ML17136A361

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Technical Specification Bases, Revision 149
ML17136A361
Person / Time
Site: Mcguire, McGuire  Duke energy icon.png
Issue date: 05/03/2017
From:
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TR-NUC-MC-005958
Download: ML17136A361 (50)


Text

Date: 5l3l201Z Distribution: Duke Energy Document Transmittal # : TR-NUC-MC-005958

1. Boyer, Robert P
2. Gardner, Troy R DOCUMENTTRANSMilTALFORM

Purpose:

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3. Howell, Pamela T Released By:

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11. WESTINGHOUSE ELECTRIC CO LLC Page 1of1 Document ID 1 2 3 4 5 6 7 8 9 10 11 UCN - MC - MNS-TSB-B 3.4.6 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINTILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.4.7 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINTILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.4.8 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINTILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.5.2 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINT I LP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.5.3 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINT ILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.6.6 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINT ILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.9.5 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINT ILP FYIIE R&AIE R&AIE R&AIE UCN - MC - MNS-TSB-B 3.9.6 - 001 - ISSUED FYIIE FYIIE FYIIE FYIIE R&AIE FYIIE PRINT ILP FYIIE R&AIE R&AIE R&AIE Remarks:

RCS Loops-MODE 4 B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Loops-MODE 4 BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison , boric acid .

The reactor coolant is circulated through four RCS loops connected in parallel to the reactor vessel, each loop containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and to prevent boric acid stratification.

In MODE 4, either RCPs or RHR loops can be used to provide forced circulation . The intent of this LCO is to provide forced flow from at least one RCP or one RHR loop for decay heat removal and transport. The flow provided by one RCP loop or RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that two paths be available to provide redundancy for decay heat removal.

APPLICABLE In MODE 4, RCS circulation is considered in the determination of the SAFETY ANALYSES time available for mitigation of the accidental boron dilution event. The RCS and RHR loops provide this circulation .

RCS Loops-MODE 4 satisfy Criterion 4 of 10 CFR 50.36 (Ref. 1).

LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

McGuire Units 1 and 2 B 3.4.6-1 Revision No. 149

RCS Loops - MODE 4 B 3.4.6 BASES LCO (continued)

Note 1 permits all RCPs or RHR pumps to be de-energized for ~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period . The purpose of the Note is to permit tests that are designed to validate various accident analyses values. One of the tests performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits the de-energizing of the pumps in order to perform this test and validate the assumed analysis values. If changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values must be revalidated by conducting the test again . The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant with boron concentrations less than required to meet SOM of LCO 3.1 .1 and maintain Keff < 0.99, therefore maintaining an adequate margin to criticality. Boron reduction with coolant of boron concentrations less than required to assure SOM and maintain Keff < 0.99 is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation ; and
b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction .

Note 2 requires that the secondary side water temperature of each SG be

~ 50°F above each of the RCS cold leg temperatures or that pressurizer water volume be < 92% (1600 ft 3 ) before the start of an RCP with any RCS cold leg temperature ~ 300°F. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.2. The water level is maintained by an OPERABLE AFW train in accordance with LCO 3.7.5, "Auxiliary Feedwater System."

Similarly for the RHR System, an OPERABLE RHR loop comprises an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are McGuire Units 1 and 2 B 3.4.6-2 Revision No. 149

RCS Loops - MODE 4 B 3.4.6 BASES LCO (continued)

OPERABLE if they are capable of being powered and are able to provide forced flow if required . Management of gas voids is important to RHR System OPERABILITY.

APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing .

One loop of either RCS or RHR provides sufficient circulation for these purposes. However, two loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to meet single failure considerations.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4 .8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.4.17, "RCS Loops-Test Exceptions";

LCO 3.9 .5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6) .

ACTIONS If only one RCS loop is OPERABLE and two RHR loops are inoperable, redundancy for heat removal is lost. Action must be initiated to restore a second RCS or RHR loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

If only one RHR loop is OPERABLE and in operation and there are no RCS loops OPERABLE , an inoperable RCS or RHR loop must be restored to OPERABLE status to provide a redundant means for decay heat removal.

If the parameters that are outside the limits cannot be restored , the unit must be brought to MODE 5 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal. With only one RHR loop OPERABLE, redundancy for decay heat removal is lost and , in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 (~ 200°F) rather than MODE 4 (200 to < 350°F). The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time, McGuire Units 1 and 2 B 3.4 .6-3 Revision No. 149

RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS (continued) based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

C.1 and C.2 If no loop is OPERABLE or in operation, except during conditions permitted by Note 1 in the LCO section, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet SOM of LCO 3.1.1 and maintain Keff < 0.99 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. The required margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 and maintains Keff < 0.99 is required to assure continued safe operation. With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM and Keff requirements maintains acceptable margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification that one RCS or RHR loop is in operation .

Verification includes flow rate, temperature, or pump status monitoring ,

which help ensure that forced flow is providing heat removal. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.2 SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is

~ 12%. If the SG secondary side narrow range water level is < 12%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat.

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

McGuire Units 1 and 2 B 3.4.6-4 Revision No. 149

RCS Loops - MODE 4 B 3.4 .6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pump. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent water hammer, pump cavitation , and pumping of non-condensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration , such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump) ,

the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water) , the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process.

McGuire Units 1 and 2 B 3.4.6-5 Revision No. 149

RCS Loops - MODE 4 B 3.4.6 BASES SURVEILLANCE REQUIREMENTS (continued)

RHR System locations susceptible to gas accumulation are monitored and , if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration , or personnel safety. For these locations alternative methods (e.g ., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4. In a rapid shutdown ,

there may be insufficient time to verify all susceptible locations prior to entering MODE 4 .

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. 10 CFR 50.36 , Technical Specifications, (c)(2)(ii) .

McGuire Units 1 and 2 B 3.4 .6-6 Revision No. 149

RCS Loops-MODE 5, Loops Filled B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 RCS Loops-MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled , the primary function of the reactor coolant is the removal of decay heat and transfer this heat either to the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. While the principal means for decay heat removal is via the RHR System, the SGs are specified as a backup means for redundancy. Even though the SGs cannot produce steam in this MODE, they are capable of being a heat sink due to their large contained volume of secondary water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid .

In MODE 5 with RCS loops filled , the reactor coolant is circulated by means of two RHR loops connected to the RCS , each loop containing an RHR heat exchanger, an RHR pump, and appropriate flow and temperature instrumentation for control , protection , and indication. One RHR pump circulates the water through the RCS at a sufficient rate to prevent boric acid stratification .

The number of loops in operation can vary to su it the operational needs.

The intent of this LCO is to provide forced flow from at least one RHR loop for decay heat removal and transport. The flow provided by one RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that a second path be available to provide redundancy for heat removal.

The LCO provides for redundant paths of decay heat removal capability.

The first path can be an RHR loop that must be OPERABLE and in operation. The second path can be another OPERABLE RHR loop or maintaining two SGs with secondary side narrow range water levels 2'.

12% to provide an alternate method for decay heat removal.

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the SAFETY ANALYSES time available for mitigation of the accidental boron dilution event. The RHR loops provide this circulation .

McGuire Units 1 and 2 B 3.4.7-1 Revision No. 149

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES APPLICABLE SAFETY ANALYSES (continued)

RCS Loops-MODE 5 (Loops Filled) satisfy Criterion 4 of 10 CFR 50 .36 (Ref. 1).

LCO The purpose of this LCO is to require that at least one of the RHR loops be OPERABLE and in operation with an additional RHR loop OPERABLE or two SGs with secondary side narrow range water level ;;::: 12%. One RHR loop provides sufficient forced circulation to perform the safety functions of the reactor coolant under these conditions. An additional RHR loop is required to be OPERABLE to meet single failure considerations. However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is two SGs with their secondary side narrow range water levels ;;::: 12%. Should the operating RHR loop fail, the SGs could be used to remove the decay heat.

Note 1 permits all RHR pumps to be de-energized :::; 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period . The purpose of the Note is to permit tests designed to validate various accident analyses values. One of the tests performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits de-energizing of the pumps in order to perform this test and validate the assumed analysis values. If changes are made to the RCS that would cause a change to the flow characteristics of the RCS , the input values must be revalidated by conducting the test again. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period is adequate to perform the test, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant with boron concentration less than required to meet SOM of LCO 3.1 .1, therefore maintaining an adequate margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SOM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation ; and
b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction .

McGuire Units 1 and 2 B 3.4 .7-2 Revision No. 149

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES LCO (continued)

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

Note 3 requires that the secondary side water temperature of each SG be

~ 50°F above each of the RCS cold leg temperatures or that pressurizer water volume be< 92% (1600 ft 3 ) before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature ~ 300°F. This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started .

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink when it has an adequate water level. Management of gas voids is important to RHR System OPERABILITY.

APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing . One loop of RHR provides sufficient circulation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side narrow range water level of at least two SGs is required to be ~ 12%.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled" ;

LCO 3.4.17 "RCS Loops-Test Exceptions";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9 .6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

McGuire Units 1 and 2 B 3.4 .7-3 Revision No. 149

RCS Loops - MODE 5, Loops Filled B 3.4 .7 BASES ACTIONS A.1 and A.2 If one RHR loop is inoperable and the required SGs have secondary side narrow range water levels < 12%, redundancy for heat removal is lost.

Action must be initiated immediately to restore a second RHR loop to OPERABLE status or to restore the required SG secondary side water levels. Either Required Action A.1 or Required Action A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no RHR loop is in operation , except during conditions permitted by Note 1, or if no loop is OPERABLE, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet SOM of LCO 3.1 .1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation , unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification that the requ ired loop is in operation .

Verification includes flow rate, temperature, or pump status monitoring ,

which help ensure that forced flow is providing heat removal. The Surveillance Frequency is based on operating experience, equipment rel iability, and plant risk and is controlled under the Surveillance Frequency Control Program .

SR 3.4.7.2 Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are ;::: 12% ensures an alternate decay heat removal method in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE , this Surveillance is not needed. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

McGuire Units 1 and 2 B 3.4 .7-4 Revision No. 149

RCS Loops - MODE 5, Loops Filled B 3.4 .7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.7 .3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the RHR pump.

If secondary side narrow range water level is ~ 12% in at least two SGs, this Surveillance is not needed. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.7.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent water hammer, pump cavitation , and pumping of non-condensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information , including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration , such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump) ,

the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water) , the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process.

McGuire Units 1 and 2 B 3.4.7-5 Revision No. 149

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE REQUIREMENTS (continued)

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES 1. 10 CFR 50 .36, Technical Specifications, (c)(2)(ii) .

McGuire Units 1 and 2 B 3.4.7-6 Revision No. 149

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4 .8 RCS Loops-MODE 5, Loops Not Filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated in the fuel, and the transfer of this heat to the component cooling water via the residual heat removal (RHR) heat exchangers. The steam generators (SGs) are not available as a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.

In MODE 5 with loops not filled, only RHR pumps can be used for coolant circulation . The number of pumps in operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least one RHR pump for decay heat removal and transport and to require that two paths be available to provide redundancy for heat removal.

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the SAFETY ANALYSES time available for mitigation of the accidental boron dilution event. The RHR loops provide this circulation. The flow provided by one RHR loop is adequate for heat removal and for boron mixing.

RCS loops in MODE 5 (loops not filled) satisfy Criterion 4 of 10 CFR 50.36 (Ref. 1).

LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation. An OPERABLE loop is one that has the capability of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used . A minimum of one running RHR pump meets the LCO requirement for one loop in operation . An additional RHR loop is required to be OPERABLE to meet single failure considerations.

Note 1 permits all RHR pumps to be de-energized for ~ 15 minutes when switching from one loop to another. The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short and core outlet temperature is maintained at least 10°F below saturation temperature. The Note prohibits boron dilution with coolant at boron concentration less than required to assure SOM of LCO 3.1 .1 is maintained or draining operations when RHR forced flow is stopped.

McGuire Units 1 and 2 B 3.4.8-1 Revision No. 149

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES LCO (continued)

Note 2 allows one RHR loop to be inoperable for a period of :::;; 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. Management of gas voids is important to RHR System OPERABILITY.

APPLICABILITY In MODE 5 with loops not filled , this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4 .5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4.17 , "RCS Loops-Test Exceptions";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

ACTIONS If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat remova l.

B.1 and B.2 If no required RHR loops are OPERABLE or in operation , except during conditions permitted by Note 1, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet SOM of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation.

The required margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SOM of LCO 3.1 .1 is required to assure continued safe operation . With coolant McGuire Units 1 and 2 B 3.4.8-2 Revision No. 149

RCS Loops - MODE 5, Loops Not Filled B 3.4 .8 BASES ACTIONS (continued) added without forced circulation, unmixed coolant could be introduced to the core, however, coolant added with boron concentration meeting the minimum SOM maintains acceptable margin to criticality. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation .

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification that one loop is in operation . Verification includes flow rate, temperature, or pump status monitoring , which help ensure that forced flow is providing heat removal. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that an additional pump can be placed in operation, if needed , to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4 .8.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation , and pumping of non-condensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations McGuire Units 1 and 2 B 3.4.8-3 Revision No. 149

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE REQUIREMENTS (continued) depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump) ,

the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring ,

then this is evaluated under the Operability Determination Process.

RHR System locations susceptible to gas accumulation are monitored and , if gas is found , the gas volume is compared to the acceptance criteria for the location . Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g ., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES 1. 10 CFR 50.36, Technical Specifications, (c)(2)(ii) .

McGuire Units 1 and 2 B 3.4.8-4 Revision No. 149

EGGS-Operating B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.2 EGGS-Operating BASES BACKGROUND The function of the ECCS is to provide core cooling and negative reactivity to ensure that the reactor core is protected after any of the following accidents:

a. Loss of coolant accident (LOCA), coolant leakage greater than the capability of the normal charging system;
b. Rod ejection accident;
c. Loss of secondary coolant accident, including uncontrolled steam or feedwater release; and
d. Steam generator tube rupture (SGTR).

The addition of negative reactivity is designed primarily for the loss of secondary coolant accident where primary cooldown could add enough positive reactivity to achieve criticality and return to significant power.

There are three phases of ECCS operation : injection, cold leg recirculation , and hot leg recirculation . In the injection phase, water is taken from the refueling water storage tank (RWST) and injected into the Reactor Coolant System (RCS) through the cold legs. When sufficient water is removed from the RWST to ensure that enough boron has been added to maintain the reactor subcritical and the containment sumps have enough water to supply the required net positive suction head to the ECCS pumps, suction is switched to the containment sump for cold leg recirculation. When the core decay heat has decreased to a level low enough to be successfully removed without direct RHR pump injection flow, the RHR cold leg injection path is realigned to discharge to the auxiliary containment spray header. After approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, part of the ECCS flow is shifted to the hot leg recirculation phase to provide a backflush which, for a cold leg break, would reduce the boiling in the top of the core and prevent excessive boron concentration .

The ECCS consists of three separate subsystems: centrifugal charging (high head), safety injection (SI) (intermediate head), and residual heat removal (RHR) (low head). Each subsystem consists of two redundant, 100% capacity trains. The ECCS accumulators and the RWST are also part of the ECCS, but are not considered part of an ECCS flow path as described by this LCO.

McGuire Units 1 and 2 B 3.5.2-1 Revision No. 149

EGGS-Operating B 3.5.2 BASES BACKGROUND (continued)

The ECCS flow paths consist of piping, valves, heat exchangers, and pumps such that water from the RWST can be injected into the RCS following the accidents described in this LCO. The major components of each subsystem are the centrifugal charging pumps, the RHR pumps, heat exchangers, and the SI pumps. Each of the three subsystems consists of two 100% capacity trains that are interconnected and redundant such that either train is capable of supplying 100% of the flow required to mitigate the accident consequences. This interconnecting and redundant subsystem design provides the operators with the ability to utilize components from opposite trains to achieve the required 100% flow to the core.

During the injection phase of LOCA recovery, a suction header supplies water from the RWST to the ECCS pumps. Mostly separate piping supplies each subsystem and each train within the subsystem. The discharge from the centrifugal charging pumps combines, then divides again into four supply lines, each of which feeds the injection line to one RCS cold leg. The discharge from the SI and RHR pumps divides and feeds an injection line to each of the RCS cold legs. Throttle valves in the SI lines are set to balance the flow to the RCS. This balance ensures sufficient flow to the core to meet the analysis assumptions following a LOCA in one of the RCS cold legs. The flow split from the RHR lines cannot be adjusted . Although much of the two ECCS trains are composed of completely separate piping, certain areas are shared between trains. The most important of these are 1) where both trains flow through a single physical pipe, and 2) at the injection connections to the RCS cold legs. Since each train must supply sufficient flow to the RCS to be considered 100% capacity, credit is taken in the safety analyses for flow to three intact cold legs. Any configuration which, when combined with a single active failure, prevents the flow from either ECCS pump in a given train from reaching all four cold legs injection points on that train is unanalyzed and might render both trains of that ECCS subsystem inoperable.

For LOCAs that are too small to depressurize the RCS below the shutoff head of the SI pumps, the centrifugal charging pumps supply water until the RCS pressure decreases below the SI pump shutoff head. During this period, the steam generators are used to provide part of the core cooling function .

During the recirculation phase of LOCA recovery, RHR pump suction is transferred to the containment sump. The RHR pumps then supply the other ECCS pumps. Initially, recirculation is through the same paths as the injection phase. Subsequently, for large LOCAs, the recirculation phase includes injection into both the hot and cold legs.

McGuire Units 1 and 2 B 3.5.2-2 Revision No. 149

ECCS-Operating B 3.5.2 BASES BACKGROUND (continued)

The high and intermediate head subsystems of the ECCS also functions to supply borated water to the reactor core following increased heat removal events, such as a main steam line break (MSLB). The limiting design conditions occur when the moderator temperature coefficient is highly negative, such as at the end of each cycle.

During low temperature conditions in the RCS , limitations are placed on the maximum number of ECCS pumps that may be OPERABLE. Refer to the Bases for LCO 3.4.12, "Low Temperature Overpressure Protection (L TOP) System," for the basis of these requirements.

The ECCS subsystems are actuated upon receipt of an SI signal. The actuation of safeguard loads is accomplished in a programmed time sequence. If offsite power is available, the safeguard loads start immediately in the programmed sequence. If offsite power is not available, the Engineered Safety Feature (ESF) buses shed normal operating loads and are connected to the emergency diesel generators (EDGs) . Safeguard loads are then actuated in the programmed time sequence. The time delay associated with diesel starting , sequenced loading , and pump starting determines the time required before pumped flow is available to the core following a safety injection actuation.

The active ECCS components, along with the passive accumulators and the RWST covered in LCO 3.5.1, "Accumulators," and LCO 3.5.4 ,

"Refueling Water Storage Tank (RWST)," provide the cooling water necessary to meet GDC 35 (Ref. 1).

APPLICABLE The LCO helps to ensure that the following acceptance criteria for the SAFETY ANALYSES ECCS, established by 10 CFR 50.46 (Ref. 2), will be met following a small break LOCA and there is a high level of probability that the criteria are met following a large break LOCA:

a. Maximum fuel element cladding temperature is ~ 2200°F;
b. Maximum cladding oxidation is ~ 0.17 times the total cladding th ickness before oxidation ;
c. Maximum hydrogen generation from a zirconium water reaction is

~ 0.01 times the hypothetical amount generated if all of the metal in the cladding cylinders surrounding the fuel , excluding the cladding surrounding the plenum volume, were to react; McGuire Units 1 and 2 B 3.5.2-3 Revision No. 149

ECCS-Operating B 3.5.2 BASES APPLICABLE SAFETY ANALYSES (continued)

d. Core is maintained in a coolable geometry; and
e. Adequate long term core cooling capability is maintained.

The LCO also limits the potential for a post trip return to power following an MSLB event and ensures that containment pressure and temperature limits are met.

Each ECCS subsystem is taken credit for in a large break LOCA event at full power (Refs. 3 and 4). This event has the greatest potential to challenge the limits on runout flow set by the manufacturer of the ECCS pumps. It also sets the maximum response time for their actuation. Direct flow from the centrifugal charging pumps and SI pumps is credited in a small break LOCA event. The RHR pumps are also credited, for larger small break LOCAs, as the means of supplying suction to these higher head ECCS pumps after the switch to sump recirculation. This event establishes the flow and discharge head at the design point for the centrifugal charging pumps. The MSLB analysis also credits the SI and centrifugal charging pumps. Although some ECCS flow is necessary to mitigate a SGTR event, a single failure disabling one ECCS train is not the limiting single failure for this transient. The SGTR analysis primary to secondary break flow is increased by the availability of both centrifugal charging and SI trains. Therefore, the SGTR analysis is penalized by assuming both ECCS trains are operable as required by the LCO. The OPERABILITY requirements for the ECCS are based on the following LOCA analysis assumptions:

a. A large break LOCA event, with loss of offsite power and a single failure disabling one ECCS train; and
b. A small break LOCA event, with a loss of offsite power and a single failure disabling one ECCS train .

During the blowdown stage of a LOCA, the RCS depressurizes as primary coolant is ejected through the break into the containment. The nuclear reaction is terminated either by moderator voiding during large breaks or control rod insertion for small breaks. Following depressurization, emergency cooling water is injected into the cold legs, flows into the downcomer, fills the lower plenum , and refloods the core.

The effects on containment mass and energy releases are accounted for in appropriate analyses (Ref. 3) . The LCO ensures that an ECCS train will deliver sufficient water to match boiloff rates soon enough to minimize the consequences of the core being uncovered following a large LOCA.

McGuire Units 1 and 2 8 3.5.2-4 Revision No. 149

EGGS-Operating B 3.5.2 BASES APPLICABLE SAFETY ANALYSES (continued)

It also ensures that the centrifugal charging and SI pumps will deliver sufficient water and boron during a small LOCA to maintain core subcriticality. For smaller LOCAs, the centrifugal charging pump delivers sufficient fluid to maintain RCS inventory. For a small break LOCA, the steam generators continue to serve as the heat sink, providing part of the required core cooling .

The ECCS trains satisfy Criterion 3 of 10CFR 50.36 (Ref. 5).

LCO In MODES 1, 2, and 3, two independent (and redundant) ECCS trains are required to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train . Additionally, individual components within the ECCS trains may be called upon to mitigate the consequences of other transients and accidents.

In MODES 1, 2, and 3, an ECCS train consists of a centrifugal charging subsystem , an SI subsystem, and an RHR subsystem. Each train includes the piping , instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon an SI signal and automatically transferring suction to the containment sump.

During an event requiring ECCS actuation , a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term, this flow path may be switched to take its supply from the containment sump and to supply its flow to the RCS hot and cold legs. The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains. Management of gas voids is important to ECCS OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, the ECCS OPERABILITY requirements for the limiting Design Basis Accident, a large break LOCA, are based on full power operation . Although reduced power would not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The centrifugal charging pump performance is based on a small break LOCA, which establishes the pump performance curve and has less dependence on power. The SI pump performance requirements are based on a small break LOCA. For both of these types of pumps, the large break LOCA analysis depends only on the flow value at containment pressure, not on the shape of the flow versus pressure curve at higher pressures. MODE 2 and MODE 3 requirements are bounded by the MODE 1 analysis.

McGuire Units 1 and 2 B 3.5.2-5 Revision No. 149

ECCS-Operating B 3.5.2 BASES APPLICABILITY (continued)

This LCO is only applicable in MODE 3 and above. Below MODE 3, the SI signal setpoint is manually bypassed by operator control, and system functional requirements are relaxed as described in LCO 3.5 .3, "ECCS-Shutdown ."

As indicated in the Note, the flow path may be isolated for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in MODE 3, under controlled conditions, to perform pressure isolation valve testing per SR 3.4.14.1. The flow path is readily restorable from the control room .

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requ irements in MODE 5 are addressed by LCO 3.4 .7, "RCS Loops-MODE 5, Loops Filled," and LCO 3.4.8 , "RCS Loops-MODE 5, Loops Not Filled ." MODE 6 core cooling requirements are addressed by LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level ," and LCO 3.9.6 , "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

ACTIONS With one or more trains inoperable and at least 100% of the ECCS flow equ ivalent to a single OPERABLE ECCS train available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC reliability evaluation (Ref. 6) and is a reasonable time for repair of many ECCS components.

An ECCS train is inoperable if it is not capable of delivering design flow to the RCS . Individual components are inoperable if they are not capable of performing their design function or supporting systems are not available.

The LCO requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECCS incapable of performing its function . Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of this Condition is to maintain a combination of equipment such that 100% of the ECCS flow equivalent to a single OPERABLE ECCS train remains available. This allows increased flexibility in plant operations under circumstances when components in opposite trains are inoperable.

McGuire Units 1 and 2 B 3.5.2-6 Revision No. 149

ECCS-Operating B 3.5.2 BASES ACTIONS (continued)

An event accompanied by a loss of offsite power and the failure of an EOG can disable one ECCS train until power is restored . A reliability analysis (Ref. 6) has shown that the impact of having one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Reference 7 describes situations in which one component, such as an RHR crossover valve, can disable both ECCS trains. With one or more component(s) inoperable such that 100% of the flow equivalent to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analysis. Therefore, LCO 3.0 .3 must be immediately entered .

As part of the 1A RHR AHU repair evolution , the Completion Time that one train of ECCS can be inoperable as specified by Required Action A.1 may be extended beyond the "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />" for up to 10 days (on Unit 1 only) . This allowance may be used one-time for the 1A RHR AHU repair.

Upon completion of the repair and restoration , the Completion Time footnote is no longer applicable and will expire on March 31 , 2016. The commitments from the LAR submittal are as follows:

Commitment Description 1 The alternate forced cooling equipment (chiller and AHU) will be installed and tested in accordance with the EC process prior to the 1A RHR AHU repair evolution .

2 At least one WZ C sump pump will be available prior to the 1A RHR AHU repair evolution .

3 The following SSCs will be protected prior to the 1A RHR AHU repair evolution, and elective maintenance to them will be deferred during the repairs to the 1A RHR pump motor AHU :

  • 1B Component Cooling Water System (CCWS) train
  • Power supply to the alternate cooling equipment
  • One WZ C sump pump 4 Prior to the 1A RHR AHU repair evolution, McGuire will monitor the National Weather Service for potential severe weather conditions. To the extent practical , severe weather conditions will be avoided .

5 Prior to the 1A RHR AHU repair evolution , and daily thereafter, McGuire will contact the Transmission Control Center (TCC) regarding system grid stability. To the extent practical , system qrid instability will be avoided.

McGuire Units 1 and 2 B 3.5.2-7 Revision No. 149

ECCS-Operating B 3.5.2 BASES ACTIONS (continued) 6 Prior to the 1A RHR AHU repair evolution , roving fire watches will be established in the following areas to minimize the chance of fire-induced LOCAs:

  • Unit 1 4.16kV Switchgear Rooms
  • 1B Diesel Generator Room
  • Fire Area 14 - vicinity of 1/2EMXB1
  • Fire Area 19 - vicinity of 1/2EMXG
  • Fire Area 25 - vicinity of 1IC02 7 Prior to the 1A RHR AHU repair evolution , procedures will have been developed to start the alternate cooling when required , and personnel will be designated to ensure that the equipment is started before room temperatures exceed the limits.

B.1 and B.2 If the inoperable trains cannot be returned to OPERABLE status within the associated 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 MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times 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 3.5.2.1 REQUIREMENTS Verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is maintained . Misalignment of these valves could render both ECCS trains inoperable. Securing these valves using the power disconnect switches in the correct position ensures that they cannot change position as a result of an active failure or be inadvertently misaligned. These valves are of the type , described in Reference 7, that can disable the function of both ECCS trains and invalidate the accident analyses. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.5.2 .2 Verifying the correct alignment for manual , power operated , and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation . This SR does not apply McGuire Units 1 and 2 B 3.5 .2-8 Revision No. 149

ECCS-Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) to valves that are locked, sealed, or otherwise secured in position , since these were verified to be in the correct position prior to locking, sealing ,

or securing . A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program .

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room . This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.2.3 ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent water hammer, pump cavitation , and pumping of non-condensable gas into the reactor vessel.

Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumu lated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e. ,

the system is sufficiently filled with water) , the Surveillance may be McGuire Units 1 and 2 B 3.5.2-9 Revision No. 149

ECCS-Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring ,

then this is evaluated under the Operability Determination Process.

ECCS locations susceptible to gas accumulation are monitored and , if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

SR 3.5.2.4 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by the ASME OM Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant safety analysis.

SRs are specified in the lnservice Testing Program, which encompasses the ASME OM Code. The ASME Code provides the activities and Frequencies necessary to satisfy the requirements.

McGuire Units 1 and 2 B 3.5.2-10 Revision No. 149

ECCS_:.Qperating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 and SR 3.5.2.6 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SI signal and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked, sealed , or otherwise secured in the required position under administrative controls. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 The position of throttle valves in the flow path on an SI signal is necessary for proper ECCS performance. These valves have mechanical locks to ensure proper positioning for restricted flow to a ruptured cold leg , ensuring that the other cold legs receive at least the required minimum flow. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.8 Periodic inspections of the ECCS containment sump strainer assembly (consisting of modular tophats, grating, plenums and waterboxes) and the associated enclosure (the stainless steel structure surrounding the strainer assembly located inside the crane wall) ensure they are unrestricted and stay in proper operating condition . Inspections will consist of a visual examination of the exterior surfaces of the strainer assembly and interior and exterior surfaces of the enclosure for any evidence of debris, structural distress, or abnormal corrosion . The intent of the surveillance is to ensure the absence of any condition which could adversely affect strainer functionality. Surveillance performance will not require removal of any tophat modules, but the strainer assembly exterior shall be visually inspected. This inspection will necessarily entail opening the top of the enclosure to allow access for inspection of the strainers, and to verify cleanliness of the enclosure interior space. A detailed inspection of the enclosure and exterior strainer assembly surfaces is required to establish a high confidence that no adverse conditions are present. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

McGuire Units 1 and 2 B 3.5.2-11 Revision No. 149

ECCS-Operating B 3.5.2 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 35.

2. 10 CFR 50.46.
3. UFSAR, Section 6.2.1.
4. UFSAR, Chapter 15.
5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii) .
6. NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
7. IE Information Notice No. 87-01.

McGuire Units 1 and 2 B 3.5.2-12 Revision No. 149

ECCS-Shutdown B 3.5.3 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5 .3 ECCS-Shutdown BASES BACKGROUND The Background section for Bases 3.5 .2, "ECCS-Operating ," is applicable to these Bases, with the following modifications.

In MODE 4, the required ECCS train consists of two separate subsystems: centrifugal charging (high head) and residual heat removal (RHR) (low head).

The ECCS flow paths consist of piping , valves, heat exchangers, and pumps such that water from the refueling water storage tank (RWST) can be injected into the Reactor Coolant System (RCS) following the accidents described in Bases 3.5.2.

APPLICABLE The Applicable Safety Analyses section of Bases 3.5.2 also applies SAFETY ANALYSES to this Bases section.

Due to the stable conditions associated with operation in MODE 4 and the reduced probability of occurrence of a Design Basis Accident (OBA), the ECCS operational requirements are reduced . It is understood in these reductions that certain automatic safety injection (SI) actuation is not available. In this MODE, sufficient time exists for manual actuation of the required ECCS to mitigate the consequences of a OBA.

Only one train of ECCS is required for MODE 4. This requirement dictates that single failures are not considered during this MODE of operation . The ECCS trains satisfy Criterion 3 of 10 CFR 50.36.

LCO In MODE 4, one of the two independent (and redundant) ECCS trains is required to be OPERABLE to ensure that sufficient ECCS flow is available to the core following a OBA.

In MODE 4, an ECCS train consists of a centrifugal charging subsystem and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST and transferring suction to the containment sump. During an event requiring ECCS actuation , a flow path is required to provide an abundant supply of water from the RWST to the RCS via the McGuire Units 1 and 2 B 3.5.3-1 Revision No. 149

ECCS - Shutdown B 3.5.3 BASES LCO (continued)

ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term , this flow path may be switched to take its supply from the containment sump and to deliver its flow to the RCS hot and cold legs. Management of gas voids is important to ECCS OPERABILITY.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In MODE 4 with RCS temperature below 350°F, one OPERABLE ECCS train is acceptable without single failure consideration , on the basis of the stable reactivity of the reactor and the limited core cooling requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4 .7, "RCS Loops-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level ," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable ECCS centrifugal charging subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS centrifugal charging subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

With no ECCS RHR subsystem OPERABLE, the plant is not prepared to respond to a loss of coolant accident or to continue a cooldown using the RHR pumps and heat exchangers. The Completion Time of immediately to initiate actions that would restore at least one ECCS RHR subsystem to OPERABLE status ensures that prompt action is taken to restore the required cooling capacity. Normally, in MODE 4, reactor decay heat is removed from the RCS by an RHR loop. If no RHR loop is OPERABLE for this function , reactor decay heat must be removed by some alternate method, such as use of the steam generators. The alternate means of McGuire Units 1 and 2 B 3.5.3-2 Revision No. 149

ECCS - Shutdown B 3.5.3 BASES ACTIONS (continued) heat removal must continue until the inoperable RHR loop components can be restored to operation so that decay heat removal is continuous.

With both RHR pumps and heat exchangers inoperable, it would be unwise to require the plant to go to MODE 5, where the only available heat removal system is the RHR. Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status.

With no ECCS high head subsystem OPERABLE, due to the inoperability of the centrifugal charging pump or flow path from the RWST, the plant is not prepared to provide high pressure response to Design Basis Events requiring SI. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time to restore at least one ECCS high head subsystem to OPERABLE status ensures that prompt action is taken to provide the required cooling capacity or to initiate actions to place the plant in MODE 5, where an ECCS train is not required.

When the Required Actions of Condition B cannot be completed within the required Completion Time, a controlled shutdown should be initiated .

Twenty-four hours is a reasonable time, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems or operators.

SURVEILLANCE SR 3.5 .3.1 REQUIREMENTS The applicable Surveillance descriptions from Bases 3.5.2 apply. This SR is modified by a Note that allows an RHR train to be considered OPERABLE during PIV testing and alignment and operation for decay heat removal , if capable of being manually realigned (remote or local) to the ECCS mode of operation and not otherwise inoperable. This allows operation in the RHR mode during MODE 4, if necessary.

REFERENCES The applicable references from Bases 3.5 .2 apply.

McGuire Units 1 and 2 B 3.5 .3-3 Revision No. 149

Containment Spray System B 3.6.6 B 3.6 CONTAINMENT SYSTEMS B 3.6.6 Containment Spray System BASES BACKGROUND The Containment Spray System provides containment atmosphere cooling to limit post accident pressure and temperature in containment to less than the design values. Reduction of containment pressure and the iodine removal capability of the spray reduce the release of fission product radioactivity from containment to the environment, in the event of a Design Basis Accident (OBA) . The Containment Spray System is designed to meet the requirements of 10 CFR 50, Appendix A, GDC 38, "Containment Heat Removal," GDC 39, "Inspection of Containment Heat Removal Systems,"

GDC 40 , "Testing of Containment Heat Removal Systems," GDC 41, "Containment Atmosphere Cleanup," GDC 42, "Inspection of Containment Atmosphere Cleanup Systems," and GDC 43, "Testing of Containment Atmosphere Cleanup Systems" (Ref. 1).

The Containment Spray System consists of two separate trains of equal capacity, each capable of meeting the system design basis spray coverage.

Each train includes a containment spray pump, one containment spray heat exchanger, spray headers, nozzles, valves, and piping. Each train is powered from a separate Engineered Safety Feature (ESF) bus. One train of Containment Spray flow is manually initiated with suction on the Containment Sump after commencement of the ECCS sump recirculation mode of operation.

The diversion of a portion of the recirculation flow from each train of the Residual Heat Removal (RHR) System to additional redundant spray headers supplements the Containment Spray System heat removal capability. Each RHR train is capable of supplying spray coverage, if desired, to supplement the Containment Spray System .

The Containment Spray System provides a spray of cold or subcooled borated water into the upper containment volume to limit the containment pressure and temperature during a OBA. In the recirculation mode of operation , heat is removed from the containment sump water by the Containment Spray System and RHR heat exchangers. Each train of the Containment Spray System provides adequate spray coverage to meet the system design requirements for containment heat removal.

McGuire Unit 1 and 2 B 3.6 .6-1 Revision No. 149

Containment Spray System B 3.6.6 BASES BACKGROUND (continued)

For the hypothetical double-ended rupture of a Reactor Coolant System pipe, the pH of the sump solution (and, consequently, the spray solution) is raised to approximately 7.9 within one hour of the onset of the LOCA. The resultant pH of the sump solution is based on the mixing of the RCS fluids ,

ECCS injection fluid , and the melted ice which are combined in the sump.

The alkaline pH of the containment sump water minimizes the evolution of iodine and the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid .

Containment Spray is manually initiated from the Control Room by opening the Containment Spray System (CSS) Pump discharge valves and starting the CSS Pump. The CSS is typically not activated until an RWST low level alarm is received . After the RHR pumps have been aligned for containment sump recirculation , containment spray pumps are aligned to the sump.

Once adequate sump level and containment pressure above 3 PSIG have been confirmed , one spray pump is manually started. The CSS maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the CSS in the recirculation mode is controlled by the operator in accordance with emergency operation procedures.

The RHR spray operation is initiated manually, when requ ired by the emergency operating procedures, after the Emergency Core Cooling System (ECCS) is operating in the recirculation mode. The RHR sprays are available to supplement the Containment Spray System, if desired, in limiting containment pressure. This additional spray capacity would typically be used after the ice bed has been depleted and in the event that containment pressure rises above a predetermined limit. The Containment Spray System is an ESF system . It is designed to ensure that the heat removal capability required during the post accident period can be attained.

The operation of the ice condenser is adequate to assure pressure suppression subsequent to the initial blowdown of steam and water from a OBA. During the post blowdown period , the Air Return System (ARS) is automatically started . The ARS returns upper compartment air through the divider barrier to the lower compartment. This serves to equalize pressures in containment and to continue circulating heated air and steam through the ice condenser, where heat is removed by the remaining ice.

McGuire Unit 1 and 2 B 3.6.6-2 Revision No. 149

Containment Spray System B 3.6.6 BASES BACKGROUND (continued)

The Containment Spray System limits the temperature and pressure that could be expected following a OBA. Protection of containment integrity limits leakage of fission product radioactivity from containment to the environment.

APPLICABLE The limiting DBAs considered relative to containment OPERABILITY SAFETY ANALYSES are the loss of coolant accident (LOCA) and the steam line break (SLB).

The OBA LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients. No two DBAs are assumed to occur simultaneously or consecutively. The postulated DBAs are analyzed, in regard to containment ESF systems, assuming the loss of one ESF bus, which is the worst case single active failure, resulting in one train of the Containment Spray System, the RHR System, and the ARS being rendered inoperable (Ref. 2).

The OBA analyses show that the maximum peak containment pressure results from the LOCA analysis, and is calculated to be less than the containment design pressure. The maximum peak containment atmosphere temperature results from the SLB analysis and was calculated to be within the containment environmental qualification temperature during the OBA SLB. The basis of the containment environmental qualification temperature is to ensure the OPERABILITY of safety related equipment inside containment (Ref. 3) .

The Containment Spray System actuation modeled in the containment analysis is based on the time associated with reaching the RWST Low Level Setpoint and operator action prior to achieving full flow through the containment spray nozzles. A delayed response time initiation provides conservative analyses of peak calculated containment temperature and pressure responses. The Containment Spray System total response time is composed of operator action , system startup time, and time for the piping to fill.

For certain aspects of transient accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the ECCS cooling effectiveness during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For these calculations, the containment backpressure is calculated in a manner designed to conservatively minimize, rather than maximize , the calculated transient containment pressures in accordance with 10 CFR 50, Appendix K (Ref. 4).

McGuire Unit 1 and 2 B 3.6.6-3 Revision No. 149

Containment Spray System B 3.6.6 BASES APPLICABLE SAFETY ANALYSES (continued)

Inadvertent actuation is precluded by design features consisting of an additional set of containment pressure sensors which prevents operation when the containment pressure is below the containment pressure control system permissive.

The Containment Spray System satisfies Criterion 3 of 10 CFR 50.36 (Ref.

5).

LCO During a OBA, one train of Containment Spray System is required to provide the heat removal capability assumed in the safety analyses. To ensure that this requirement is met, two containment spray trains must be OPERABLE with power from two safety related , independent power supplies. Therefore, in the event of an accident, at least one train operates.

Each Containment Spray System includes a spray pump, headers, valves, heat exchangers, nozzles, piping , instruments, and controls to ensure an OPERABLE flow path capable of being manually initiated to take suction from the Containment Sump and delivering it to the Containment Spray Rings. Management of gas voids is important to Containment Spray System OPERABILITY.

APPLICABILITY In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the Containment Spray System.

In MODES 5 and 6, the probability and consequences of these events are reduced because of the pressure and temperature limitations of these MODES. Thus, the Containment Spray System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS With one containment spray train inoperable, the affected train must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The components in this degraded condition are capable of providing 100% of the heat removal after an accident. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a OBA occurring during this period .

McGuire Unit 1 and 2 B 3.6.6-4 Revision No. 149

Containment Spray System B 3.6.6 BASES ACTIONS (continued)

B.1 and B.2 If the affected containment spray train 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 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times 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.

The extended interval to reach MODE 5 allows additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment of manual and power operated valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation . This SR does not apply to valves that are locked , sealed , or otherwise secured in position since they were verified in the correct position prior to being secured . This SR does not require any testing or valve manipulation . Rather, it involves verification, through a system walkdown or computer status indication, that those valves outside containment and capable of potentially being mispositioned, are in the correct position . The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Prog ram.

The surveillance includes verifying the correct alignment of the containment spray pump discharge valves.

The Surveillance is mod ified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required McGuire Unit 1 and 2 B 3.6.6-5 Revision No. 149

Containment Spray System B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued) by the ASME OM Code (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the lnservice Testing Program.

SR 3.6.6.3 and SR 3.6.6.4 Not Used.

SR 3.6.6.5 and SR 3.6.6 .6 These SRs require verification that each containment spray pump discharge valve can be manually opened or is prevented from opening and each containment spray pump can be manually started or is de-energized and prevented from starting upon receipt of Containment Pressure Control System start and terminate signals. The EOG Load Sequencer must be reset in order for the containment spray pump to start. The CPCS is described in the Bases for LCO 3.3.2, "ESFAS." The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.6 .6.7 With the containment spray inlet 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 Unit 1 and 2 B 3.6.6-6 Revision No. 149

Containment Spray System B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6.8 Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration , such as stand-by versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water) , the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring , then this is evaluated under the Operability Determination Process.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location . Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration , or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations McGuire Unit 1 and 2 B 3.6.6-7 Revision No. 149

Containment Spray System B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued) where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41 ,

GDC 42, and GDC 43.

2. UFSAR, Section 6.2 .
3. 10 CFR 50.49.
4. 10 CFR 50, Appendix K.
5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
6. ASME Code for Operation and Maintenance of Nuclear Power Plants.

McGuire Unit 1 and 2 B 3.6.6-8 Revision No. 149

RHR and Coolant Circulation- High Water Level B 3.9.5 B 3.9 REFUELING OPERATIONS B 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation-High Water Level BASES BACKGROUND The purpose of the RHR System in MODE 6 is to remove decay heat and sensible heat from the Reactor Coolant System (RCS), as required by GDC 34 , to provide mixing of borated coolant and to prevent boron stratification (Ref. 1). Heat is removed from the RCS by circulating reactor coolant through the RHR heat exchanger(s) , where the heat is transferred to the Component Cooling Water System. The coolant is then returned to the RCS via the RCS cold leg(s). Operation of the RHR System for normal cooldown or decay heat removal is manually accomplished from the control room . The heat removal rate is adjusted by controlling the flow of reactor coolant and component cooling water through the RHR heat exchanger(s) . Mixing of the reactor coolant is maintained by this continuous circulation of reactor coolant through the RHR System.

APPLICABLE If the reactor coolant temperature is not maintained below 200°F, SAFETY ANALYSES boiling of the reactor coolant could result. This could lead to a loss of coolant in the reactor vessel. Additionally, boiling of the reactor coolant could lead to a reduction in boron concentration in the coolant due to boron plating out on components near the areas of the boiling activity.

The loss of reactor coolant and the reduction of boron concentration in the reactor coolant would eventually challenge the integrity of the fuel cladding , which is a fission product barrier. One train of the RHR System is required to be operational in MODE 6, with the water level ~ 23 ft above the top of the reactor vessel flange, to prevent this challenge. The LCO does permit de-energizing the RHR pump for short durations, under the condition that the boron concentration is not diluted. This conditional de-energizing of the RHR pump does not result in a challenge to the fission product barrier.

The RHR System satisfies Criterion 4 of 10 CFR 50.36 (Ref. 2).

LCO Only one RHR loop is required for decay heat removal in MODE 6, with the water level ~ 23 ft above the top of the reactor vessel flange. Only one RHR loop is required to be OPERABLE, because the volume of water above the reactor vessel flange provides backup decay heat removal capability. At least one RHR loop must be OPERABLE and in operation to provide:

McGuire Units 1 and 2 B 3.9 .5-1 Revision No. 149

RHR and Coolant Circulation - High Water Level B 3.9.5 BASES LCO (continued)

a. Removal of decay heat;
b. Mixing of borated coolant to minimize the possibility of criticality; and
c. Indication of reactor coolant temperature.

An OPERABLE RHR loop includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs. The operability of the operating RHR train and the supporting heat sink is dependent on the ability to maintain the desired RCS temperature.

Management of gas voids is important to RHR System OPERABILITY.

The LCO is modified by a Note that allows the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period ,

provided no operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to meet the minimum boron concentration of LCO 3.9.1. Boron concentration reduction with coolant at boron concentrations less than required to assure minimum required RCS boron concentration is maintained is prohibited because uniform concentration distribution cannot be ensured without forced circulation . This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period , decay heat is removed by natural convection to the large mass of water in the refueling cavity.

The acceptability of the LCO and the LCO NOTE is based on preventing boiling in the core in the event of the loss of RHR cooling . However, it has been determined that when the upper internals are in place in the reactor vessel there .is insufficient communication with the water above the core for adequate decay heat removal by natural circulation . As a result, boiling in the core could occur in a relatively short time if RHR cooling is lost. Therefore, during the short period of time that the upper internals are installed, administrative processes are implemented to reduce the risk of core boiling. The availability of additional cooling equipment, including equipment not required to be OPERABLE by the Technical Specifications, contributes to this risk reduction . The plant staff assesses these cooling sources to assure that the desired minimal level of risk is maintained. This is commonly referred to as defense-in-depth.

This strategy is consistent with NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management." (Ref.3)

McGuire Units 1 and 2 B 3.9.5-2 Revision No. 149

RHR and Coolant Circulation - High Water Level B 3.9.5 BASES APPLICABILITY One RHR loop must be OPERABLE and in operation in MODE 6, with the water level ;;::: 23 ft above the top of the reactor vessel flange, to provide decay heat removal. The 23 ft water level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.7, "Refueling Cavity Water Level." Requirements for the RHR System in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the water level < 23 ft are located in LCO 3.9 .6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

ACTIONS RHR loop requirements are met by having one RHR loop OPERABLE and in operation, except as permitted in the Note to the LCO.

If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that which would be required in the RCS for minimum refueling boron concentration . This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

If RHR loop requirements are not met, actions shall be taken immediately to suspend loading of irradiated fuel assemblies in the core. With no forced circulation cooling, decay heat removal from the core occurs by natural convection to the heat sink provided by the water above the core.

A minimum refueling water level of 23 ft above the reactor vessel flange provides an adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading a fuel assembly, is a prudent action under this condition .

If RHR loop requirements are not met, actions shall be initiated and continued in order to satisfy RHR loop requirements. With the unit in MODE 6 and the refueling water level ;;::: 23 ft above the top of the reactor vessel flange, corrective actions shall be initiated immediately.

McGuire Units 1 and 2 B 3.9.5-3 Revision No. 149

RHR and Coolant Circulation - High Water Level B 3.9.5 BASES ACTIONS (continued)

If RHR loop requirements are not met, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded .

The Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is reasonable, based on the low probability of the coolant boiling in that time.

SURVEILLANCE SR 3.9.5.1 REQUIREMENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to prevent thermal and boron stratification in the core . The RCS temperature is determined to ensure the appropriate decay heat removal is maintained . The Surveillance Frequency is based on operating experience, equipment reliability , and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.9.5.2 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation , and pumping of non-

,c ondensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration , such as stand-by versus operating conditions.

McGuire Units 1 and 2 B 3.9.5-4 Revision No. 149

RHR and Coolant Circulation - High Water Level B 3.9.5 BASES SURVEILLANCE REQUIREMENTS (continued)

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump) ,

the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water) , the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found , the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration , or personnel safety. For these locations alternative methods (e.g. , operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. UFSAR, Section 5.5.7.

2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii) .
3. NUMARC 91-06, '"Guidelines for Industry Actions to Assess Shutdown Management".

McGuire Units 1 and 2 B 3.9.5-5 Revision No. 149

RHR and Coolant Circulation-Low Water Level B 3.9.6 B 3.9 REFUELING OPERATIONS B 3.9.6 Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level BASES BACKGROUND The purpose of the RHR System in MODE 6 is to remove decay heat and sensible heat from the Reactor Coolant System (RCS), as required by GDC 34, to provide mixing of borated coolant, and to prevent boron stratification (Ref. 1). Heat is removed from the RCS by circulating reactor coolant through the RHR heat exchangers where the heat is transferred to the Component Cooling Water System. The coolant is then returned to the RCS via the RCS cold leg(s). Operation of the RHR System for normal cooldown decay heat removal is manually accomplished from the control room. The heat removal rate is adjusted by controlling the flow of reactor coolant and component cooling water through the RHR heat exchanger(s) . Mixing of the reactor coolant is maintained by this continuous circulation of reactor coolant through the RHR System.

APPLICABLE If the reactor coolant temperature is not maintained below 200°F, boiling SAFETY ANALYSES of the reactor coolant could result. This could lead to a loss of coolant in the reactor vessel. Additionally, boiling of the reactor coolant could lead to a reduction in boron concentration in the coolant due to the boron plating out on components near the areas of the boiling activity. The loss of reactor coolant and the reduction of boron concentration in the reactor coolant will eventually challenge the integrity of the fuel cladding, which is a fission product barrier. Two trains of the RHR System are required to be OPERABLE, and one train in operation, in order to prevent this challenge.

The RHR System satisfies Criterion 4 of 10 CFR 50.36 (Ref. 2) .

LCO In MODE 6, with the water level< 23 ft above the top of the reactor vessel flange, both RHR loops must be OPERABLE .

Additionally, one loop of RHR must be in operation in order to provide:

a. Removal of decay heat;
b. Mixing of borated coolant to minimize the possibility of criticality; and
c. Indication of reactor coolant temperature.

McGuire Units 1 and 2 B 3.9.6-1 Revision No. 149

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES LCO (continued)

An OPERABLE RHR loop consists of an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs. The operability of the operating RHR train and the supporting heat sink is dependent on the ability to maintain the desired RCS temperature.

Management of gas voids is important to RHR System OPERABILITY.

Both RHR pumps may be aligned to the Refueling Water Storage Tank to support filling the refueling cavity or for performance of required testing .

APPLICABILITY Two RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MODE 6, with the water level < 23 ft above the top of the reactor vessel flange, to provide decay heat removal. Requirements for the RHR System in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS) . RHR loop requirements in MODE 6 with the water level ~ 23 ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level."

ACTIONS A.1 and A.2 If less than the required number of RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status and to operation or until ~ 23 ft of water level is established above the reactor vessel flange . When the water level is

~ 23 ft above the reactor vessel flange, the Applicability changes to that of LCO 3.9.5, and only one RHR loop is required to be OPERABLE and in operation . An immediate Completion Time is necessary for an operator to initiate corrective actions.

If no RHR loop is in operation , there will be no forced circulation to provide mixing to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation . Introduction of coolant inventory must be from sources that have a boron concentration greater than that which would be required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation .

McGuire Units 1 and 2 B 3.9.6-2 Revision No. 149

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES ACTIONS (continued)

If no RHR loop is in operation, actions shall be initiated immediately, and continued, to restore one RHR loop to operation. Since the unit is in Conditions A and B concurrently, the restoration of two OPERABLE RHR loops and one operating RHR loop should be accomplished expeditiously.

If no RHR loop is in operation, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures that dose limits are not exceeded. The Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is appropriate for the majority of time during refueling operations, based on time to coolant boiling, since water level is not routinely maintained at low levels.

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability, prevent vortexing in the suction of the RHR pumps, and to prevent thermal and boron stratification in the core. The RCS temperature is determined to ensure the appropriate decay heat removal is maintained. In addition, during operation of the RHR loop with the water level in the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met.

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

SR 3.9.6.2 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation . Verification is performed by verifying proper breaker alignment and power available to the required pump. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

McGuire Units 1 and 2 B 3.9.6-3 Revision No. 149

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.6.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump),

the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration , or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible McGuire Units 1 and 2 B 3.9.6-4 Revision No. 149

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES SURVEILLANCE REQUIREMENTS (continued) location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. UFSAR, Section 5.5 .7.

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

McGuire Units 1 and 2 B 3.9.6-5 Revision No. 149