ML103270658
| ML103270658 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/18/2010 |
| From: | Repko R Duke Energy Carolinas, Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML103270658 (41) | |
Text
REGIS T. REPKO Vice President O Ernergy McGuire Nuclear Station Duke Energy MG01 VP /12700 Hagers Ferry Rd.
Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis. repko@duke-energy. com November 18, 2010 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Document Control Desk
Subject:
Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Response to Request for Additional Information Related to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program This letter provides the responses to a request for additional information (RAI) regarding the McGuire License Amendment Request (LAR) dated March 24, 2010 applicable to the relocation of specific surveillance frequencies to a licensee controlled program in accordance with TSTF-425 Revision 3 and NEI 04-10 Revision 1. The RAI request was conveyed by the NRC staff via electronic mail from Jon Thompson on October 21, 2010. The NRC staff's questions and Duke Energy's responses are provided in Enclosure 1.
In addition, Enclosure 2 contains updated Technical Specification (TS) and Bases marked up pages related to four TS changes that were recently approved by the NRC. As communicated on page 3 of Attachment 1 of the subject LAR, there were six LARs pending NRC review and approval that affect surveillances modified by this LAR. Four of the six LARs have been approved by the NRC and implemented by McGuire, while two are still pending. As stated in the LAR, McGuire is now providing the updated TS and Bases pages. These changes do not represent deviations from TSTF-425 or the NRC's model safety evaluation.
Please replace the corresponding pages in your LAR files. The following table summarizes the affected TS and Bases.
www. duke-energy com
November 18, 2010 Nuclear Regulatory Commission Page 2 Table of Updated TS and Bases Marked up Pages Date of NRC Affected TS Surveillances Approval June 28, 2010 SRs 3.6.13.1, 3.6.13.4, 3.6.13.5 and 3.6.13.6. Modifies Ice Condenser Door SR descriptions and deletes 3.6.13.6.
May 5, 2010 SR 3.8.1.4. Modifies minimum EDG day tank level. Bases page not affected.
August 2, 2010 SR 3.3.1.11. Excore detector replacement modification August 24, 2010 SR 3.6.6.7. Revises spray nozzle inspection frequency. This SR will no longer relocate to the surveillance frequency control program per TSTF-425.
The conclusions reached in the original determination that the LAR contains No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement have not changed as a result of this request for additional information.
Please contact Lee A. Hentz at 980-875-4187 if additional questions arise regarding this LAR.
Sincerely, Regis T. Repko Enclosures
November 18, 2010 Nuclear Regulatory Commission Page 3 cc:
w/enclosures L. A. Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. H. Thompson (addressee only)
Project Manager (MCGuire)
U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD, 20852-2738 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station W. L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645
November 18, 2010 Nuclear Regulatory Commission Page 4 OATH AND AFFIRMATION Regis T. Repko 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.
Regis,.rnpko, Site Vice President N\\Q&V4 (vý
,Wy fv Ioq,01 Subscribed and sworn to me:
Date fl\\a-air (I,/7279&rm Date My commission expires:
'C
ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)
RELATED TO THE APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM NRC RAIs and Duke Responses
- 1. Table 2-1 of Attachment 2 identifies specific unresolved "gaps" of the McGuire Nuclear Station probabilistic risk assessment (PRA) internal events model to meeting the American Society of Mechanical Engineers PRA standard Capability Category II supporting requirements. In the column labeled "Importance to 5b Application", the licensee asserts, for some specific supporting requirements which are not met at Capability Category II, that:
i)
Certain gaps will be assessed on a case-by-case basis ii)
The gap has no or minimal impact on surveillance test exceptions.
Asserting that certain gaps are to be assessed on a case-by-case basis is inconsistent with Nuclear Energy Institute (NEI) 04-10, Revision 1, which specifically requires Capability Category II. Further, NEI 04-10, requires all gaps to Capability Category II to be assessed via sensitivity studies. This position was accepted by the staff in its safety evaluation of NEI 04-10 Revision 1. Therefore, notwithstanding the assertions in Table 2-1 regarding Capability Category I, each supporting requirement not meeting Capability Category II must be further evaluated by sensitivity studies when applying the internal events PRA model for this application.
With regard to item ii above, the gaps cannot be dispositioned a priori,.since this would also conflict with NEI 04-10 which did not identify any supporting requirements that were not required for this application. Again, such gaps must be evaluated by sensitivity studies for each surveillance frequency change.
The licensee is therefore requested to confirm that their plant program for control of surveillance frequencies includes a requirement to assess all open gaps to Capability Category II of the standard via sensitivity studies for each application of the NEI 04-10 methodology, and does not rely upon any a priori assessment of the relevance of the supporting requirement.
Duke Response:
All open gaps to Capability Category II of the standard will be addressed via sensitivity studies for each application of the NEI 04-10 methodology, and will not rely upon any a priori assessment of the relevance of the supporting requirement. The Duke Energy plant program for control of surveillances has been revised to clarify the requirement to assess all open gaps to Capability Category II of the standard via sensitivity studies for each application of the NEI 04-10 methodology, and does not rely upon any a priori assessment of the relevance of the supporting requirement.
Table 2-1 has been revised to remove wording that indicated gaps will be assessed on a case-by-case basis or that gaps have no or minimal impact on the surveillance frequency change. Revised Table 2-1 is attached to this enclosure.
- 2.
In Table 2-1, Attachment 2 of the submittal, gap #14 identifies twelve supporting requirement deficiencies to the model. The licensee dispositions this gap as documentation issues. The NRC staff requires a detailed clarification for all supporting requirements that were assessed against Capability Category I1 technical requirements and characterized as model documentation issues.
Duke Response:
Table 2-1 has been revised to provide a detailed clarification for all supporting requirements that were assessed against Capability Category I! technical requirements and characterized as model documentation issues. Revised Table 2-1 is attached to this enclosure.
ENCLOSURE 1 REVISED TABLE 2-1 STATUS OF IDENTIFIED GAPS IN THE MCGUIRE PRA TO CAPABILITY CATEGORY II OF THE ASME PRA STANDARD THROUGH ADDENDA RA-Sc-2007 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #1 Accident sequence notebooks AS-B3 Open. Phenomenological For each and system model notebooks effects are considered in the surveillance should document the model, although these frequency change phenomenological conditions considerations are not evaluation, any created by the accident sequence always documented.
phenomenological progression.
conditions created by the accident sequence progression will be identified, included and documented in the analysis.
Gap #2 Revise the data calc. to discuss DA-Ala Open. Structures, Systems Each surveillance component boundaries and Components (SSC) and frequency change definitions, unavailability boundaries, evaluation will use SSC failure modes and definitions for SSC success criteria are used
- boundary, consistently across analyses; unavailability however, these need to be boundary, failure formally documented.
mode, and success criteria consistently across the systems and data analyses.
Page I
ENCLOSURE 1 Applicable Impact on 5b Title Description of Gap SRs Current Status / Comment Applications Gap #3 Revise the data calc. to group DA-B1 Open. Partitioning the failure Each surveillance standby and operating component rates represents a frequency change data. Group components by refinement to the data evaluation will service condition to the extent analysis process.
include sensitivity supported by the data.
Previously, generic data studies to consider sources often did not provide the impact of standby and operating failure grouping data into rates. NUREG/CR-6928 operating vs.
does provide more of this standby failure rates data, and will be used going and by service forward.
condition.
Gap #4 Enhance the documentation to DA-D4 Open. As part of the Each surveillance include a discussion of the Bayesian update process, frequency change specific checks performed on the checks are performed to evaluation will verify Bayesian-updated data, as assure that the posterior that the Bayesian required by this SR.
distribution is reasonable update process given the prior distribution produces a and plant experience. These reasonable posterior checks need to be formally distribution. (See documented.
the example tests in DA-D4.)
Page 2
ENCLOSURE 1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #5 Provide documentation of the DA-D6 Open. Generic CCF Each surveillance comparison of the component probabilities are considered frequency change boundaries assumed for the for applicability to the plant.
evaluation will generic common cause failure CCF probabilities are ensure that CCF (CCF) estimates to those consistent with plant probabilities are assumed in the PRA to ensure experience and component consistent with that these boundaries are boundaries, although the component consistent.
CCF documentation needs boundaries and to be enhanced to discuss plant experience.
component boundaries.
Gap-#6 Enhance the human reliability HR-A2 Open. Based on evaluations Each surveillance analysis (HRA) to consider the using the EPRI HRA frequency change potential for calibration errors.
calculator, calibration errors evaluation will that result in failure of a identify and consider single channel are expected the impact that to fall in the 10-3 range.
equipment Relative to post-initiator calibration errors human error probabilities could have on the (HEPs), equipment random results and failure rates and conclusions.
maintenance unavailability, calibration HEPs are not expected to contribute significantly to overall equipment unavailability.
Page 3
ENCLOSURE1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #7 Identify maintenance and HR-A3 Open. Based on evaluations Each surveillance calibration activities that could using the EPRI HRA frequency change simultaneously affect equipment calculator, calibration errors evaluation will in either different trains of a that result in failure of identify any work redundant system or diverse multiple channels are practices that could systems.
expected to fall in the simultaneously 10-5 (or smaller) range.
affect equipment in Relative to post-initiator either different trains HEPs, latent human error of a redundant probabilities, equipment system or diverse random failure rates and systems.
maintenance unavailability, calibration HEPs and misalignment of multiple trains of equipment are not expected to contribute significantly to overall equipment unavailability.
Gap #8 Develop mean values for pre-HR-D6 Open. Pre-initiator HEPs are Each surveillance initiator HEPs.
generally set to relatively frequency change high screening values, which evaluation will use bound the mean values, mean values for pre-Even so, pre-initiator HEPs initiator HEPs.
are not significant contributors to risk.-
Page 4
ENCLOSURE 1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #9 Document in more detail the HR-G3 Open. Performance shaping Each surveillance influence of performance shaping factors are accounted for in frequency change factors on execution human error the development of human evaluation will use probabilities, error probabilities, although HEP values that detailed documentation is have been not always available for quantified with every HRA input, consideration of plant-specific and scenario-specific performance shaping factors.
Gap #10 Enhance HRA documentation of HR-G4 Open. Thermal/hydraulic Each surveillance the time available to complete (T/H) analyses, simulator frequency change actions.
runs and operator interviews evaluation will use are used in developing the HEP events with time available to complete time available inputs operator actions. The time based on plant-at which the cue to take specific T/H action is received is specified analyses or in the HEP quantification.
simulations.
However, the HRA documentation needs to be enhanced to provide a traceable path to all analysis inputs.
Page 5
ENCLOSURE 1 Title Description of Gap Applicable Current Status / Comment Impact on 5b SRs Applications Gap #11 Document a review of the human HR-G6 Open. HFEs are reviewed For each failure events (HFEs) and their by knowledgeable site surveillance final HEPs relative to each other personnel to assure high frequency change to confirm their reasonableness quality. However, this review evaluation, post-given the scenario context, plant needs to be better initiator HEPs will be history, procedures, operational documented.
reviewed against practices, and experience, each other to check their reasonableness given the scenario context, plant procedures, operating practices and experience.
Gap #12 Develop mean values for post-HR-G9 Open. The use of mean Each surveillance initiator HEPs.
values for HEPs instead of frequency change lower probability median evaluation will use values can affect the PRA mean values for results.
post-initiator HEPs.
Page 6
ENCLOSURE1 Applicable Impact on 5b Title Description of Gap SRs Current Status / Comment Applications Gap #13 Develop more detailed HR-H2 Open. Operator recovery Each surveillance documentation of operator cues, actions are credited only if frequency change relevant performance shaping they are feasible, as evaluation will credit factors, and availability of determined by the operator actions sufficient manpower to perform procedural guidance, cues, only if they are the action.
performance shaping factors feasible, as and available manpower. As determined by the noted for HR-G3, -G4, and -
procedural G6 above, the guidance, cues, documentation of these performance considerations needs to be shaping factors and enhanced.
available manpower.
Page 7
ENCLOSURE 1 Title Applicable Current Status / Comment Impact on 5b Description of Gap SRs Applications Gap #14 Document:
a structured, systematic identification of initiating events a review of generic analyses of similar plants the systematic evaluation of the potential for failure of each system, including support systems, to result in an initiating event the inclusion of initiators resulting from common cause equipment failures and from routine system alignments the disposition of events that have occurred at conditions other than at-power operation for their potential to result in an initiator while at power plant personnel input in determining whether potential initiating events have been overlooked a review of plant-specific precursor events for their potential to result in initiating events a structured, systematic initiating events grouping process that facilitates accident sequence definition and quantification that initiators are grouped by similarity of plant response, success criteria, timing, and effect on operators and relevant systems; or events can be subsumed within a bounding group the initiating events analysis assumptions and sources of uncertainty IE-Al IE-A3 IE-A3a I E-A4 I E-A4a IE-A5 IE-A6 I E-A7 IE-B1 IE-B2 IE-B3 IE-D3 Open. No technical issues are identified, just a need to enhance the documentation.
The list of McGuire PRA initiating events is consistent with that of its sister plant, Catawba Nuclear Station, as well as with those found in analyses for similar plants, such as those contained in the Pressurized Water Reactor Owner's Group PSA Model and Results Comparison Database.
The McGuire initiating events analysis is revised with each PRA update to ensure that it remains consistent with industry operating experience as well as current plant design, operation and experience. In addition, calculation MCC-1535.00-00-0116, Potential Internal Initiating Events for the McGuire PRA, has been performed to address the IE supporting requirements.
However, this analysis needs to be incorporated into the base case PRA model.
Each surveillance frequency change evaluation will review MCC-1535.00-00-0116 for potential impacts on the analysis. Each surveillance frequency change evaluation will include sensitivity analyses to determine the impact of the assumptions and sources of model uncertainty on the 5b analysis results.
Page 8
ENCLOSURE1 Applicable Impact on 5b, Title Description of Gap SRs Current Status / Comment Applications Gap #15 Various enhancements to the IF-B3 Open. The McGuire internal A plan and schedule internal flood analysis:
IF-C2c flooding analysis has been are in place for
" Identify the release IF-C3 upgraded to meet the updating the base case PRA model. In characteristic and capacity IF-C3b Standard's requirements.
the interim, for each associated with each flood IF-E6b However, this model needs surveillance source.
IF-F2 to be incorporated into the frequency change, f Discuss flood mitigative base case PRA model.
we will evaluate all featuress SRs not meeting
- Address the potential for spray, CCII with sensitivity jet impingement, and pipe whip studies and refer to failures.
the updated MNS
" Provide more analysis of flood flood analyses for propagation flowpaths.
i n
alys.
Address potential structural failure of doors or walls due to flooding loads and the potential for barrier unavailability.
" Address potential indirect effects.
- Enhance the documentation to address all of the SR details.
Page 9
ENCLOSURE 1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #16 Explicitly model Reactor Coolant LE-C6 Open. This issue affects Each surveillance System (RCS) depressurization certain small LOCAs.
frequency change for small Loss of Coolant However, since the small evaluation will Accidents (LOCAs) and perform LOCA contribution to Large include a sensitivity the dependency analysis on the Early Release Frequency study to assess the HEPs.
(LERF) is small, there is no importance of significant impact on the explicitly modeling PRA results.
RCS depressurization for small LOCAs.
Page 10
ENCLOSURE 1 Title Applicable Current Status / Comment Impact on 5b Description of Gap SRs Applications Gap #17 Various enhancements to the LERF documentation.
LE-G3 LE-G5 LE-G6 Open.
Each surveillance frequency change evaluation will document:
- the relative contribution of contributors to LERF and any limitations in the LERF analysis that would impact the 5b evaluation the use of the quantitative definition for significant accident progression sequence provided in the "Acronyms and Definitions" section of the PRA Standard.
Page I I
ENCLOSURE 1 AppliableImpact on 5b Titl Decritio ofGapApplicable Current Status / Comment Ipc n5 Title Description of Gap SRs Applications Gap #18 Perform and document a LE-F3 Open. Since McGuire and Each surveillance comparison of PRA results with QU-D3 Catawba are sister plants, in frequency change similar plants and identify causes practice, their results are evaluation will for significant differences. Identify often compared. Also, perform and the contributors to LERF and comparisons performed for document a characterize the LERF the Mitigating Systems comparison of CDF uncertainties consistent with the Performance Index and other and LERF results applicable ASME Standard programs help identify with those of similar requirements.
causes for significant plants.
differences. However, to fully meet this SR, the model quantification documentation needs to be enhanced to provide a results comparison.
Gap #19 Perform and document sensitivity LE-F2 Open. This is addressed Each surveillance analyses to determine the impact LE-G4 with each Surveillance Test frequency change of the assumptions and sources QU-E4 Interval assessment.
evaluation will of model uncertainty on the include sensitivity results.
analyses to determine the impact of the assumptions and sources of model uncertainty on the 5b analysis results.
Page 12
ENCLOSURE 1 Applicable Impact on 5b Title Description of Gap Ala Current Status / Comment Applications SRs Applications__
Gap #20 Expand the documentation of the PRA model results to address all required items.
QU-F2 QU-F6 Open. These SRs pertain to the model quantification documentation.
Each surveillance frequency change evaluation will document:
- the model integration
- process, recovery analysis, and uncertainty and sensitivity analyses the use of definitions for significant basic event, significant cutset, and significant accident sequence provided in the "Acronyms and Definitions" section of the PRA Standard.
Page 13
ENCLOSURE 1 Title Description of Gap Applicable Current Status / Comment Impact on 5b SRs Applications Gap #21 Improve the documentation on the SC-A4 Open. Success criteria are Each surveillance T/H bases for all safety function developed to address all of frequency change success criteria for all initiators, the modeled initiating events, evaluation will However, the documentation ensure that the of success criteria needs to success criteria be improved to include address all initiators.
initiator information.
Gap #22 Provide evidence that an SC-B5 Open. McGuire success Each surveillance acceptability review of the T/H criteria are consistent with frequency change analyses is performed.
those of sister plants evaluation will check included in the Pressurized and ensure the Water Reactor Owners reasonableness and Group (PWROG) acceptability of the Probabilistic Safety T/H analyses results Assessment (PSA) used to support the database. However, to fully success criteria.
meet this SR, the success criteria documentation needs to be enhanced to include a results comparison.
Page 14
ENCLOSURE1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #23 Expand the documentation of the SC-Cl Open. These SRs pertain to Each surveillance success criteria development to SC-C2 the success criteria frequency change address all required items.
documentation.
evaluation will ensure that.:
- success criteria are documented in a manner that facilitates the 5b application, model upgrades and peer review
- the processes used to develop overall PRA success criteria and supporting engineering bases, including inputs, methods and results are documented.
Page 15
ENCLOSURE1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs Applications Gap #24 Enhance the system documentation to include an up-to-date system walkdown checklist and system engineer review for each system.
SY-A4 Open. To support system model development, walkdowns and plant personnel interviews were performed. However,-
documentation of an up-to-date system walkdown is not included with each system notebook.
Workplace procedure XSAA-115, PRA Modeling Guidelines, has been revised to require documentation of a system walkdown and system engineer interview.
A plan and schedule for updating the system models with the revised guidance is in place.
Until each system notebook is updated, the impact of this gap will be evaluated for each surveillance frequency change.
Page 16
ENCLOSURE1 Applicable Impact on 5b Title Description of Gap SRs Current Status / Comment Applications Gap #25 Enhance the systems analysis documentation to discuss component boundaries.
SY-A8 Open. Basic event component boundaries utilized in the systems analysis are consistent with those in the data analysis. I addition, component boundaries are consistent with those defined in the generic failure rate source documents, such as NUREG/CR-6928.
Dependencies among n
Each surveillance frequency change evaluation will use definitions for SSC
- boundary, unavailability boundary, failure mode, and success criteria consistently across the systems and data analyses.
components, such as interlocks, are explicitly modeled, consistent with the PRA Modeling Guidelines workplace procedure. There is no evidence of a technical problem with component boundaries, just a need to improve the documentation, Page 17
ENCLOSURE 1 Title Applicable Current Status / Comment Impact on 5b TeDescription of Gap SRs Applications Gap #26 Provide quantitative evaluations SY-A14 for screening.
Open. There is no evidence of a technical problem associated with the screening of components or component failure modes, just a need to document a quantitative screening. It is expected that conversion to a more quantitative approach would not change decisions about whether or not to exclude components or failure modes. A review of our qualitative screening process confirms this expectation. For example, transfer failure events for motor-operated valves (MOVs) with 24 hr exposure times may not be modeled unless probabilistically significant with respect to logically equivalent basic events. For McGuire, the MOV transfers failure probability is less than 1% of the MOV fails to open on demand failure rate. In cases like this, not including the relatively low probability failure mode in the PRA model does not have an appreciable impact on the results.
For each surveillance frequency change, the component and failure mode screening performed in, the systems analysis will be verified to meet the quantitative requirements provided in SY-A14.
Page 18
ENCLOSURE 1 Applicable Impact on 5b Title Description of Gap SRs Current Status / Comment Applications Gap #27 Per Duke's PRA modeling SY-B8 Open. As noted for SY-A4, The impact of this guidelines, ensure that a walkdowns (which look for gap will be walkdown/system engineer spatial and environmental evaluated for each interview checklist is included in hazards) have been surveillance each system notebook. Based on performed, although up-to-frequency change.
the results of the system date walkdown See Gap #24.
walkdown, summarize in the documentation is not system write-up any possible included with each system spatial dependencies or notebook.
environmental hazards that may impact multiple systems or redundant components in the same system.
Page 19
ENCLOSURE1 Applicable Current Status / Comment Impact on 5b Title Description of Gap SRs C
Applications Gap #28 Document a consideration of SY-B15 Open. The impact of For each potential SSC failures due to adverse environmental surveillance adverse environmental conditions.
conditions on SSC reliability frequency change, is considered but is not potential SSC failure always documented, due to adverse However, there is no environmental evidence of a technical conditions will be problem associated with identified, included components that may be and documented in required to operate in the analysis.
conditions beyond their environmental qualification, just a need to improve the documentation.
Page 20
ENCLOSURE1 Title Applicable Current Status / Comment Impact on 5b Description of Gap SRs Applications Gap #29 Enhance system model documentation to comply with all ASME PRA Standard requirements.
SY-C2 Open. This SR pertains to the systems analysis documentation.
Workplace procedure XSAA-115, PRA Modeling Guidelines, has been revised to provide guidance on meeting the Standard's supporting requirements. A plan and schedule for updating the system models with the revised guidance is in place.
Until each system notebook is updated, the impact
.of this gap will be evaluated for each surveillance frequency change.
Page 21
ENCLOSURE 2 UPDATED TECHNICAL SPECIFICATION AND BASES PAGES Date of NRC Affected TS Surveillances Approval June 28, 2010 SRs 3.6.13.1, 3.6.13.4, 3.6.13.5 and 3.6.13.6. Modifies Ice Condenser Door SR descriptions and deletes 3.6.13.6.
May 5, 2010 SR 3.8.1.4. Modifies minimum EDG day tank level. Bases page not affected.
August 2, 2010 SR 3.3.1.11. Excore detector replacement modification August 24, 2010 SR 3.6.6.7. Revises spray nozzle inspection frequency. This SR will no longer relocate to the surveillance frequency control program per TSTF-425.
Ice Condenser Doors 3.6.13 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
Required Action and C.1 Restore ice condenser door 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> associated Completion to OPERABLE status and Time of Condition B not closed position.
met.
D.
Required Action and D. 1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or C AND not met.
D.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.13.1 Verify all lower inlet doors indicate closed by the Inlet r
Door Position Monitoring System.
SR 3.6.13.2 Verify, by visual inspection, each intermediate deck door is closed and not impaired by ice, frost, or debris.
SR 3.6.13.3 Verify, by visual inspection, each top deck door'
- a.
Is in place; and
- b.
Has no condensation, frost, or ice formed on the door that would restrict its opening.
,ere~
(continued)
McGuire Units 1 and 2 3.6.13-2 Amendment Nosýý
Ice Condenser Doors 3.6.13 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.13.4 Verify, by visual inspection, each lower inlet door is not.
impaired by ice, frost, or debris.
SR 3.6.13.5 Verify torque required to cause each lower inlet door to begin to open is *< 675 in-lb, and verify free movement of the door.
SR 3.6.13.6 (deleted)
SR 3.6.13.7 Verify for each intermediate deck door:
- a.
No visual evidence of structural deterioration;
- b.
Free movement of the vent assemblies; and
- c.
Free movement of the door.
McGuire Units 1 and 2 3.6.13-3 Amendment Nos.
Ice Condenser Doors B 3.6.13 BASES ACTIONS (continued) allowing enough air leakage to cause the maximum ice bed temperature to approach the melting point. The Frequency of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is based on the fact that temperature changes cannot occur rapidly in the ice bed because of the large mass of ice involved. The 14 day Completion Time is based on long term ice storage tests that indicate that if the temperature is maintained below 27 0F, there would not be a significant loss of ice from sublimation. If the maximum ice bed temperature.
is > 27°F at any time or if the doors are not closed and restored to OPERABLE status within 14 days, the situation reverts to Condition C and a Completion Time of.48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to restore the inoperable door to OPERABLE status or enter into Required Actions D. 1 and D.2.
Ice bed temperature must be verified within the specified Frequency as augmented by the provisions of SR 3.0.2. Entry into Condition B is not required due to personnel standing on or opening an intermediate deck or top deck door for short durations (< 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) to perform required surveillances, minor maintenance such as ice removal, or routine tasks such a system walkdowns C. 1 If Required Actions B.1 or B.2 are not met, the doors must be restored to OPERABLE status and closed positions within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time is based on the fact that, with the very large mass of ice involved, it would not be possible for the temperature to increase to the melting point and a significant amount of ice to melt in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
D.1 and D.2 If the ice condenser doors cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed CompletionTimes are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.6.13.1 REQUIREMENTS Verifying, by means of the Inlet Door Position Monitoring System, that the lower inlet doors are in their closed positions makes the operator eare of an inadvertent opening of one or more lower inlet doors.
FrFquyrc/
McGuire Unts 1 and 2 B 3.6.13-5 Revision No-$
Ice Condenser Doors B 3.6.13 BASES SURVEILLANCE REQUIREMENTS (continued)
ýy of 12 hoWi ensuýreýsat operator n each s ware of the atus I
oors of the'Xoors.
S R 3.6.13.2 Verifying, by visual inspection, that each intermediate deck door is closed and not impaired by ice, frost, or debris provides assurance that the intermediate deck doors (which form the floor of the upper plenum where frequent maintenance on the ice bed is performed) have not been left open or obstructed. In determining if a door is impaired by ice, the frost accumulation on the doors, joints, and hinges are to be consider in ecthe wtm he lifting force sifint fr buildu an The Fquency of
/7 days is S ased on engineering judgmet and takes isnto rinsideration S such f ors as the frrr e c ofenrn t th inei rate ice condoý r
-I dec. k, the time reqcudied for signifi.P nt rotbuildu, and the proba'Wlitv SR 3.6.13.3 Verifying, by visual inspection, that the top deck doors are in place and not obstructed provides assurance that the doors are performing their function of keeping warm air out of the ice condenser during normal operation, nd would not b ucted if called u open in res onse toa TB~
he Frequency of 92 days is-based on/egierig
-dmet
- a. /
The relative in acessibility and lack/df traffic in the vicinity e
Sdoors mak t unlikely that a doo uld be inadvertentleft open;,
/b.
Exce ive air leakage wou be detected by temp ature mo/T'rtoring in the ice co enser; and
- c.
The light construc n of the doors would sure that, in th vent of a DBA, air a gases passing throu the ice conden r would find a flow pa, even if a door wer bstructed.
SR 3.6.13.4 Verifying, by visual inspection, that the ice condenser lower inlet doors are not impaired by ice, frost, or debris rovides assurance that e doors are free to open in the event DB For nit e Frequency 18 mont> is basedo door design, ýhich does t allow water cond sation to f eze, and oper sing exper ce, which dies cod.eaio o ~
e
- ~n xe:Dwhc McGuire Unts 1 and 2 B 3.6.13-6 Revision N 5
Ice Condenser Doors B 3.6.13
.BASES SURVEILLANCE REQUIREMENTS (continued) propen&
for ice build-p on or behin he doors while powr. Because o igh radiation*he vicinity of the1
- King power o ration, this S eillance is norm pe shutdown.
SR 3.6.13.5 7-3 Verifying the initial opening torque of the lower inlet doors provides assurance that no doors have become stuck in the closed position and maintains consistency with the safety analysis initial conditions. Verifying the doors are free to move provides assurance that the hinges and spring closure mechanisms are functioning properly and not degrading.
The verifications consists of:
a) Ascertaining the opening torque (torque required to just begin to move the door off of its seal) of each door when pulled (or pushed) open and ensuring this torque is < 675 in-lb, as resolved to the vertical hinge pin centerline, and b) Opening each door manually to the full extent of its available swing arc (i.e., up to slight contact with the shock absorber) and releasing the door, verifying that the spring closure mechanisms are capable of returning the door toward the closed position.
The opening torque test a) should be performed first to minimize the loss of cold head in the ice condenser and prevent any preconditioning of the seal area. During the freedom of movement test b) the cold head is not required, and once the effect of cold head is reduced through outflow, the door may not completely return to its seal from the open position.
The opening torque test limiting value of 675 in-lb is based on the design cold head pressure on the closed lower inlet doors of approximately 1 pound per s quare foo he ýFreency of 18 months is a e
passive ntre o the sprin osure mechanism operating exper rce, which indic s a low propensity r icebuild-up on o ehind the doors while the it is at power. Bec se high radiatio 1 n the
/
\\ icinity of the lo r inlet doors during wer operation, this urveillance is normally perf med during a shutdown.
SR 3.6.13.6 (deleted)
SR 3.6.13.7 Verifying the OPERABILITY of the intermediate deck doors provides assurance that the intermediate deck doors are free to open in the event McGuire Unts 1 and 2 B 3.6.13-7 Revision N(11ý9
Ice Condenser Doors B 3.6.13 BASES SURVEILLANCE REQUIREMENTS (continued) of a DBA. The verification consists of visually inspecting the intermediate doors for structural deterioration, verifying free movement of the vent assemblies, and ascertaining free movement of each door when lifted with the applicable force shown below:
Door Lifting Force a.
b.
C.
d.
Adjacent to crane wall Paired with door adjacent to crane wall Adjacent to containment wall Paired with door adjacent to containment wall
< 37.4 lb
< 33.8 lb
< 31.8 lb
< 31.0 lb Th eqbsdon the_ asive design of the
/
n meit l*jýorte qe*ýf Cpersonnel entry othe te act ýh 3*.6.13.2 confi~r on a !7 day.
I/ FreqwUen ¥that.the doors are n imp~aired by ice, frett, or debris, whiph
- ar w/as adoor would fail th~E" opnngfrc (esLe.,
by sticking/*Yf ro0m
/
inr -ased door weight).
REFERENCES
- 1.
UFSAR, Chapter 6.
- 2.
- 3.
10 CFR 50.36, Technical Specifications, (c)(2)(ii).
- 4.
MCS-1558.NF-00-0001 "Design Basis Specification for the NF System".
McGuire Unts 1 and 2 B 3.6.13-8 Revision N q;8
AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.3
NOTES
- 1.
DG loadings may include gradual loading as recommended by the manufacturer.
- 2.
Momentary transients outside the load range do not invalidate this test.
- 3.
This Surveillance shall be conducted on only one DG at a time.
- 4.
This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
Verify each DG is synchronized and loaded and operates for Ž 60 minutes at a load Ž_ 3600 kW and < 4000 kW.
SR 3.8.1.4 Verify each day tank contains >_ 39 inches of fuel oil.
SR 3.8.1.5 Check for and remove accumulated water from each day K tank.
SR 3.8.1.6 Verify the fuel oil transfer system operates to automatically transfer fuel oil from storage tank to the day tank.
(continued)
McGuire Units 1 and 2 3.8.1-6 Amendment NoC5ý72 ý4
RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY i
SR 3.3.1.9 NOTES-Verification of setpoint is not required.
Perform TADOT.
SR 3.3.1.10 NOTES This Surveillance shall include verification that the time constants are adjusted to the prescribed values.
Perform CHANNEL CALIBRATION.
i4 SR 3.3.1.11 NOTES-
- 1.
Neutron detectors are excluded from CHANNEL CALIBRATION.
2-Power Range Neutron Flux high voltage detector saturation curve verification is not required to be performed prior to entry into MODE 1 or 2.
- 3.
Intermediate Range Neutron Flux detector plateau voltage verification is not required to be performed prior to entry into MODE 1 or 2.*
1 n/ont)~s Perform CHANNEL CALIBRATION.
)
SR 3.3.1.12 Perform CHANNEL CALIBRATION.
SR 3.3.1.13 Perform COT.
(continued)
- I This note applies to the Westinghouse-supplied compensated ion chamber neutron detectors. The compensated ion chamber neutron detectors are being replaced with Thermo Scientific-supplied fission chamber neutron detectors which do not require detector plateau voltage verification. Therefore, this note does not apply to the fission chamber neutron detectors.
McGuire Units 1 and 2 3.3.1-12 Amendment Nos.Q
RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification is accomplished during the CHANNEL CALIBRATION.
SR 3.3.1.10 A CHANNEL CALIBRATION is performed every 18 months. The CHANNEL CALIBRATION may be performed at power or during refueling based on testing capability. Channel unavailability evaluations in References 10 and 11 have conservatively assumed that the CHANNEL CALIBRAITON is performed at power with the channel in bypass.
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.
CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint methodology.
The Frequency of 18 months is based on the assumption of an 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.
SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. The applicable time constants are shown in Table 3.3.1-1.
SR 3.3.1.11 SR 3.3.1.11 is the performance o_2 dNEL CALIBRATION, as described in SR 3.3.1.10 -
yfno4tL'*s. Two notes modify this SR.
Note 1 states that neutron etectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The high voltage detector saturation curve is evaluated and compared to the manufacturer's data. The Westinghouse-supplied boron-triflouride (BF 3) source range neutron detectors and compensated ion chamber intermediate range neutron detectors are being replaced with Thermo Scientific-supplied fission chamber source and intermediate range neutron detectors. The CHANNEL CALIBRATION for the BF 3 source McGuire Units 1 and 2 B 3.3.1-52 Revision Na
RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued)
)-g 3K3./. /1 range neutron detectors consists of two methods. Method 1 consists of obtaining the discriminator curves for source range, evaluating those curves, and comparing the curves to the manufacturer's data (adjustments to the discriminator voltage are performed as required).
Method 2 consists of performing waveform analysis. This analysis process monitors the actual number and amplitude of the Neutron/Gamma pulses being generated by the SR detector. The high voltage is adjusted to optimize the amplitude of the pulses while maintaining as low as possible high voltage value in order to prolong the detector life. The discriminator voltage is then adjusted, as required, to reasonably ensure that the neutron pulses are being counted by the source range instrumentation and the unwanted gamma pulses are not being counted as neutron pulses.
The CHANNEL CALIBRATION for the compensated ion chamber intermediate range neutron detectors consists of the high voltage detector plateau for intermediate range, evaluating those curves, and comparing the curves to the manufacturer's data. The CHANNEL CALIBRATION for the fission chamber source and intermediate range neutron detectors consists of verifying that the channels respond correctly to test inputs with the necessary range and accuracy.
Note 2 states that this Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1. Note 3 applies to the compensated ion chamber intermediate range neutron detectors, and states that this Surveillance is not required to be performed for entry into MODE 2 or 1. Notes 2 and 3 are required because the unit must be in at least MODE 2 to perform the test for the compensated ion chamber intermediate range detectors and MODE 1 for the power range detectors.
mnthFrque**roJitrequenJ?.,
is based-on te need to perform ti SSurvei~nce under e conditions t-apply during a t outage and the pp po*ial for an/
planned tran~s Z~ if the Surveillce were perfor d
ith the rea or at power. 04rating experiee has shown th e
copo tsuully pasýZ'he ýSurveillance Wvhen performed,,n the 18 month Frequency.
For Functions for which TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions" (Reference 12) has been implemented, this SR is modified by two Notes as identified in Table 3.3.1-1. 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 McGuire Units 1 and 2 B 3.3.1-53 Revision Nq$
Containment Spray System 3.6.6 SURVEILLANCE FREQUENCY SR 3.6.6.2 Verify each containment spray pump's developed head at In accordance with the flow test point is greater than or equal to the required the Inservice developed head.
Testing Program SR 3.6.6.3 Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.6.6.4 Verify each containment spray pump starts automatically 1)m h
on an actual or simulated actuation signal.
SR 3.6.6.5 Verify that each spray pump is de-energized and prevented from starting upon receipt of a terminate signal and is allowed to start upon receipt of a start permissive from the Containment Pressure Control System (CPCS).
)
SR 3.6.6.6 Verify that each spray pump discharge valve closes or is prevented from opening upon receipt of a terminate signal and is allowed to open upon receipt of a start permissive from the Containment Pressure Control System (CPCS).
SR 3.6.6.7 Verify each spray nozzle is unobstructed.
Following activities which could result in nozzle blockage McGuire Units 1 and 2 3.6.6-2 Amendment No
Containment Spray System B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.6.3 and SR 3.6.6.4 These SRs require verification that each automatic containment spray valve actuates to its correct position and each containment spray pump starts upon receipt of an actual or simulated Containment Pressure High-High signal. This Surveillance is not required for valves that are locked,; sealed, or otherwise secured in the required position under administrative congl, survellancmayquency is tasf oth th o-ersorm eq e Surverf nces under thethnditicons that ayepu ly du isg a plan utage and re potential for aonplanned trachnt f the contan spwera pump stwatsto e
ise'-tornartpower.
perating fro anderminate hsi nas. T t
POse iso rie nteBae o C
[
"e**n.0 ts usually' pas he Su lacS eromd att P6 18 month Freeeency. Th fore,,.
cetab om r a reliabili y*
standpoint.
The surveillance of containment sump isolation valves is also required by SR 3.6.6.3. A single surveillance may be used to satisfy both
_f._-. *requirements.
usin a vauu blowe to. induc air flw.hruh.ac6ozlet These SRs require verification that each containment spray pump discharge vale opens or is prevented from opening and each containment spray pump starts or is de-energized and prevented from
~starting upon receipt of Containment Pressure Control System start.
and terminate tials TSR. Howeeribeds nsthe Bases foriLCO S R 3.6.6.7 With the containment sp fuid valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. The spray nozzles can also be tested using a vacuum blower to induce air flow through each nozzle to verify unobstructed flow. This SR requires verification that each spray nozzle is unobstructed following activities that could cause nozzle blockage. Normal plant operation and activities are not expected to initiate this SR. However, activities such as inadvertent spray actuation that causes fluid flow through the nozzles, major configuration change, or a loss of foreign material control when working within the respective system boundary, may require surveillance performance.
McGuire Units 1 and 2 B 3.6.6-6 Revision Nc X