Text

Selected Licensee Commitments Manual, Revision Date: 02/03/11
	ML111010387
Person / Time
Site:	Catawba
Issue date:	04/05/2011
From:	Hart R, Morris J, Pasour T; Duke Energy Corp
To:	; Office of Nuclear Reactor Regulation
References
	DUK110950002
	Download: ML111010387 (261)
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CHAPTER 16.7-2 CHAPTER 16.7-3 CHAPTER 16.9-1 CHAPTER 16.9-3 NA NA NA NA NA 047 004 002 006 003 03/24/11 03/24/11 03/24/11 03/24/11 03/24/11 CADM-03 vi V2 lV1 Vi V1 V1 V1 V1 V1 T1 V10 vi x

V26 V1 74 REMARKS: PLEASE REFER TO THE ATTACHED MEMO FOR FILING INSTRUCTIONS J R MORRIS VICE PRESIDENT CATAWBA NUCLEAR STATION BY:

T K PASOUR CNO1RC TKP/RJA A

Duke DUKE ENERGY CORPORATION Duke Catawba Nuclear Station r# Energy.

4800 Concord Rd.

York. SC 29745 March 24, 2011 Re:

Catawba Nuclear Station Selected Licensee Commitments Manual Revision Date: 02/03/11 Attached are revisions to the Catawba Nuclear Station Selected Licensee Commitments Manual. Please remove and replace the following pages:

REMOVE THESE PAGES INSERT THESE PAGES LIST OF EFFECTIVE SECTIONS Pages 1 through 4 Revision 46 Pages 1 through 4 Revision 47 TAB 16.7 SLC 16.7-2 Revision 3 SLC 16.7-3 Revision 1 SLC 16.9-1 Revision 5 SLC 16.9-3 Revision 2 SLC 16.7-2 Revision 4 SCL 16.7-3 Revision 2 SLC 16.9-1 Revision 6 SLC 16.9-3 Revision 3 TAB 16.9 If you have any questions concerning the contents of this package update, contact Toni Pasour at (803)701-3566.

Randy Hart Manager, Regulatory Compliance Attachment www. duke-energy. corn

LIST OF EFFECTIVE SECTIONS SECTION TABLE OF CONTENTS 16.1 16.2 16.3 16.5-1 16.5-2 16.5-3 16.5-4 16.5-5 16.5-6 16.5-7 16.5-8 16.5-9 16.5-10 16.6-1 16.6-2 16.6-3 16.6-4 16.6-5 16.7-1 16.7-2 16.7-3 16.7-4 16.7-5 REVISION NUMBER 12 1

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LIST OF EFFECTIVE SECTIONS SECTION 16.7-6 16.7-7 16.7-8 16.7-9 16.7-10 16.7-11 16.7-12 16.7-13 16.7-14 16.7-15 16.7-16 16.8-1 16.8-2 16.8-3 16.8-4 16.8-5 16.9-1 16.9-2 16.9-3 16.9-4 16.9-5 16.9-6 16.9-7 16.9-8 REVISION NUMBER 2

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Catawba Units 1 and 2 Page 2 Revision 47

LIST OF EFFECTIVE SECTIONS SECTION 16.9-9 16.9-10 16.9-11 16.9-12 16.9-13 16.9-14 16.9-15 16.9-16 16.9-17 16.9-18 16.9-19 16.9-20 16.9-21 16.9-22 16.9-23 16.9-24 16.9-25 16.10-1 16.10-2 16.10-3 16.11-1 16.11-2 16.11-3 16.11-4 REVISION NUMBER 3

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LIST OF EFFECTIVE SECTIONS SECTION 16.11-5 16.11-6 16.11-7 16.11-8 16.11-9 16.11-10 16.11-11 16.11-12 16.11-13 16.11-14 16.11-15 16.11-16 16.11-17 16.11-18 16.11-19 16.11-20 16.11-21 16.12-1 16.13-1 16.13-2 16.13-3 16.13-4 REVISION NUMBER 0

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REVISION DATE 10/09/02 06/08/09 06/23/10 10/09/02 10/09/02 08/21/09 03/20/03 10/09/02 10/09/02 10/09/02 10/09/02 10/09/02 10/09/02 08/21/09 10/09/02 08/21/09 10/09/02 10/09/02 10/09/02 10/09/02 Catawba Units 1 and 2 Page 4 Revision 47

Seismic Instrumentation 16.7-2 16.7 INSTRUMENTATION 16.7-2 Seismic Instrumentation COMMITMENT APPLICABILITY:

The seismic monitoring instrumentation shown in Table 16.7-2-1 shall be FUNCTIONAL.

At all times.

REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required A.1 Restore non-functional 30 days seismic monitoring instrument(s) to instrument(s) non-FUNCTIONAL status.

functional.

OR A.2 Prepare and submit a 40 days Special Report to the Commission outlining the cause of the malfunction and the plans for restoring the instrument(s) to FUNCTIONAL status.

B.

Accessible seismic B. 1 Restore instrument(s) to Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months monitoring instrument(s)

FUNCTIONAL status.

following the seismic actuated during a event seismic event > 0.01 g.

AND B.2 Retrieve data from Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actuated instrument(s) and following the seismic analyze to determine event magnitude of vibratory ground motion.

AND (continued)

Catawba Units 1 and 2 16.7-2-1 Revision 4

Seismic Instrumentation 16.7-2 REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.3 Prepare and submit a 10 days Special Report to the Commission describing the magnitude, frequency spectrum, and resultant effect upon facility features important to safety.

TESTING REQUIREMENTS NOTE Refer to Table 16.7-2-1 to determine which TRs apply for each seismic instrument.

TEST FREQUENCY TR 16.7-2-1

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

CHANNEL CHECK not required for seismic trigger of 1IEEVD 1030 or 1IEEVD 1040.

Perform CHANNEL CHECK.

14 days for first 3 months of service after initial system startup AND 31 days thereafter TR 16.7-2-2 Perform COT.

6 months TR 16.7-2-3 Perform CHANNEL CALIBRATION.

18 months Catawba Units 1 and 2 16.7-2-2 Revision 4

Seismic Instrumentation 16.7-2 Table 16.7-2-1 Seismic Monitoring Instrumentation INSTRUMENTS AND SENSOR MEASUREMENT REQUIRED TESTING LOCATIONS RANGE CHANNELS REQUIREMENTS

1.

Triaxial Accelerographs l.a 11EEVD 1020 (Remote

-2 g to +2 g 1 (1)

TR 16.7-2-1 Sensor A) Unit 1 TR 16.7-2-2 Containment Base Slab TR 16.7-2-3 Elev. 553' 0" 1.b 11EEVD 1010 (Remote

-2 g to +2 g 1(1)

TR 16.7-2-1 Sensor B) Unit 1 AFW TR 16.7-2-2 Pump Room Elev. 544' TR 16.7-2-3 0"

1.c 11EEVD 1000 Control

-2 g to +2 g 1 i" TR 16.7-2-1 Room Elev. 595' 0" TR 16.7-2-2 TR 16.7-2-3 1.d 1IEEVD 1030 Unit 1

-2 g to +29 1g )

TR 16.7-2-2 Containment Bldg. Elev.

TR 16.7-2-3 652' 0", Azimuth 00 1.e 1IEEVD 1040 Unit 1

-2 g to +29 1 "

TR 16.7-2-2 Containment Bldg. Elev.

TR 16.7-2-3 612' 10", Azimuth 00 (1) With reactor control room indication.

Catawba Units 1 and 2 16.7-2-3 Revision 4

Seismic Instrumentation 16.7-2 BASES The FUNCTIONALITY of the seismic monitoring instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for the facility to determine if plant shutdown is required pursuant to Appendix A of 10 CFR Part 100. The instrumentation is consistent with the recommendations of Regulatory Guide 1.12, "Nuclear Power Plant Instrumentation for Earthquakes", Revision 2.

The seismic monitoring instrumentation system records seismic data acquired by five triaxial accelerographs (at locations per Table 16.7-2-1, Items 1.a through 1.e); each accelerograph consists of a solid state recording device (using static random access memory (SDRAM) storage) and an integral micro electro-mechanical sensor (or MEMS accelerometer).

All five accelerographs are connected to the network control center (NCC) 11 EECS 1000 located in the control room (on the 1 MC8 back panel, near 1 IEEVD 1000). The NCC provides a centralized location for: on-line system monitoring (including continuous self-checking of significant functions and power supply status); data retrieval from each accelerograph; data transfer (download) to the dedicated system computer 1 IEECO 9000 for required analysis purposes (i.e., analysis required following a seismic event); system status indications (associated with the NCC and all five accelerographs);

date/time synchronization (for each accelerograph); and generation of a common "start recording" trigger command (to all accelerographs) in the event that a trigger acceleration threshold is exceeded on two (2) of the three (3) accelerographs required for generation of the Operating Basis Earthquake (OBE) exceedance signal. The required channels for generation of the OBE exceedance signal are: 11EEVD 1000 (control room); 1IEEVD 1010 (Unit 1 AFW pump room); and 1IEEVD 1020 (Unit 1 annulus). System failures will result in an alarm condition on the NCC and a remote alarm sent to the Unit 1 Operator Aid Computer.

The two upper containment accelerographs (1IEEVD 1030 and 1IEEVD 1040) were excluded from the CHANNEL CHECK required by TR 16.7-2-1, since they are not used to generate the OBE exceedance signal (indicated by the Unit 1 control room annunciator system). The other three accelerographs were chosen since they are either: 1) located at the base of a Category 1 structure (1IEEVD 1010 and 1IEEVD 1020), consistent with measurement locations per Regulatory Guide 1.12 guidance; or 2) within the control room area (11 EEVD 1000), to confirm that the seismic event was felt by operators.

REFERENCES

1.

10 CFR Part 100, Appendix A.

2.

Regulatory Guide 1.12, "Nuclear Power Plant Instrumentation for Earthquakes", Revision 2, March 1997.

3.

Catawba Updated Final Safety Analysis Report, Section 3.7.4, "Seismic Instrumentation Program".

Catawba Units 1 and 2 16.7-2-4 Revision 4

Meteorological Instrumentation 16.7-3 16.7 INSTRUMENTATION 16.7-3 Meteorological Instrumentation COMMITMENT

a.

The meteorological monitoring instrumentation channels shown in Table 16.7-3-1 shall be FUNCTIONAL.

AND

b.

The meteorological monitoring instrumentation channels shown in Table 16.7-3-2 shall be maintained to ensure 90%

data recovery on an annual basis.

APPLICABILITY:

At all times.

REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required A.1 Restore non-functional 7 days meteorological channel(s) to monitoring channel(s)

FUNCTIONAL status.

non-functional.

OR A.2 Prepare and submit a 17 days Special Report to the Commission outlining the cause of the malfunction and the plans for restoring the channel(s) to FUNCTIONAL status.

B.

One or more required B.1 Prepare and submit a Within 10 days of meteorological Special Report to the determining the monitoring channel(s)

Commission outlining the missed requirement having < 90% annual cause of the deficiency and data recovery, the plans for restoring the annual data recovery goals.

Catawba Units 1 and 2 16.7-3-1 Revision 2

Meteorological Instrumentation 16.7-3 TESTING REQUIREMENTS

NOTE Refer to Table 16.7-3-1 to determine which TRs apply for each meteorological instrument.

TEST FREQUENCY TR 16.7-3-1 Perform CHANNEL CHECK.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TR 16.7-3-2 Perform instrument calibration.

6 months Catawba Units 1 and 2 16.7-3-2 Revision 2

Meteorological Instrumentation 16.7-3 Table 16.7-3-1 Meteorological Monitoring Instrumentation INSTRUMENT AND LOCATION REQUIRED TESTING CHANNELS REQUIREMENTS

1.

Wind Speed 1.a Meteorological Tower Nominal 1

TR 16.7-3-1 Elev. 663.5' TR 16.7-3-2 1.b Meteorological Tower Nominal 1

TR 16.7-3-1 Elev. 830.5' TR 16.7-3-2

2.

Wind Direction 2.a Meteorological Tower Nominal 1

TR 16.7-3-1 Elev. 663.5' TR 16.7-3-2 2.b Meteorological Tower Nominal 1

TR 16.7-3-1 Elev. 830.5' TR 16.7-3-2

3.

Air Temperature 3.a Ambient Meteorological Tower 1

TR 16.7-3-1 Nominal Elev. 660.25' TR 16.7-3-2 3.b Delta Temperature Meteorological 1

TR 16.7-3-1 Tower Nominal Elev. 827.25-TR 16.7-3-2 660.25'

4.

Precipitation (l) 4.a Precipitation Sensor Pad (Near 1

TR 16.7-3-1 Meteorological Tower) Nominal TR 16.7-3-2 Elev. 630.0' (1)

Not required by Regulatory Guide 1.23, Revision 0.

Catawba Units 1 and 2 16.7-3-3 Revision 2

Meteorological Instrumentation 16.7-3 Table 16.7-3-2 Meteorological Monitoring Instrumentation Data Recovery Requirements INSTRUMENT AND LOCATION

1.

60M Joint Data Recovery 1.a Wind Speed Nominal Elev. 830.5' 1.b Wind Direction Nominal Elev.

830.5' 1.c Delta Temperature Nominal Elev.

827.25-660.25'

2.

10M Joint Data Recovery 2.a Wind Speed Nominal Elev. 663.5' 2.b Wind Direction Nominal Elev.

663.5' 2.c Delta Temperature Nominal Elev.

827.25-660.25'

3.

Ambient Air Temperature Nominal Elev. 660.25'

4.

Precipitation Nominal Elev. 630.0' TYPE Joint Joint Individual Individual Catawba Units 1 and 2 16.7-3-4 Revision 2

Meteorological Instrumentation 16.7-3 BASES The FUNCTIONALITY of the meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation doses to the public as a result of routine or accidental release of radioactive materials to the atmosphere. This capability is required to evaluate the need for initiating protective measures to protect the health and safety of the public and is consistent with the recommendations of Regulatory Guide 1.23, "Onsite Meteorological Programs," February 1972, for wind speed, wind direction, and air temperature at two elevations. Precipitation is not required by Regulatory Guide 1.23, Revision 0. However, it is monitored since it is used by the model for offsite dose assessment calculations.

The regulatory guide states that in lieu of providing redundant digital recorders, digital outputs may be supplemented by strip chart recorders to minimize possible loss of data due to instrument malfunction. Thus, the strip chart recorder in the control room is required in order to comply with the regulatory guide.

An instrument calibration will consist of the following test:

1) A bench based test, certification, and/or calibration of the tower mounted sensors for:

wind speed wind direction ambient and delta temperature RTDs

2) An instrument loop calibration from the input of the signal processors to the end devices. The identification of an out-of-tolerance condition or failure of a component within the instrument loop renders the channel non-functional until the component is calibrated or repaired/replaced.

3) For wind direction a line phase differential compensation will be performed, which includes the tower signal cable.

4) For precipitation, a measured volume of water will be poured into the sensor and the signal conditioner module's output verified correct.

5) A CHANNEL CHECK, subsequent to any work performed. This will verify continuity of the signal cable between the sensor and signal processors.

6) The wind speed sensors and cup-sets or wind direction sensors and vanes do not require wind tunnel testing as an assembly.

7) Replacement of cup-sets or vanes does not require an instrument calibration of the affected channel.

The greater than or equal to 90% annual data recovery requirement is to ensure that the meteorological instrumentation is maintained to minimize extended periods of instrument outage. The reporting cycle is a calendar year (January 1 through December 31). A 60-day period from the end of the calendar year is allowed for data reduction, validation, and data quality assurance, before the data recovery report is generated.

Catawba Units 1 and 2 16.7-3-5 Revision 2

Meteorological Instrumentation 16.7-3 BASES (continued)

The 90% data recovery is a statistical analysis of the respective data for the required parameters. This analysis includes out-of-service time resulting from components being in Condition A of this SLC and routine calibration/servicing time.

REFERENCES

1.

Regulatory Guide 1.23, Revision 0.

Catawba Units 1 and 2 16.7-3-6 Revision 2

Fire Suppression Water System 16.9-1 16.9 AUXILIARY SYSTEMS 16.9-1 Fire Suppression Water System COMMITMENT The Fire Suppression Water System shall be FUNCTIONAL with:

a.

At least two fire suppression pumps, each with a capacity of 2500 gpm, with their discharge aligned to the fire suppression header, and

b.

A FUNCTIONAL flow path capable of taking suction from Lake Wylie and transferring the water through distribution piping with FUNCTIONAL sectionalizing control valves and isolation valves for each sprinkler system, hose standpipe, or fire hydrant required to be FUNCTIONAL per SLCs 16.9-2, 16.9-4, and 16.9-23.

APPLICABILITY:

At all times.

Catawba Units 1 and 2 16.9-1-1 Revision 6

Fire Suppression Water System 16.9-1 REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required pump A.1 Restore non-functional 7 days and/or associated water equipment to supply non-functional.

FUNCTIONAL status.

OR A.2 Provide alternate backup 7 days pump or supply.

B.

Automatic starting B.1 Place at least one pump in Immediately function for all required continuous operation.

pumps non-functional.

AND B.2 Restore non-functional 7 days equipment to FUNCTIONAL status.

C.

Fire Suppression Water C.1 Establish backup Fire 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months System non-functional Suppression Water for reasons other than System.

Condition A or B.

Catawba Units 1 and 2 16.9-1-2 Revision 6

Fire Suppression Water System 16.9-1 TESTING REQUIREMENTS TEST FREQUENCY TR 16.9-1 -1 Start each electric motor-driven pump and operate it for 20 days on a

> 15 minutes on recirculation flow.

STAGGERED TEST BASIS TR 16.9-1-2 Verify that each manual, power operated, or automatic In accordance with valve in the flow path, which is accessible during plant performance operation, is in the correct position.

based criteria in BASES TR 16.9-1-3 Perform a system flush of the outside distribution loop 6 months and verify no flow blockage by fully opening the hydraulically most remote hydrant.

TR 16.9-1-4

NOTE Not applicable to valves RF389B, RF447B, and RF457B.

Cycle each testable valve in the flow path through at 12 months least one complete cycle of full travel.

TR 16.9-1-5 Verify that each manual, power operated, or automatic 18 months valve in the flow path, which is inaccessible during plant operation, is in the correct position.

TR 16.9-1-6 Perform a system functional test, including simulated 18 months automatic actuation of the system throughout its operating sequence, and:

a.

Verify that each fire suppression pump starts within 10 psig of its intended starting pressure (A pump, primary switch - 95 psig; B pump, primary switch - 90 psig; and C pump, primary switch -

85 psig); and

b.

Verify that each pump develops > 2500 gpm at a net pressure > 144 psig by testing at three points on the pump performance curve.

(continued)

Catawba Units 1 and 2 16.9-1-3 Revision 6

Fire Suppression Water System 16.9-1 TESTING REQUIREMENTS (continued)

TEST FREQUENCY TR 16.9-1-7 Cycle each valve in the flow path which is not testable 18 months during plant operation through at least one complete cycle of full travel.

TR 16.9-1-8 Perform a system flow test in accordance with Chapter 8, 3 years Section 16 of the National Fire Protection Association Fire Protection Handbook, 15th Edition.

BASES The FUNCTIONALITY of the Fire Suppression Systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located. The Fire Suppression System consists of the water water supply/distribution system, sprinkler systems, fire hose stations, fire hydrants, and CO 2 systems. The collective capability of the Fire Suppression Systems is adequate to minimize potential damage to safety related equipment and is a major element in the facility Fire Protection Program.

The intent of COMMITMENT b. is to ensure a FUNCTIONAL flow path from the water source (in this case Lake Wylie), through FUNCTIONAL pumps as required in COMMITMENT a., and through the main header distribution piping - up to but not including the branch lines for each sprinkler system, hose standpipe, or fire hydrant required to be FUNCTIONAL per SLCs 16.9-2, 16.9-4, and 16.9-23. When a sectionalizing control valve or an isolation valve becomes non-functional, then the fire suppression features (sprinkler system, hose standpipe, or fire hydrant) affected must be evaluated and the applicable SLC entered (16.9-2, 16.9-4, or 16.9-23). COMMITMENT b. of this SLC would only apply if a non-functional sectionalizing valve(s) or isolation valve(s) rendered the entire main distribution piping non-functional.

The ability to demonstrate that the valves in the RF/RY flow path can be cycled is critical to maintaining the system properly. The containment isolation valves (RF389B and RF447B) and the annulus sprinkler system isolation valve (RF457B) are required to be cycled or stroked in accordance with the Catawba Inservice Testing Program. Therefore, credit can be taken for cycling these valves under the IWV program, and they do not need to be cycled annually to meet the SLC criteria.

The proper positioning of RF/RY valves is critical to delivering fire suppression water at the fire source as quickly as possible. The option of Catawba Units 1 and 2 16.9-1-4 Revision 6

Fire Suppression Water System 16.9-1 BASES (continued) increasing or decreasing the frequency of valve position verification allows the ability to optimize plant operational resources. Should an adverse trend develop with RF/RY valve positions, the frequency of verification shall be increased. Similarly, if the RF/RY valve position trends are positive, the frequency of verification could be decreased.

Through programmed trending of RF/RY as found valve positions, the RF/RY System will be maintained at predetermined reliability standards.

The Fire Protection Engineer is responsible for trending and determining verification frequencies based on the following:

Initially the frequency shall be monthly.

Annually review the results of the completed valve position verification procedures.

If the results demonstrate that the valves are found in the correct position at least 99% of the time, the frequency of conducting the valve position verification may be decreased from monthly to quarterly or quarterly to semiannually or semiannually to annually as applicable. The frequency shall not be extended beyond annually (plus grace period).

If the results demonstrate that the valves are not found in the correct position at least 99% of the time, the frequency of conducting the valve position verification shall be increased from annually to semiannually or semiannually to quarterly or quarterly to monthly as applicable. The valve position verification need not be conducted more often than monthly.

In the event that portions of the Fire Suppression Systems are non-functional, alternate backup fire fighting equipment is required to be made available in the affected areas until the non-functional equipment is restored to service. When the non-functional fire fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed to provide an alternate means of fire fighting than if the non-functional equipment is the primary means of fire suppression.

In the event the Fire Suppression Water System becomes non-functional, immediate corrective measures must be taken since this system provides the major fire suppression capability of the plant.

Since the requirement for fire suppression pump automatic starting functions is intended to provide a high level of system standby readiness, loss of a primary pressure switch renders its associated main fire pump non-functional. If the primary pressure switch for one of the two required pumps is non-functional, its associated pump is non-functional if not placed in continuous operation and Condition A applies. If both primary Catawba Units 1 and 2 16.9-1-5 Revision 6

Fire Suppression Water System 16.9-1 BASES (continued) pressure switches for the required pumps are non-functional, it is acceptable to place at least one of the two required pumps in continuous operation and restore FUNCTIONALITY within 7 days, which is essentially meeting the requirements of Condition A (one of the two required pumps non-functional).

This SLC is part of the Catawba Fire Protection Program and therefore subject to the provisions of the Catawba Facility Operating License Conditions #8 for NPF-35 and #6 for NPF-52.

REFERENCES

1.

Catawba UFSAR, Section 9.5.1.

2.

Catawba SER, Section 9.5.1, including Supplements 2, 3, 4, and 5.

3.

Catawba Plant Design Basis Specification for Fire Protection, CNS-1465.00-00-0006, as revised.

4.

Catawba UFSAR, Section 18.2.8.

5.

Catawba License Renewal Commitments, CNS-1274.00 0016, Section 4.12.1.

Catawba Units 1 and 2 16.9-1-6 Revision 6

CO 2 Systems 16.9-3 16.9 AUXILIARY SYSTEMS 16.9-3 C0 2 Systems COMMITMENT The following High Pressure and Low Pressure C02 Systems shall be FUNCTIONAL:

a.

Low Pressure C02 System - diesel generator rooms, and

b.

High Pressure CO 2 System - auxiliary feedwater pump rooms.

Whenever equipment protected by the systems is required to be OPERABLE.

APPLICABILITY:

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

Non-functional or breached fire barrier features (walls, floors, ceilings, doors, dampers, and penetration seals) affect C02 System FUNCTIONALITY, since openings affect the ability to achieve and maintain C02 concentrations within the room.

Catawba Units 1 and 2 16.9-3-1 Revision 3

C02 Systems 16.9-3 REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Low A. 1.1 Verify fire barrier between 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Pressure CO 2 Systems Train A and Train B diesel non-functional.

generator rooms is FUNCTIONAL.

AND A.1.2 Verify backup fire 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months suppression equipment is available.

AND A.1.3 Establish hourly fire watch.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR A.2 Establish continuous fire 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months watch.

B.

One or more High B.1 Establish continuous fire 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Pressure C02 Systems watch.

non-functional.

Catawba Units 1 and 2 16.9-3-2 Revision 3

CO 2 Systems 16.9-3 TESTING REQUIREMENTS TEST FREQUENCY TR 16.9-3-1 Verify that each manual, power operated, or automatic In accordance with valve in the flow path is in the correct position.

performance based criteria in BASES TR 16.9-3-2 Verify that the Low Pressure CO 2 System storage tank 31 days level is > 44% of full capacity.

TR 16.9-3-3 Verify that the weight of each High Pressure CO 2 System 6 months storage cylinder is > 90% of full charge weight.

TR 16.9-3-4 Perform a visual inspection of all spot type heat 6 months detectors in each initiating device circuit.

TR 16.9-3-5

NOTE A different detector shall be selected for each test.

Simulate system actuation by applying a heat source to 6 months one restorable spot type heat detector in each initiating device circuit.

TR 16.9-3-6 Verify that the supervisory function of the alarm circuits 6 months operates properly and provides correct alarm response for each initiating device circuit.

TR 16.9-3-7 Verify each Low Pressure CO 2 System actuates 18 months manually and automatically, upon receipt of a simulated actuation signal.

TR 16.9-3-8 Verify that the Low Pressure CO2 System normal and 18 months emergency ventilation system fans receive an "off' signal upon system operation.

(continued)

Catawba Units 1 and 2 16.9-3-3 Revision 3

C02 Systems 16.9-3 TESTING REQUIREMENTS (continued)

TEST FREQUENCY TR 16.9-3-9 Perform a visual inspection of the Low Pressure C02 18 months System discharge nozzles to assure no blockage.

TR 16.9-3-10 Verify each High Pressure C02 System actuates 18 months manually and automatically, upon receipt of a simulated actuation signal.

TR 16.9-3-11 Verify that damper closure devices receive an actuation 18 months signal upon High Pressure C02 System operation.

TR 16.9-3-12 Perform a visual inspection of the High Pressure C02 18 months System discharge nozzles to assure no blockage.

TR 16.9-3-13 Deleted.

BASES The FUNCTIONALITY of the Fire Suppression Systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located. The Fire Suppression System consists of the water supply/distribution system, sprinkler systems, fire hose stations, fire hydrants, and C02 systems. The collective capability of the Fire Suppression Systems is adequate to minimize potential damage to safety related equipment and is a major element in the facility Fire Protection Program.

The proper positioning of RF/RY valves is critical to delivering fire suppression C02 at the fire source as quickly as possible. The option of increasing or decreasing the frequency of valve position verification allows the ability to optimize plant operational resources. Should an adverse trend develop with C02 Systems valve positions, the frequency of verification shall be increased. Similarly, if the C02 Systems valve position trends are positive, the frequency of verification could be decreased. Through programmed trending of C02 Systems as found valve positions, the C02 fire protection systems will be maintained at predetermined reliability standards. The Fire Protection Engineer is responsible for trending and determining verification frequencies based on the following:

Catawba Units 1 and 2 16.9-3-4 Revision 3

C02 Systems 16.9-3 BASES (continued)

Initially the frequency shall be monthly.

Annually review the results of the completed valve position verification procedures.

If the results demonstrate that the valves are found in the correct position at least 99% of the time, the frequency of conducting the valve position verification may be decreased from monthly to quarterly or quarterly to semiannually or semiannually to annually as applicable. The frequency shall not be extended beyond annually (plus grace period).

If the results demonstrate that the valves are not found in the correct position at least 99% of the time, the frequency of conducting the valve position verification shall be increased from annually to semiannually or semiannually to quarterly or quarterly to monthly as applicable. The valve position verification need not be conducted more often than monthly.

The main bank (9 cylinders) or the reserve bank (9 cylinders) provides a sufficient quantity of C02 to totally flood any of the three auxiliary feedwater pump pits with the required design concentration. Therefore, the High Pressure C02 System is FUNCTIONAL with the system aligned to either the main or the reserve bank of cylinders. The system is aligned to the main or reserve bank of cylinders by means of a local manual toggle switch.

In the event that portions of the Fire Suppression Systems are non-functional, alternate backup fire fighting equipment is required to be made available in the affected areas until the non-functional equipment is restored to service. When the non-functional fire fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed to provide an alternate means of fire fighting than if the non-functional equipment is the primary means of fire suppression.

This SLC is part of the Catawba Fire Protection Program and therefore subject to the provisions of the Catawba Facility Operating License Conditions #8 for NPF-35 and #6 for NPF-52.

REFERENCES

1.

Catawba UFSAR, Section 9.5.1.

2.

Catawba SER, Section 9.5.1, including Supplements 2, 3, 4, and 5.

3.

Catawba Plant Design Basis Specification for Fire Protection, CNS-1465.00-00-0006, as revised.

Catawba Units 1 and 2 16.9-3-5 Revision 3

ML111010387

Text

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