued)

Catawba Units 1 and 2 3.8.6-2 Amendment Nos. 60ý)

Battery Cell Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A not met. AND OR B.2 ---.-.------ NOTE -------------

Only applicable for One or more batteries inoperable DG batteries.

(channel(s) of DC batteries, DG batteries, or both) with average Enter applicable Immediately electrolyte temperature. Condition(s) and Required of the representative Action(s) of LCO 3.8.1, cells < 60°F. "AC Sources - Operating",

or LCO 3.8.2, "AC Sources OR - Shutdown" for the associated DG made One or more batteries inoperable.

(channel(s) of DC b ies, G beries Curg ýnle*ýacid el or both) with one or

-more battery cell parameters not within Category C values.

C.

neo mreGC. 1 En r applicable ~ iI batteries util ing nickel C ndition(s) and equired cadmium c Ils with electrolyt level not .at,-or ction(s) of LC 3.8.1, "AC'Sources - perating" I

abovet lowtmark n orLCO3.8.2 "ACSourc s not at below the hi - Shutdown"For the mark. f associated G made inoperabl batteries utili g nick.

cadmium s with w t or more c, nected lls

< 1.36 V/

Catawba Units I and 2 3.8.6-3 Amendment NosE.1

t, . :

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cearameters of the channels of DC and 7 days DG batteriesuiling acid ellseet Table 3.8.6-1 Category A limits.

SR 3.8.6.2 /Verify cadmi CýD j'kif D high n SR 3.8.6.3 e of he channels of DC and Verify battery cell arametes 92 days DG batteries zi eadacid cItsmeet Table 3.8.6-1 I Category B limi s. AND Once within 7 days after a battery discharge

<110 V AND Once within 7 days after a battery overcharge

> 150V SR 3.8.6.4 Verify average electrolyte temperature for the channels 92 days of DC and DG batteries of representative cells is > 60°F.

Catawba Units 1 and 2 3.8.6-4 Amendment Nos.@Z )

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the UFSAR;

b. The Station Manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;

c. The Vice President of Catawba Nuclear Site shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.-

d. Theq cutiyý Vi Pre ' ent N le Gen ,tioDe rtn)e will be the Senior Nuclear Executive and have corporate responsibility for overall nuclear safety; and

e. The individuals who train the operating staff, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager, however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

5.2.2 Unit Staff The unit staff organization shall include the following:

a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed .operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.

A total of three non-licensed operators are required for the two units.

(continued)

Catawba Units 1 and 2 5.2-1 Amendment No<17 65

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.4 Not used. I 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1. Illustration of Reactor Core Safety Limits for Specification 2.1.1,

2. Moderator Temperature Coefficient BOL and EOL limits and 60 ppm and 300 ppm surveillance limits for Specification 3.1.3,

3. Shutdown Bank Insertion Limit for Specification 3.1.5,

4. Control Bank Insertion Limits for Specification 3.1.6,

5. Axial Flux Difference limits for Specification 3.2.3,

6. Heat Flux Hot Channel Factor for Specification 3.2. 1,

7. Nuclear Enthalpy Rise Hot Channel Factor for Specification 3.2.2,

8. Overtemperature and Overpower Delta T setpoint parameter values for Specification 3.3.1,

9. Reactor Coolant System Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits for Specification 3.4.1,

10. Accumulator and Refueling Water Storage Tank boron

.concentration limits for Specification 3.5.1 and 3.5.4, "11. Reactor Coolant System and refueling canal boron concentration limits. for Specification 3.9.1,

12. Spent fuel pool boron concentration limits for Specification 3.7.15,

13. SHUTDOWN MARGIN for Specification 3.1.1,

.14. 31 EFPD Surveillance Penalty Factors for Specifications 3.2.1 and 3.2.2, and 15.. Reactor Makeup Water _umps Combined Flow Rates limit for Specification/ 3.3.9#3j (continued)

Catawba Units 1 and 2 5.6-2 Amendratent Nos

HIS B 3.6.9 B 3.6 CONTAINMENT SYSTEMS B 3.6.9 Hydrogen Ignition System (HIS)

BASES BACKGROUND The HIS reduces the potential for breach of primary containment due to a

-hydrogen oxygen reaction in post accident environments. The HIS is required by 10 CFR 50.44, "Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors" (Ref. 1), and Appendix A, GDC 41, "ContainmentAtmosphere Cleanup" (Ref. 2), to reduce the hydrogen. concentration in the primary containment following a degraded core accident. The HIS must be capable of handling an amount of hydrogen equivalent to that generated from a metal water reaction involving 75% of the fuel cladding surrounding the active fuel region (excluding the plenum volume).

10 CFR 50.44 (Ref. 1) requires units with ice condenser containments to install suitable hydrogen control systems that would accommodate an amount of hydrogen equivalentto that generated from the reaction of 75%

of the fuel cladding. with water. Thee.IiIS providesthis required capability.

This requirement was placed on ice-condenser units because of their.

small containment volume and low design pressure (compared with pressurized water reactor dry containments). Calculations indicate that if hydrogen equivalent to that generatedfrom the reaction of 75% of the fuel cladding with water were to collect in the primary containment, the resulting hydrogen concentration would be far above the lower flammability limit such that,: if ignited from a random ignition source, the resulting hydrogen burn Would seriously challenge the containment and safety systems in the containment.

The HIS is based on the concept of controlled ignition using thermal ignitors, designed to be capable of functioning in a post accident environment, seismicall supported, and capable of actuation from the 7u*. - .control room.A total f4tignitors are distributed throughout the various I regions of containment in which hydrogen could be released or to which it could flow in significant quantities. The ignitors are arranged in two ndent trains such that each .containment region has at least two igniit*one from each train,- controlled and powered redundantly so that I ignition would occur in each region even if one train failed to energize.

During Unit 2 Cycle. 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected ignitor replacement, each train's ignitor located beneath the reactor vessel missile ield may be inoperable without impacting the OPERABILITY of its respective train.

Catawba Units I and 2 B 3.6.9-1 Revision NOW

HIS B 3.6.9 BASES BACKGROUND (continued)

When the HIS is initiated, the ignitorlements are energized and heat up to a surface temperature > 1700I°2 At this temperature, they ignite the hydrogen gas that is present in the airspace in the vicinity of the ignitor.

The HIS depends on the dispersed location of the ignitors so that local pockets of hydrogen at increased concentrations would burn before reaching a hydrogen concentration significantly higher than the lower flammability limit. Hydrogen ignition in the vicinity of the ignitors is assumed to occur when the local hydrogen concentration reaches 8.5 volume percent (Vio) and results in 100% of the hydrogen present being consumed.

APPLICABLE The HIS causes hydrogen in containment to bum in a controlled SAFETY ANALYSES manner as it accumulates following a degraded core accident (Ref. 3).

Burning occurs at the lower flammability concentration, where the resulting temperatures and pressures, are relatively benign. Without the system, hydrogen could build up to higher concentrations that could result in a vio ent reaction if ignited by a random ignition source after such a buildup.

The hydrogen ignitors are not included for mitigation of a Design Basis Accident (DBA)-be6ause an amount of hydrogen equivalent to that generated from the. reaction of 75% of the fuel: cladding with water is far in excess of the hydrogen calculated for the limiting DBA loss of coolant accident (LOCA). The hydrogen ignitors have been shown by I probabiliStic risk analysis to be a significant contributor to limiting the severity of accident sequences that are commonly found to dominate risk for units with ice condenser containments. As such, the hydrogen ignitors satisfy Criterion 4 of 10 CFR 50.36 (Ref. 4).

LCO Two HIS trains must be OPERABLE with power from two independent, safety related power supplies.

, to-i For this unit, an OPERABLE HIS train consists of 34 (Unit 1) or 33A(Unit

2) of 35 ignitors energized on the train.

D in Unit 2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected .ignitor replacement, each train's ignitor located beneath the reactor vessel missile eld may be inoperable without impacting theOPERABILITY of its respective train. W/

/9A Catawba Units 1 and 2 B 3.6.9-2 Revision N

HIS B 3.6.9 BASES LCO (continued)

Operation with at least one HIS train ensures that the hydrogen in containment can be burned in a controlled manner. Unavailability of both HIS trains could lead to hydrogen buildup to higher concentrations, which could result in a violent reaction if ignited. The reaction could take place fast enough to lead to high temperatures and ovqrpressurization of containment and, as a result, breach containment or cause containment leakage rates above those assumed in the safety analyses. Damage to safety related equipment located in containment could also occur.

APPLICABILITY Requiring OPERABILITY in MODES 1 and 2 for the HIS ensures its immediate availability after safety injection and scram actuated on a LOCA initiation. In the post accident environment, the two HIS subsystems are required to control the hydrogen concentration within containment to near its flammability limit of 4.0 v/o assuming a worst case single failure. This prevents overpressurization of containment and damage to safety related equipment and instruments located within containment.

In MODES 3 and 4, both the hydrogen production rate and the total hydrogen production after a LOCA would be significantly less than that calculated for the DBA LOCA. Also, because of the limited time in these MODES, the probability of an accident requiring the HIS is low.

Therefore, the HIS is not required in MODES 3 and 4.

In MODES 5 and 6, the probability and consequences of a LOCA are reduced due to the pressure and temperature limitations of these MODES. Therefore, the HIS is not required to be OPERABLE in MODES 5 and 6.

ACTIONS A.1 and A.* ' -

With one HIS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days or the OPERABLE train must be verified OPERABLE frequently by performance of'SR 3.6.9.1. The 7 day Completion Time is based on the low probability of the occurrence of a degraded core event that would generate hydrogen in amounts equivalent Y

For to a metal water reaction of 75% of the core cladding, the Unit 2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected ignitor replacement, each train's ignitor located beneath the reactor vessel missile shield may be inoperable without requiring entry into this Condition.

Catawba Units 1 and 2 B 3.6.9-3 Revision No.-&

HIS B 3.6.9 BASES ACTIONS (continued) length of time after the event that operator action would be required to prevent hydrogen accumulation from exceeding this limit, and the low probability of failure of the OPERABLE HIS train. Alternative Required Action A.2, by frequent surveillances, provides assurance that the OPERABLE train continues totbe OPERABLE.

Condition B is one containment region with no OPERABLE hydrogen ignitor. Thus, while in Condition B, or in Conditions A and B simultaneously, there would always be ignition capability in the adjacent containment regions that would provide redundant capability by flame propagation to the region with no OPERABLE ignitors.

Required Action B.1 calls for the restoration of one hydrogen ignitor in each region to OPERABLE status within 7 days. The 7 day Completion Time is based on the same reasons given under Required Action A.1.

C.l1 The unit must be placed in a MODE in which the LCO does not apply if the HIS subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time. This is done by placing the unit in at least

-MODE 3 within 6hours. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.9.1 REQUIREMENTS This SR confirms that > 34 (Unit 1) or 3 *(Unit 2) of 35 hydrogen ignitors can be successfully energized in each train. The ignitors are simple resistance elements. Therefore, energizing provides assurance of

For Unit,2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows\

affected ignitor replacement, each train's ignitor located beneath the reactor vessel missile shield may be inoperable without requiring entry into this Condition.

- For Unit 2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected ignitor replacement, this SR is not applicable to each train's ignitor located beneath the reactor vessel missile shield.

Catawba Units 1 and 2 B 3.6.9-4 Revision No.(-)

HIS B 3.6.9 BASES SURVEILLANCE REQUIREMENTS (continued)

OPERABILITY. The allowance of one inoperable hydrogen ignitor is acceptable because, although one inoperable hydrogen ignitor in a region would compromise redundancy in that region, the containment regions are interconnected so that ignition in one region would cause burning to progress to the others (i.e., there is overlap in each hydrogen ignitor's effectiveness between regions). The Frequency of 92 days has been shown to be acceptable- through operating experience.

SR 3.6.9.2 This SR confirms that the two inoperable hydrogen ignitors allowed by SR 3.6.9.1 (i.e., one in each train) are not in the same containment

--- io The Frequency of 92 days is acceptable based on the Frequency of SR 3.6.9.1, which provides the information for performing this SR.

SR 3.6.9.3 A more detailed functional test is performed every 18 months to verify system OPERABILITY. Each ignitor is visually examined to ensure that it is clean and that the electrical circuitry is energized. All ignitors, including normally inaccessible ignitors, are visually checked for a glow to verify that they are energized. Additionally, the surface temperature of each

- ignitor is measured to be > 17Q0°F to demonstrate that a temperature sufmief-nmr iiggnition is achiever. The 1700°F temperature is a surveillance requirement. "An Analysis of Hydrogen Control Measures at McGuire Nuclear Station" (Ref. 5), section 3.8 identifies that the required normal operation temperature is 1500 0F. Therefore, based upon ignitor S........... *... performance-lestind conducted* atiG-atawba, the surveillance requirement of 17001F ensures that sufficient margin is present for continued hydrogen ignition under degraded bus conditions. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based e-,* on the refueling cycle. Therefore, the Frequency was concluded to be K*For acceptable from a reliability standpoint.

Unit 2 Cycle 11 operation only, or until the next Unit 2 entry into MODE 5 which allows affected ignitor replacement, this SR is not applicable to each train's- ignitor located beneath the N

\~reactor vessel missile shield.

Catawba Units 1 and 2 B 3.6.9-5 Revision Noo7

4 DC Sources-Operating B 3.8.4 BASES ACTIONS (continued) the loss of the channel DC power and the associated DG DC power, the load center power for the train is inoperable and the Condition(s) and Required Action(s) for the Distribution Systems must be entered immediately.

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations. The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 9).

SR 3.8.4.2 Verifying batte individual cell voltag While on float charge f the DG batteries uf ing nickel cadmium c s ensures each cell is pable of I supporti their intended functio . Float charge is the c ition in which the q rger is supplying the c/inuous charge requir to overcome the in nal losses of a battery battery cell) and mai in the battery (or a attery cell) in a fully ch ed state. Thebatte eli voltage limit of>

1.36 V is consistent the nominal design v age of the battery and is based on the man 'cturer's recommende minimum float charge voltage for a fu charged cell with ade te capacity. The battery is designed a ized with a capacity in sufficient to allow up to e 6E )- cell to be Ily degraded with a vo ge < 1.36 V assumi that are ju ered out. The battery' zing calculations account for degraded cells cel y assuming the degra cell undergoes a worst-cas olarity versal during a design scharge. For this surveillanc ,a minimum of two cells shall be tes every seven days. The cells elected for testing shall be rotated o monthly basis. The 7 day Fr uency is consistent with the manuf urer's recommendations.

Catawba Units 1 and 2 B 3.8.4-5 Revision No

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.3 For the DC channel and DG batteriesýillead visual inspection to detect corrosion of the battery terminals and connections, or measurement of the resistance of each intercell, interrack, intertier, and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of visible corrosion does not necessarily represent a failure. of this SR, provided an evaluation determines that the visible corrosion does not affect the OPERABILITY of the battery.

ls an Fv rthDobadteries c trosion' of utilizin the batt ry bicke terminals and c etnections cadmium n provi dcosvisua nspect n to detect j*eri~ration that c; uld or abnormal Id indicati n of physical damage Te presence of vi i~le poten ally degrade batt~r performance. aailure of this SR provided an corrsion does not'ne. ssarily represent e RBUation determin that the visiryle cor.siondoesnot ctthe The Surveillance Frequency for these inspections, which can detect conditions that can cause power losses dueto resistance heating, is 92 days. This Frequency is considered acceptable based on operating experience related to detecting corrosion trends.

SR 3.8.4.4 For the DC channerbatteries, visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not necessarily represent a failure of this S8R, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function).

For the D batteries, visu Iinspection of the attery cells, cell lates, and battery rcks provides an/indication of physi al damage o abn rma!

jars ar~e/not transparent, adirect by:

the DGhickel cadmium oattery cell deta ioration nd abnormal fo physical damage plates re inspected cell jar sides of eacl inspe rcell ing the electrolytr of each for excessive/bowing te

1) vis ally inspecting d 2) visually deformation, and/ normal for a appear nce.

Revision No.*)

Iand 2 B 3.8.4-6 Catawba Units

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.8.4.5 and SR 3.8.4.6 Visual inspection and resistance measurements of intercell, interrack, intertier, and terminal connections provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition.' The anticorrosion material, as recommended by the manufacturer for the batteries, is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion Is not intended to require removal of and inspection under each terminal connection. The removal of visible corrosion is a

,preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.5.

For th'e 'batteries utilizJig nickel cad'-miur lcells, the cell-t cell ermin ipole s.crews sho ~id be set from 14 o 15 foot-poun(* of torque._,

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.8.4.7 This .SR requires that each battery charger for the DC channel be capable of supplying at least 200 amps and at least 75 amps for the DG chargers. All chargers shall be tested at a voltage of at least 125 V for

Ž8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . These requirements are-based on the design capacity of the chargers (Ref. 4). According to Regulatory Guide 1.32 (Ref. 10), the battery charger supply Is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensures that these requirements can be satisfied.

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance duringthese 18 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

IRevision No.0 q Catawba Units I and 2 B 3.8,4-7

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.8 A battery service test is a special test of battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The vital battery's actual duty cycle is identified in calculation CNC-1 381.05-00-0011, 125 VDC Vital Instrumentation and Control Power System Battery and Battery Charger Sizing Calculation.

The test duty cycle is the actual duty cycle adjusted for the temperature correction factor for 601F operation, and a design margin of typically 10 to 15% for load addition. The DC channel batteries are tested to supply a current > 534.11 amps for the first minute, then > 279.23 amps for the next 9 minutes, > 387.66 amps for the next 10 minutes, and > 293.49 amps for the next 100 minutes. Terminal voltage is required to remain >

110.4 volts during this test. The DG battery's actual duty cycle is identified in calculation CNC-1381'.05-00-0050, 125 VDC Diesel Generator Battery and Battery Charger Sizing Calculation. The test duty cycle is the actual duty cycle adjusted for the temperature correction factor for 601F operation,_and a design margin of typicall 10 to 15% for load addition.f*-e DG Iatteries utilizirnqnickel cadmium/cells are tes '

csretedoasup p current>> 2122 amps for etht n >f42.5m aem s

> 3or the 10 the minutes,

/42.5 a ps for next then 108 min tes. Terminal rerraining for1271.8v(itage is re(lqy d to the nexinute, amps k,,remaii 'a 105 vot drn this et.hD-G batteries tl'1'ing Id th a >d "

Isre tested to supply a cur~rent _>228.0 amps for the first minute, then

> 37.75 amps for the next 10 minutes, then > 127.1 amps for the next minute, then > 37.75 amps for the remaining 108 minutes. Terminal voltage is required to remain > 105 volts during this test. (Note: The duty cycle in the UFSAR is used for battery sizing and includes the temperature factor of 11%, a design margin of 15%, and an aging factor of 25%.)

Except for performing SR 3.8.4.8 for the DC channel batteries with the unit on line, the Surveillance Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 10), which states that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests, not to exceed 18 months.

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

Catawba Units 1 and 2 63.8.4-8 Revision No.(7)

Battery Cell Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters BASES BACKGROUND This LCO delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the channels of DC power source I batteries. The LCO also addresses the trains of DC for the Diesel I Generator battery i A discussion of these batteries. and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources-Operating," and LCO 3.8.5, "DC Sources-Shutdown."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY ANALYSES analyses in.the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2),

assume Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This.includes maintaining at least one train of DC sources OPERABLE during accident conditions, in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power; and

b. A worst case single failure.

Battery cell parameters satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Electrolyte limits are conservatively established, allowing continued DC :electrical system function even with Category A and B limits not met.

Catawba Units 1 and 2 8 3.8.6-1 Revision NoA711k W

Battery Cell Parameters B 3.8.6 BASES APPLI.CABILITY The battery cell parameters are required solely for the support of the associated DC electrical power subsystems. Therefore, battery electrolyte is only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACTIONS A.1, A.2, and A.3 With one or more cells in one or more batteries (DC batteries, DG batteries z lead aci ce or both) not within limits (i.e., Category A !

limits not metCategory B limits not met, or Category A and B limits not met) but within the Category C limits specified in Table 3.8.6-1 in the accompanying LCO,-the battery is degraded but there is still sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of Category A or B limits not met and operation is permitted for a limited period.

The pilot cell electrolyte level and float voltage are required to be verified to meet the.Category C limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (Required Action A.1). This check will provide a quick indication of the status of the remainder of the battery cells. One hour-provides time to inspect the electrolyte level and to confirm the float voltage:of the pilot bells. One hour is considered a reasonable amount of time to perform the required verification.

Verification that the Category C limits are met (Required Action A.2) provides assurance that during the time needed to restore the parameters to -the Category A and B limits, the battery is still capable of performing its intended function. A period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to complete the initial, verification because specific gravity measurements must be obtained for each connected cell. Taking into consideration both the time .required to perform the required verification and the assurance that the battery cell parameters are not severely degraded, this time is considered reasonable. The verification is repeated at 7 day intervals until the parameters are restored to Category A or B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surveillances.

Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. With the

..consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable prior to declaring the battery inoperable.

Catawba Units 1 and 2 B 3.8.6-2 Revision N6.0

L f Battery Cell Parameters B 3.8.6 BASES ACTIONS (continued) -

B. 1 and B.2 With one or more batteries (DC batteries, DG batteriesj e i

<2D or both) with one or more battery cell parameters outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as not completing the Required Actions of Condition A within the required Completion Time or average electrolyte temperature of representative cell applible i to DO/batteries aW both typs of DG bitteries1falling below 60WF, are also cause for immediately declaring the associated DC electrical power subsystem inoperable per Required Action B.1.

In addition, Required Action'B.2 mandates that the appropriate LCO(s) must then be entered for the DG supported by the inoperable DC subsystem. If the plant is in MODES 1 through 4, LCO 3.8.1, "AC Sources - Operating" is required to be entered. If the DG is required to support equipment during MODES 5 or 6 or movement of irradiated fuel

-assemblies, regardless of operating mode, LCO 3.8.2, "AC Sources -

Shutdown," is the appropriate LCO.

Required Action B.2 is modified by a Note indicating that it is only applicable for inoperable DG batteries.

cor onigD lcria oe usystemrst be decl!ared/

pmith ro one DG batrie mr utilizing n kel ce cn hmore bat cel t within limits f page, v

s I eola required f the DG is not assumed nd the correspondi DC electrical power. system must be eclared inoperable immedi ely. Appropriate LCO( must then be en red for the DGsupported y the inoperable DC s system.' If the pl t is in MODES I throug 4, LCO 3.8.1, "AC So ces-Operating" i required to be entered.

If the DG is re uired to support equip nt during MODE 5 or 6 or movement o irradiated fuel assembli ,regardless of o rating mode, LCO 3.8.2, 'AC Sources-Shutdow 'is the appropriat LCO.

Catawba Units 1 and 2 B 3.8.6-3 Revision No"

I Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.1 -

REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 4), which recommends regular battery inspections (at least one per month) including voltage, specific gravity, and electrolyte temperature of pilot cells. This SR is applicable to both DC batteries and DG batteries lead a d cell SR 3.8.6.2 This SR erifies the DG ni el cadmium bat ry cell para ter of leve ia

/ ~~regular/ attery inspecctior Vat eas once every 7 days). T e electroly/

/lVa)t s-,,9_ _' -. level' monitored in or:Jrto maintain ba ryperforma ~e and I

.~~ \eftiveness.- The 7 fy Frequency ha been shown *cceptable *roughJ SR 3.8.6.3 The guarterly inspection of the channels o6UDC and DG batteriejin e acid Ils for specific gravity and voltage is consistent with IEEE-450 (Ref. 4). In addition, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a battery discharge < 110 V or a battery overcharge > 150 V, the battery must be demonstrated to meet Category B limits. Transients, such, as motor starting transients, which may momentarily cause battery voltage to drop to *_110 V, do not constitute a battery discharge provided the battery terminal voltage and float current return to pre-transient values. This inspection is also consistent with IEEE-450 (Ref. 4), which recommends special inspections following a severe discharge or overcharge, to ensure that no significant degradation of the battery occurs as a consequence of such discharge or overcharge.

SR 3.8.6.4 This Surveillance verification that the average temperature of representative cells is _>60'F,- is consistent with a recommendation of IEEE-450 (Ref. 4), that states that the temperature of electrolytes in representative cells should be determined. on a quarterly basis.

Lower than normal temperatures act to inhibit or reduce battery capacity.

This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer recommendations.

Catawba Units 1 and 2 B 3.8.6-4 Revision No.

ATTACHMENT 3 NRC COMMITMENTS Attachment 3, Page 1

There are no regulatory commitments being made with this license amendment request.

Attachment 3, Page 2

ML082880098

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