MNS-14-043, (Mns), Units 1 and 2, Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-12-049

(Mns), Units 1 and 2, Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-12-049

ML14161A231
Person / Time
Site:	McGuire, Mcguire
Issue date:	05/20/2014
From:	Capps S Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, MNS-14-043, TAC MF2741, TAC MF2742
Download: ML14161A231 (19)

Text

Steven D. Capps Vice President gd DUKE McGuire Nuclear Station

ENERGY, Duke Energy MG01VP 112700 Hagers Ferry Road Huntersville, NC 27078 o: 980-875-4805 f: 980-875-4809 Steven.Capps@duke-energy.com May 20, 2014 Serial: MNS-14-043 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17 Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-1 2-049 (TAC Nos. MF 2741, 2742)

REFERENCES:

1. Letter dated September 12, 2013 from Duke Energy to NRC, License Amendment Request for a revision to Technical Specification 3.3.2 in support of NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", dated March 12, 2012 (Adams Accession No.) ML13262A500

2. Letter dated April 9, 2014 from NRC to Duke Energy, "Request for Additional Information" Regarding License Amendment Request to Modify Technical Specification 3.3.2 Setpoint. ML14097A118

3. Letter dated April 28, 2014 from NRC to Duke Energy, "Request for Additional Information" Regarding License Amendment Request to Modify Technical Specification 3.3.2 Setpoint. ML14114A526 In Reference 1, Duke Energy submitted a LAR for a revision to Technical Specification 3.3.2 in support of NRC Order EA-12-049.

In References 2 and 3, the NRC transmitted Requests for Additional Information (RAIs) regarding the LAR.

The purpose of this letter is to respond to the Reference 2 and 3 RAI letter questions. The attachments to this letter constitute McGuire's response. The format for each RAI response attachment is to restate the RAI question, followed by the appropriate response. An additional attachment is included with a markup of the most current revision of the affected TS page which has been revised since the September 12, 2013 submittal of this LAR.

A4 5'

U.S. Nuclear Regulatory Commission May 20, 2014 Page 2 There are no regulatory commitments contained in this letter or its attachments.

If you have any questions or require additional information, please contact George Murphy at (980) 875-5715.

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

Executed on May 20, 2014.

Sincerely, Steven D. Capps Attachments:

1. Reference 2 RAI Questions and Responses

2. Reference 3 RAI Questions and Responses

3. Markup of Current Revision of the Affected TS Page (3.3.2-14) after Amendment 272/252 Implementation

U.S. Nuclear Regulatory Commission May 20, 2014 Page 3 xc:

V.M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 E.J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 0-8C2A 11555 Rockville Pike Rockville, MD 20852-2738 G.E. Miller, Project Manager (MNS and CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

ATTACHMENT 1 Reference 2 RAI Questions and Responses

Page 2 of 10 ATTACHMENT 1 REQUEST FOR ADDITIONAL INFORMATION MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATION 3.3.2 IN SUPPORT OF COMPLIANCE WITH NRC ORDER EA-12-049 DOCKET NOS. 50-369 AND 50-370 By letter dated September 12, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13262A500), Duke Energy Carolinas submitted a license amendment request (LAR) to amend the Technical Specifications (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," FUNCTION 6.f, "Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low (c)" for McGuire Nuclear Station, Units 1 and 2, in support of plant modifications required to achieve compliance with the NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements of Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

In order for the NRC staff to complete its review of the LAR, the following additional information is requested.

Page 3 of 10 ATTACHMENT 1

1. Provide an overall summary of calculations performed including the various tolerances used in calculating the total loop uncertainties, reference accuracy, and drift indicating how they comply with applicable requirements of this request (e.g., General Design Criterion (GDC) 13, GDC 20, and 10 CFR 50.36(c)(1)(ii)(a)). Please ensure that the summary indicates how all these tolerances comply with the 95/95 confidence level specified in RG 1.105.

RAI #1 Response:

The auxiliary feedwater suction automatic transfer signal is sensed by mechanical process pressure switches. The pressure switch uncertainty analyses included the following vendor specified device uncertainty contributions:

Uncertainty Vendor Specified Uncertainty Contribution Comments Contribution Repeatability

+/-1.0 %span Drift

+/-2.5% span annually See Note 1 Temperature Effect

+/-(psi setpoint)x(0.0003/°F)(delta-T)

NOTES:

1) The annual vendor drift value was conservatively extrapolated to envelope the maximum actual calibration interval (treated as random-independent over the vendor specified drift interval). A historical drift study of -100 calibrations for a similar model switches, demonstrated the instrument drift was random and independent of time, and that the vendor specified drift magnitude enveloped the actual observed drift magnitude with a 95/95 confidence interval. The extrapolated drift value utilized in the uncertainty analyses was based on the maximum calibration interval and readily envelopes the vendor specified annual drift magnitude.

The vendor specified instrument uncertainty contributions were presumed to represent a 95/95 confidence interval, in the absence of information to the contrary. The vendor specified uncertainty contributions were treated as random-independent effects.

In addition to the vendor specified uncertainty contributions, uncertainty contributions were included for the following:

Calibration setting tolerance, Measuring and Test Equipment, Process measurement uncertainties for density variations and water-leg measurement, Seismic uncertainty The instrument uncertainty contributions for calibration setting tolerance and measuring and test equipment effects were treated as random-independent effects. The process measurement and seismic uncertainty allowances were conservatively treated as bi-directional biases.

Page 4 of 10 ATTACHMENT 1 These individual uncertainty contributions were combined within the uncertainty analyses based on the methods described by ISA-$67.04-1994, "Setpoints for Nuclear Safety-Related Instrumentation," as endorsed by RG 1.105. The random independent terms were combined by the square-root-sum-of-the-squares method, and the result was then algebraically increased by the magnitude of the bias terms.

General Design Criterion 13 for Instrumentation and Control states:

"Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the Containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

DISCUSSION:

The proposed modifications in this amendment request do not compromise the ability to monitor important variables and systems. The proposed modification will continue to ensure adequate suction source is maintained for the Auxiliary Feedwater pumps, and thereby serve to ensure the system is maintained within the prescribed operating range. The proposed changes to adopt TSTF-493 as-found and as-left tolerance requirements further serve to ensure that the instrumentation and Auxiliary Feedwater pumps will operate within the bounds defined in the Safety Analysis.

General Design Criterion 20 for Protection System Functions:

"The protection system shall be designed:

1. To initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences, and

2. To sense accident conditions and to initiate the operation of systems and components important to safety."

DISCUSSION:

The proposed modifications in this amendment request do not affect the ability of the protection system to sense accident conditions and automatically initiate operation of systems and components important to safety. The proposed changes will continue to ensure an adequate suction source is maintained for the Auxiliary Feedwater pumps. The proposed changes to adopt TSTF-493 as-found and as-left tolerance requirements further serves to ensure that the instrumentation and Auxiliary Feedwater system will operate within the bounds defined in the Safety Analysis.

Page 5 of 10 ATTACHMENT 1 10 CFR 50.36(c)(1)(ii)(A) states in part:

"Limiting safety system settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions.

Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. If, during operation, it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor.....

DISCUSSION:

The proposed modifications in this amendment request will continue to ensure that an adequate suction source is maintained for the Auxiliary Feedwater pumps, and thereby continue to ensure that safety limits are not exceeded. The Technical Specification Nominal Trip Setpoint, Allowable Value, and TSTF-493 tolerance requirements for the Auxiliary Feedwater Pump Suction transfer instrumentation serve to ensure the system will operate within the bounds defined in the Safety Analysis.

Page 6 of 10 ATTACHMENT 1

2. Provide representative plant procedures to demonstrate how the plant procedures comply with the TSTF-493 footnotes.

RAI #2 Response:

The following guidance is excerpted from procedure IP/1/A/3050/013 E, RWST Class 1E Level Transmitter Loop Calibration (1 FWLP5010) Channel I which reflects how the Technical Specification TSTF-493 footnotes have been incorporated into the calibration procedure.

Similar calibration procedure changes will be implemented for the Auxiliary Feedwater pump suction pressure switches addressed by Technical Specification Table 3.3.2-1.

2.3 Procedure Footnotes NOTE:

Footnotes are indicated in procedure by {Fn} at end of applicable step, where n is one of the following reference step numbers.

2.3.9 Adoption of Technical Specification Task Force (TSTF), TSTF-493, Rev. 004, July 13, 2009, "Clarification Application of Setpoint Methodology for LSS Functions" for Tech Spec 3.3.2 FWST Lo Level Auto-swapover Function, requires entry into Corrective Action Program (PIP) IF FWST Lo Level Auto-Swapover Function setpoint found outside "Allowable As-Found (AF) Tolerance".

2.3.10 TSTF-493, Rev. 004, July 13, 2009, allows technician to assess response of LSS Function instrumentation DURING surveillance for As-Found (AF) data outside As Found tolerance, but conservative to Tech Spec Allowable Value. Technician assessment is independently reviewed within Corrective Action Program (PIP) by Engineering. The Independent Review for above condition is required PRIOR to returning channel to service, and shall consider historical performance of instrumentation.

2.3.11 TSTF-493, Rev. 004, July 13, 2009, requires Operability Evaluation for Tech Spec Tech Spec 3.3.2 FWST Low Level Auto-Swapover Function PRIOR to return to service IF As-Found (AF) data is found non-conservative to Tech Spec Allowable Value.

Page 7 of 10 ATTACHMENT 1

5.

Limits And Precautions 5.12 IF As Found data for FWST Low Level Auto-Swapover Function (1 FWEM501 1, K1 relay) is NOT within Allowable As Found Tolerance but is within Technical Specification Allowable Value, a PIP shall be written to comply with TSTF-493 Safety Limit Limiting Safety System Setting. {F2.3.9}

5.13 IF As Found data for FWST Low Level Auto-Swapover Function (1FWEM5011, K1 relay) is found NOT within Allowable As Found Tolerance but is within Technical Specification Allowable Value, a determination will be performed by both the Maintenance technicians and Engineering concurrently PRIOR to returning channel to service utilizing available information to ensure channel will perform as expected. For example, this determination may include an evaluation of proper instrument/channel response when adjusting to within Allowable As Left Tolerance, magnitude of change per unit time, previous history, etc., to provide confidence that channel will perform its specified safety function. {F2.3.10}

5.14 IF As Found data for FWST Low Level Auto-Swapover Function (1FWEM5011, K1 relay) is found non-conservative to Technical Specification Allowable Value, an Operability Evaluation will be performed by Engineering, corrective actions determined and implemented PRIOR to returning channel to service. {F2.3.1 1) 10.2 Transmitter Calibration 10.2.15 IF FWST Low Level As Found Setpoint for 1FWEM5011 (K1) is NOT within AS FOUND tolerance, perform As Found (AF) TSTF-493 evaluation as follows {F2.3.9, F2.3.10, F2.3.1 1}:

A.

IF As Found setpoint value -> 95.96 INWC perform the following:

1.

Notify Engineer of the following:

a.

As Found setpoint is out of As Found Tolerance and greater than Tech Spec Allowable Value (TSAV).

b.

Joint Technician/Engineer evaluation will have to be performed before returning to service and PIP initiated by Engineering:

Engineer Notified

2.

Adjust 1 FWEM5011 (K1) to within As Left tolerance and record on 1.1.

3.

IF joint Technician/Engineer evaluation determined that channel CANNOT be returned to service, troubleshoot and repair loop per applicable procedures.

Page 8 of 10 ATTACHMENT 1 B.

jFAs Found setpoint value < 95.96 INWC (i.e., FWST Low Level Setpoint found outside Tech Spec Allowable Value of 92.3 inches level) perform the following:

1.

Notify CRS, OSM and Supervisor:

CRS Notified OSM Notified Supervisor Notified

2.

Notify CRS to initiate PIP:

CRS Notified

3.

Notify CRS to have Engineer perform operability evaluation to determine if channel can be returned to service:

CRS Notified

4.

Adjust 1 FWEM501 1 (K1) to within As Left tolerance and record on 1.1.

5.

IF joint Technician/Engineer evaluation determined that channel CANNOT be returned to service, troubleshoot and repair loop per applicable procedures.

Page 9 of 10 ATTACHMENT 1 DUKE ID 1FWLT5010 1 FWP5010 MANUFACTURER ROSEMOUNT WESCHLER LOCATION FWST INSTRUMENT ROOM CONTROL ROOM 1MC9 INPUT OUTPUT UNITS: VDC OUTPUT UNITS: INCHES

% OF 1 UNITS AS Allowable Tolerances AS AS AS RANGE INWC DESIRED FOUND AS FOUND AS LEFT LEFT DESIRED FOUND LEFT TOLERANCE TOLERANCE3 Allowable Tolerance 2

0 3.02 1.000 0.984 to 1.016 0.990 to 1.010 0

-5.15 to 5.15 25 128.88 2.000 1.984 to 2.016 1.990 to 2.010 125 119.85 to 130.15 50 254.75 3.000 2.984 to 3.016 2.990 to 3.010 250 244.85 to 255.15 75 380.61 4.000 3.984 to 4.016 3.990 to 4.010 375 369.85 to 380.15 100 506.47 5.000 4.984 to 5.016 4.990 to 5.010 500 494.85 to 505.15 75 380.61 4.000 3.984 to 4.016 3.990 to 4.010 375 369.85 to 380.15 50 254.75 3.000 2.984 to 3.016 2.990 to 3.010 250 244.85 to 255.15 25 128.88 2.000 1.984 to 2.016 1.990 to 2.010 125 119.85 to 130.15 0

3.02 1.000 0.984 to 1.016 0.990 to 1.010 0

-5.15 to 5.15

1. Inputs include corrections for specific gravity of 2775 PPM Boron and 3 INWC Water Leg per Ref. 2.1.4 (i.e., DPINWC = 1.0069(LevelTank+3 inwc)).

2. As Found Tolerance based on Allowable As Found Tolerance (+/-0.39% of Voltage Span) calculated via TSTF-493 methodology in Ref 2.1.4.

3. As Left Tolerance based on CTELT (+/-0.25% of Voltage Span) per Ref. 2.1.4 is conservative to the TSTF-493 Allowable As Left Tolerance (+/-0.32% of Voltage Span).

Page 10 of 10 ATTACHMENT 1 DUKE ID M1A0003 MANUFACTURER SAIC LOCATION COMPUTER ROOM INPUT OUTPUT UNITS: INCHES

% OF 1 UNITS AS AS RANGE INWC DESIRED FOUND Allowable Tolerance LEFT 0

3.02 0

-2.85 to 2.85 25 128.88 125 122.15to 127.85 50 254.75 250 247.15 to 252.85 75 380.61 375 372.15 to 377.85 100 506.47 500 497.15 to 502.85 75 380.61 375 372.15to 377.85 50 254.75 250 247.15 to 252.85 25 128.88 125 122.15to 127.85 0

3.02 0

-2.85 to 2.85

1. Inputs include corrections for specific gravity of 2775 PPM Boron and 3 INWC Water Leg per Ref. 2.1.4 (i.e., DPINWC = 1.0069(LevelTank+3 inwc)).

2. As Found Tolerance based on Allowable As Found Tolerance (+/-0.39% of Voltage Span) calculated via TSTF-493 methodology in Ref 2.1.4.

3. As Left Tolerance based on CTELT (+/-0.25% of Voltage Span) per Ref. 2.1.4 is conservative to the TSTF-493 Allowable As Left Tolerance (+/-0.32% of Voltage Span).

ATTACHMENT 2 Reference 3 RAI Questions and Responses

Page 2 of 4 ATTACHMENT 2 REQUEST FOR ADDITIONAL INFORMATION MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATION 3.3.2 IN SUPPORT OF COMPLIANCE WITH NRC ORDER EA-12-049 DOCKET NOS. 50-369 AND 50-370 By letter dated September 12, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13262A500), Duke Energy Carolinas (Duke)

• submitted a license amendment request (LAR) to amend the Technical Specifications (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation,"

FUNCTION 6.f, "Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low (c)" for McGuire Nuclear Station, Units 1 and 2, in support of plant modifications required to achieve compliance with the NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements of Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

In order for the NRC staff to complete its review of the LAR, the following additional information is requested.

Page 3 of 4 ATTACHMENT 2

1. In the submittal, Duke stated:

The existing safety-related automatic alignment of NSW to the AFW pumps' suction is achieved by means of pressure switches which open AC-motor operated valves. The pressure switches are located on the AFW pump suction lines. The AFW MDPs utilize two pressure switches per train (one switch per isolation valve).

The TDAFWP utilizes four switches per train. A low pressure signal sensed by two switches on either train will cause the assured NSW supply of water for the pump to be aligned.

The NRC staff acknowledges that a low pressure signal sensed by two switches on a train of pressure switches associated with the motor-driven auxiliary feedwater pump will open flow from the service water header to the pump's suction. However, the submittal indicated that the turbine-driven auxiliary feedwater pump has four pressure switches per train. From the description given, it appears that there are actually two trains of two switches in this logic, each train associated with a different nuclear service water header. If this is the situation, the above statement, "A low pressure signal sensed by two switches on either train will cause the assured NSW supply of water for the pump to be aligned," would not be true for all cases for the turbine-driven auxiliary feedwater pump. In this case, only a select two pressure switches of the four switches will open flow from a service water header.

The NRC staff requests the licensee to clarify its description of the pressure switch logic associated with the turbine-driven auxiliary feedwater pump and make any necessary changes.

RAI #1 Response:

Each motor-driven AFW pump train is provided with an assured suction supply from the associated train of NSW (i.e. A train NSW provides the assured suction to the A motor-driven AFW pump, and B train NSW provides the assured suction to the B motor-driven AFW pump).

For a given train of NSW to automatically align to the associated motor-driven AFW pump, low AFW pump suction pressure must be sensed by two pressure switches on that train of AFW.

Technical Specification 3.3.2 Condition N is entered when one or more of the two pressure switch channels are inoperable for a given motor-driven AFW pump.

Each turbine-driven AFW pump is provided with assured suction supplies from both the A and B trains of NSW. For a given train of NSW to automatically align to the turbine-driven AFW pump, low AFW pump suction pressure must be sensed by two train-associated pressure switches located on the turbine-driven AFW pump suction. There are four switches located on the turbine-driven AFW pump suction; two A-train associated switches, and two B-train associated switches. Technical Specification 3.3.2 Condition N is entered when one or more of the four pressure switch channels are inoperable for the turbine-driven AFW pump.

14 Page 4 of 4 ATTACHMENT 2 SBPB-RAI-2

2. The licensee is proposing different setpoints for the pressure switches on the "2A" motor-driven auxiliary feedwater pumps. The Technical Specifications are combined for Unit 1 and Unit 2.

Figure 1 in Attachment 4 shows some piping configurations are different for the two units, especially where the new "SSS/ELAP" supply of water ties into the suction piping.

The NRC staff requests confirmation that the elevation difference for the "2A" motor-driven auxiliary feedwater pumps is 2-feet on both units.

RAI #2 Response:

Each Unit at McGuire Nuclear Station has two motor-driven (MD) AFW pumps and one turbine-driven (TD) AFW pump. For Unit 1, these pumps are referred to as the 1 A and 1 B MD AFW pumps, and the Unit 1 (#1 TD) AFW pump. For Unit 2, these pumps are referred to as the 2A and 2B MD AFW pumps, and the Unit 2 (#2 TD) AFW pump. The centerline of the Unit 2 AFW motor-driven pump 2A suction flow element is approximately 2 feet lower than the centerline elevations of the other Unit 2 pumps' suction flow elements (2B MD and #2 TD) and all of the Unit 1 pumps' suction flow elements (1A and 1B MD, and #1 TD).

ATTACHMENT 3 Markup of Current Revision of the Affected TS Page (3.3.2-14) after Amendment 272/252 Implementation

Page 2 of 2 ATTACHMENT 3 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 6)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

6.

Auxiliary Feedwater (continued)

e.

Trip of all Main Feedwater Pumps

f.

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - LoVE )

7.

Automatic Switchover to Containment Sump 1,2 1,2,3 1 per MFW pump 2 per MDP, 4 per TDP SR 3.3.2.7 SR 3.3.2.9 N,O

.R3327 NA NA

a.

Refueling Water Storage Tank (RWST) Level -

Low 1,2,3 3

P,S SR 3.3.2.1 SR 3.3.2.3(a)(b)

SR 3.3.2.8(a)(b)

SR 3.3.2.9

> 92.3 inches 95 inches Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

(continued)

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

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

L (c) Prior to completion of the AC independent AFW pump suction transfer scheme modification on the' respective Unit, the Allowable Value for this Function is >3 psig (>4 psig 2A MDP only) and the Nominal Trip Setpoint for this Function is 3.5 psig (4.5 psig 2A MDP only).

NOTE 1:

The Trip Setpoint for the Containment Pressure Control System start permissive/termination (SP/T) shall be > 0.3 psig and < 0.4 psig. The allowable value for the SP/T shall be > 0.25 psig and < 0.45 psig.

McGuire Units 1 and 2 3.3.2-14 Amendment Nos. 272i252