MNS-17-031, License Amendment Request for Temporary Changes to Technical Specifications to Address an 'A' Train Nuclear Service Water System (Nsws) Non-Conforming Condition

License Amendment Request for Temporary Changes to Technical Specifications to Address an 'A' Train Nuclear Service Water System (Nsws) Non-Conforming Condition

ML17262A090
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/14/2017
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
MNS-17-031
Download: ML17262A090 (81)

Text

{{#Wiki_filter:(~ DUKE Steven D. Capps ENERGY<< Vice President McGuire Nuclear Station Duke Energy MG01 VP I 12700 Hagers Ferry Road Huntersville, NC 28078 o: 980 .875.4805 f: 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 50.90 September 14, 2017 Serial: MNS-17-031 U.S. Nuclear Regulatory Commission Washington , DC 20555-001 ATTENT ION : Document Control Desk Duke Energy Carolinas , LLC (Duke Energy) McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17

Subject:

License Amendment Request for Temporary Changes to Technical Specifications to address an 'A' Train Nuclear Service Water System (NSWS) Non-Conforming Condition Technical Specifications (TS) Sections: 3.5.2, Emergency Core Cooling System (ECCS) - Operating 3.6.6, Containment Spray System (CSS ) 3.7.5, Auxil iary Feedwater (AFW) System 3.7.6, Component Cooling Water (CCW) System 3.7.7, Nuclear Service Water System (NSWS) 3.7.9, Control Room Area Ventilation System (CRAVS) 3.7.11 , Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) 3.8.1, AC Sources - Operating References :

1. Duke Energy letter MNS-15-026 , McGuire Nuclear Station , Units 1 and 2, License Amendment Request for Temporary Changes to Technical Specifications for Correction of an 'A ' Train Nuclear Service Water System (NSWS) Degraded Condition , dated June 30, 2015 (ADAMS Accession No. ML15191A025)

2. NRC letter, McGuire Nuclear Station, Units 1 and 2: Issuance of License Amendment Regarding Nuclear Service Water System Allowed Outage Time Extension (GAG Nos.

MF6409 and MF6410) , dated March 16, 2016 (Accession No. ML15306A141 )

US Nuclear Regulatory Commission September 14, 2017 Page 2 In accordance with the provisions of 10 CFR 50.90, Duke Energy proposes a license amendment request (LAR) for the Renewed Facility Operating Licenses (FOL) and Technical Specifications (TS) for the McGuire Nuclear Station , Units 1 and 2, to allow temporary changes to TS 3.5.2, Emergency Core Cooling System (ECCS) - Operating; TS 3.6.6, Containment Spray System (CSS); TS 3.7.5, Auxiliary Feedwater (AFW) System; TS 3.7.6, Component Cooling Water (CCW) System; TS 3.7.7, Nuclear Service Water System (NSWS); TS 3.7.9, Control Room Area Ventilation System (CRAVS); TS 3.7.11 , Auxiliary Building Filtered Ventilation Exhaust System (ABFVES), and TS 3.8.1 , AC Sources- Operating . The proposed amendment will permit the 'A' Train NSWS to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity, or by March 31 , 2019, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS pumps will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS piping from the SNSWP is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Currently, the 'A' Train NSWS piping from the SNSWP is classified as Operable But Non-conforming (OBDN) due to the piping not functioning as originally designed and exhibiting significantly less margin when compared to the 'B' Train Piping . The activities associated with the 'A' Train NSWS piping are necessary to address the OBDN condition . Duke Energy submitted a similar LAR to the NRC on June 30, 2015 (Reference 1) with supplemented letters dated August 11 , 2015, September 24, 2015, October 8, 2015, December 7, 2015, February 10, 2016, and February 25, 2016. The NRC issued the license amendment on March 16, 2016 (Reference 2) to permit the 'A'Train NSWS to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the SNSWP. The 14 days were to be taken by March 1, 2017. An effort was undertaken to resolve the non-conforming condition by accepting the condition as-is and bringing it into the MNS licensing basis under 10 CFR 50.59. That effort was not successful. As a result, the piping inspection was not performed by the 2017 deadline. The project scope has been simplified and is described in Attachment 1. This new LAR received a detailed review by plant personnel and the Management staff. As a result, several enhancements and changes were made. These changes do not adversely impact the LAR justification . A summary of those changes is provided in Attachment 1 Section 1.0. Also similar to the June 30 , 2015 LAR, this LAR is being subm itted using a deterministic approach that contains risk insights. Attachment 1 provides Duke Energy's evaluation of the LAR which contains a description of the proposed changes , the technical evaluation , the regulatory evaluation , the determination that this LAR contains No Significant Hazards Considerations, the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement, and precedents for the LAR.

US Nuclear Regulatory Commission September 14, 2017 Page 3 provides a marked-up version of the affected TS. Reprinted (clean) TS pages will be provided to the NRC prior to issuance of the approved amendment. provides a marked-up copy of the TS Bases changes for information only. provides marked-up Nuclear Service Water System (NSWS) flow diagrams and piping diagrams to support information provided in Attachment 1. provides the Regulatory Commitments made in support of this LAR Duke Energy requests NRC review and approval of this LAR by January 31 , 2018, in order to support the activities on the 'A' Train NSWS suction piping from the SNSWP, currently scheduled for the spring of 2018. Pursuant to 10CFR50.91, a copy of this LAR has been forwarded to the appropriate North Carolina state officials . Please direct any comments or questions regarding this submittal to Jeff Thomas at (980) 875-4499. I declare under penalty of perjury that the foregoing is true and correct. Executed on September 14, 2017. Sincerely, jJlJ{'ef Steven D. Capps Attachments:

1. Evaluation of Proposed Amendment

2. Marked-up McGuire Technical Specification Pages

3. Marked-up copy of the McGuire Technical Specification Bases Pages

4. Marked-up copy of the NSWS simplified flow diagrams and piping diagrams

5. Regulatory Commitments

US Nuclear Regulatory Commission September 14, 2017 Page 4 cc w/ Attachments: C. Haney, Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave ., NE, Suite 1200 Atlanta, GA 30303-1257 A. Hutto, NRC Senior Resident Inspector McGuire Nuclear Station M. Mahoney, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 W. L. Cox, 111 , Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh , NC 27699-1645

ATTACHMENT 1 EVALUATION OF PROPOSED AMENDMENT 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 System Description 3.2 OBDN Resolution Discussion 3.3 Description of Activities during AOT 3.4 Defense in Depth Considerations 3.5 Compensatory Measures and Commitments 3.6 Compliance with Current Regulations 3.7 Evaluation of Safety Margins 3.8 Configuration Risk Management 3.9 Conclusions

4.0 REGULATORY EVALUATION

4.1 Appl icable Regulatory Requirements/Criteria 4.2 Precedents 4.3 Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

S

1.0

SUMMARY

DESCRIPTION The proposed license amendment request (LAR) will permit the 'A' Train Nuclear Service Water System (NSWS) to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity, or by March 31 , 2019, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS pumps will remain aligned to Lake Norman. After the system has been restored , post maintenance testing will require that the 'A' Train NSWS be aligned to the SNSWP to restore operability and exit the TS action. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the SNSWP supply to 'A' Train NSWS is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time . The alignment of 'A' Train NSWS to the Lake Norman water source during this activity is consistent with the normal plant operating alignment. The alignment is also consistent with the Engineering Safety Features Actuation System (ESFAS) response alignment (i.e. Safety Injection). The piping to be removed from service during this activity affects the assured water source for the 'A' Train NSWS. The assured water source for 'A' Train NSWS is the SNSWP. This water source is only necessary for a low probability seismic event that adversely impacts the Lake Norman dam or the Lake Norman water supply to the NSWS. See Figures 1-9 in that depict the alignments and features described in this LAR. The operability of 'B' Train NSWS is not affected by the proposed changes . For defense-in-depth , the 'B' Train NSWS will be placed in its ESFAS alignment to the SNSWP water source prior to starting the LAR activity and remain in this alignment until the 'A' Train NSWS SNSWP water source is restored and ready for post maintenance testing . The SNSWP water source and piping are seismically qualified for both 'A' and 'B' Train NSWS. Procedures will be established to provide an additional defense in depth contingency that could be used in the event of an extremely low probability of a loss of the Lake Norman water source due to a seismic event. The procedures will ensure that system operation is maintained within design limits (less than or equal to 2 NSWS pumps running on a header), control of maximum system flow, and that system configuration prevents interaction of the degraded equipment with the functional equipment (See Figure 7: "Contingency for Loss of 'B' NSWS pump After Response to Loss of Lake Norman" in Attachment 4 ). Fukushima Response FLEX modifications have been installed and the FLEX strategies will be available for implementation as additional defense-in-depth on both units. It is expected that both units will remain in Mode 1 during the activity and no discretionary maintenance or discretionary testing will be planned on either NSWS Train except for the 'A' Train NSWS piping to the SNSWP. Currently the 'A' Train NSWS piping from the SNSWP is classified as Operable But Non-conforming (OBDN) due to the piping not functioning as originally designed and exhibiting significantly less margin when compared to the 'B' Train Piping . The identification and resolution of the 'A' Train NSWS SNSWP supply piping non-conforming condition is necessary to resolve the OBDN condition. The proposed LAR is a simplified version of the amendment issued by the NRC on March 16, 2016. This approved amendment contained additional activities related to the installation of a second manway for personnel access between the auxiliary building wall and Page 2 of 35

the first isolation valve in the 'A' Train SNSWP supply piping for a personnel egress/ingress path. The project scope in this proposed license amendment request has been simplified by removing the planned installation of the second manway. Duke Energy has determined that an additional personnel access manway is not necessary to remove the obstruction . This new LAR received a detailed review by plant personnel and the Management staff. As a result, several enhancements and changes were made. These changes do not adversely impact the LAR justification. A summary of those changes is provided below.

• The OBDN condition has been re-classified from "degraded" to "non-conforming." The

        'A' Train of NSW was considered degraded due to marginal pump NPSH when aligned to the SNSWP. Since 2015, when the first LAR was submitted , the NSWS flow balance calculation and performance test procedures have been revised to ensure each NSWS train was capable of providing the required flowrates to each required component while also ensuring that each NSWS pump was supplied with acceptable NPSH . The 'A' Train remains non-conforming to the MNS licensing basis since the 'A' Train piping from the SNSWP is not functioning as originally designed and exhibiting significantly less margin when compared to the 'B' Train piping .

• Commitment 1 is revised to remove the requirement to operate the 'A' Train NSWS pumps during the 14 day extended Completion Time . The Commitment to align the 'A' Train of NSWS to Lake Norman will remain. Commitment 3 is revised to remove the requirement to keep the 'B' Train NSWS pumps in standby. The Commitment to align the 'B' Train of NSWS to the SNSWP will remain. These changes allow for operational flexibility to swap operating trains if needed for required testing or maintenance. As stated in Commitment 6, discretionary testing and maintenance will not be performed.

These Train alignments maintain the NSW system in its ESFAS response alignment. The 'A' Train of the NSWS will remain the preferred operating train .

• For Commitment 5, FLEX strategies, the reference to installing FLEX modifications has been deleted since they are now installed and complete . FLEX strategies remain a commitment.
• All commitments associated with the installation of the second personnel manway in the Auxiliary Building are not needed since this manway will not be installed or utilized .

These Commitments were ; 8, 9, 10, 11 , 13, 14, 22, 26, 29, 31 ,and 32.

• Section 3.1, the "Description of Activities" table has been enhanced with no major changes .
• Commitment 21, list of "Protected Equipment, " the Auxiliary Building WZ sump pumps were removed since they were associated with the second personnel manway which will not be installed . The MNS Switchyard was added .
• Commitment 24, the requirement to perform system performance testing following restoration of the 'A' Train of NSWS, has been deleted since this is redundant to normal, required operability testing. The Duke Energy Fleet Testing procedure requires that all appropriate testing be performed following maintenance to verify that a system , structure or component (SSC) may be returned to service. SSCs shall be tested following maintenance to ensure; the Page 3 of 35

SSC is capable of performing its intended function , the deficiency was corrected, and that the maintenance activity did not create a new deficiency. The appropriate level of testing will be completed based on the A train work performed .

• Commitment 27, manually create a YELLOW risk condition within the ERAT program ,

has been deleted since this is not necessary and redundant to Commitments 6 (no discretionary maintenance or testing), 12 (control activity under the "Infrequently Performed Test or Evolution" process), and 21 (protected equipment). These commitments already focus site attention on the significance of the proposed activity. 2.0 DETAILED DESCRIPTION The proposed LAR would revise TS Action 3.5.2 A.1, TS Action 3.6.6 A.1 , TS Action 3.7.5 B.1, TS Action 3.7.6 A.1 , TS Action 3.7.7 A.1 , TS Action 3.7.9 A.1 , TS Action 3.7.11 A.1 , and TS Action 3.8.1 B.4 to add a note similar to the following that states:

       "[Applicable TS System] 'A' Train is allowed to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity, or by March 31, 2019, whichever occurs first.

During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time . Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments described in MNS LAR submittal correspondence letter MNS-17-031 ." The TS actions affected by this LAR are applicable in Modes 1-4 with the exception of TS 3.5.2 A.1 which is applicable in Modes 1-3 and TS 3.7.9 which is applicable in Modes 1-6. The activity described in this LAR is expected to be performed with both units in Mode 1. The marked-up TS pages illustrating the proposed change are provided in Attachment 2.

Background:

The Ultimate Heat Sink (UHS) for McGuire is the SNSWP. Lake Norman , with an approximate volume of 1,093,000 acre-feet, provides the highest net positive suction head to the Nuclear Service Water (NSW) Pumps, and normally serves as the heat sink cooling water reservoir. As an Engineered Safety Feature (ESF), the Lake Norman Low Level Intake (LU) source is automatically aligned to supply the NSW 'A' Trains of both units following a safety injection signal from either unit or the loss of offsite power (LOOP) on either unit. Cowan 's Ford Dam , impounding Lake Norman , is qualified for an Operating Basis Earthquake (OBE), or approximately one-half Safe Shutdown (Design Basis) Earthquake (SSE). Due to the fact that Page 4 of 35

the Lake Norman water supply is not qualified to a SSE this water supply is not cred ited for postulated seismic events. While the Lake Norman water supply is only qualified to an OBE, a Seismic Fragility Assessment of the McGuire Low Level Intake Water Pipeline performed for Duke Energy in December of 2011 indicates that the dam and water supply would withstand a SSE. This is documented in Duke Energy calculation titled McGuire Low Level Intake Water Pipeline Seismic Fragility Assessment. The SNSWP, which is qualified for an SSE, serves as the most severe natural phenomena heat sink cooling water reservoir. Two lines (Train 'A' and Train 'B') are provided from the SNSWP to meet single failure criteria should a seismic event cause loss of Cowan 's Ford Dam and resulting loss of Lake Norman. All supply and discharge piping for the SNSWP is seismically qualified. As an Engineered Safety Feature, the Train 'B' SNSWP supply is automatically aligned to supply the 'B' Trains of both units following a safety injection signal from either unit or a LOOP on either unit. Testing performed in 2009 indicated that the Unit 1 and 2 'A' Train NSWS pumps were close to or at the required net positive suction head (NPSH) when aligned to the SNSWP with both Unit 1 and 2 'A' Trains operating at approximately 10,000 gpm . Based on these testing results and further evaluation it was determined that 'A' Train NSWS pump suction pressure had been significantly lower than that of the 'B' Train since prior to 1988. Testing has confirmed Unit 1 and 2 'B' Train NSWS operabil ity is not impacted . Visual inspections of the 'A' Train NSWS supply piping were limited to the first several hundred feet of the approximate 2,000 feet of the NSWS piping from the SNSWP based on the capabilities of commercial divers. The results of an Acoustic Reflectometry inspection of the 'A' Train NSWS piping from the SNSWP performed in 2011 indicated a sizable flow restriction located approximately 1,500 feet downstream of the suction point from the SNSWP. However, a subsequent remotely operated vehicle (ROV) video survey inspected the piping out to 1,800 feet and did not identify any cond itions that would have restricted NSWS flow. The last segment of piping could only be inspected in a safe and reliable manner after a deep well manway was installed closer to the area to be inspected . The well for the manway was recently installed and the 'A ' NSWS piping was wet tapped to allow access into the pipe from the manway. The manway provides personnel access to the last segment of piping for removal of the obstruction . See Figures 8 and 9 in Attachment 4. A new inspection of the remaining 'A' Train NSWS piping is planned to confirm the location and size of this anomaly. The inspection of the last section of piping will be conducted subject to existing TS 3.7.7 completion time .

'A' Train NSWS is normally aligned to Lake Norman and would not be subject to the NPSH condition described above. However, if the 'A' Train were to be manually aligned to the SNSWP, the flow rates could be high enough to challenge the 'A' Train NSWS pump required NPSH. Based on this condition , the 'A' Train NSWS piping from the SNSWP was determined to be OBDN due to the piping not functioning as originally designed and exh ibiting significantly less margin when compared to the 'B' Train Piping .

System modeling determined that general corrosion and differences between 'A' and Page 5 of 35

'B' Train NSWS pipe geometry was unlikely to be the primary cause of suction pressure differences observed on the 'A' Train NSWS pumps. The pipe inspection activity will require 'A' Train NSWS be aligned to be Lake Norman until the system is ready for post maintenance testing (see Figure 6: NSWS Alignment During 14 Day Out of Service Window, in Attachment 4). This is the normal and ESFAS alignment for 'A' Train NSWS. The 'A Train' NSWS supply from the SNSWP will be closed with power removed from the motor operated valve ORN-7A (see Figure 5: Piping to Be Removed from Service during the Extended Completion Time , in Attachment 4 ). This will remove the capability to manually align the 'A' Train NSWS to the SNSWP in response to a seismic event that results in damage to the supply piping from Lake Norman or the highly improbable loss of Lake Norman. If such an event should occur during the activities in the proposed amendment, 'B' Train NSWS will supply all necessary needs to maintain the Ultimate Heat Sink Safety Function . Station procedures require that the 'A' and 'B' Trains of the NSWS be aligned to the SNSWP for a loss of LLI or an earthquake equal to or greater than an QBE. This is the only time that 'A' Train NSWS is required to be aligned to the SNSWP except for testing and maintenance activities. In all other cases , 'A' Train NSWS is aligned to the Lake Norman water source. Additionally, the McGuire earthquake response procedure requires that the operating units be shutdown and cooled down to Hot Standby (Mode 3) within six (6) hours following an OBE. If an SSE occurs, this procedure requires that the units be shutdown and cooled down to Cold Shutdown (Mode 5) within thirty (30) hours. This amendment is proposed to avoid an unnecessary Unit 1 and 2 (dual unit) shutdown. Entry into and operation of shutdown cooling is not without risk as it involves significant plant manipulations and evolutions on both the plant primary and secondary systems by Operations personnel. This risk is averted by remaining at power. By performing this activity with both units on-line, the ab ility of plant personnel (Operations, Maintenance, and Plant Management) to focus on the NSWS activity will be enhanced , which is expected to improve Nuclear Safety with minimal risk. This is a one-time change in support of the inspection and resolution activity. A permanent TS change is not being requested . The March 31 , 2019 expiration date is needed to provide flexibility for the scenario in which the NSW piping inspection reveals an unanticipated condition that requires additional planning and resources to be developed before correcting the non-conforming condition .

'A' Train NSWS Repair Evolution :

The location of the restriction appears to be in the 'A' Train NSWS piping under the station 's Unit 2 Emergency Diesel Generator (EOG) building . Before starting the NSWS repair evolution a survey is planned to confirm the location , size and characterization of the restriction . The survey will be conducted under the existing TS 3.7.7 completion time of 72 hours. If the survey results conclude that the repair activity is needed and can be successfully completed , then the clock for the 14 day completion time authorized by this LAR will start. The 14 day completion time extension is based on the most likely scenario for the OBDN cond ition which is that a fixed construction artifact in the 'A' NSWS piping is restricting flow to the suction of the 'A' NSWS pumps from the SNSWP. The scope of planning for th is activity Page 6 of 35

includes actions to extract the debris and complete any minor repairs associated with removal of the debris. The scope of the activity does not allow for major excavation or activities that would adversely affect other Safety Related SSCs or Functions. Identification of a condition in which repairs could impact the ability of an SSC to perform its Safety Function would result in termination of activities and restoration of 'A' Train NSWS to the current OBDN condition. If the results of the planned survey identify a condition that the station cannot resolve within the 14 day completion time , then the NSW system will be restored to its current OBDN condition and the use of the 14 day completion time will be postponed until the necessary evaluation and planning can be completed to perform the evolution within the 14 day completion time. Delay of the object recovery activity would be acceptable as long as operability of the NSWS is not impacted. On the other hand, if the survey presents any opportunities for a less intrusive or less time consuming solution for addressing the OBDN condition , then these opportunities will be pursued , as appropriate and use of the 14 day completion time to address the repair will be minimized . Foreign Material Exclusion (FME) will be controlled during the proposed activities in accordance with AD-MN-ALL-0002 , Foreign Material Exclusion (FME). Any debris resulting from the obstruction removal activity will be mechanically cleaned out before the system is closed for return to service per FME plan developed in accordance with the above procedure. The 'A' NSWS piping will also be inspected prior to closeout. The system will then be reversed flushed from the LU to the SNSWP with isolation to downstream components to force any sediment back to the SNSWP. Following 'A' Train restoration, system testing will be performed to verify that the NSWS performance meets operability requirements. Systems Affected by a NSW System Outage: The impact of the proposed TS changes on the operation of the ECCS, CSS, AFW , CCW, NSWS, CRAVS, ABFVES , EOG and the Control Room Area Chilled Water (CRACWS) systems due to the NSW System repair activities during the requested 14 day period was evaluated . Although considered inoperable , the 'A' EDGs and 'A' Train NSWS and their supported systems will be technically capable of performing their intended functions barring the highly improbable loss of Lake Norman . The operation of 'B' Train NSWS is not affected by the proposed changes. The CRAVS , ABFVES , and CSS are expected to remain in their normal operating alignments during the time that the temporary TS changes would be enacted . These systems will be operated in accordance with their respective normal operating procedures during the extended completion time. The 'A' Train safety related systems supported by NSWS will remain functional while the temporary TS changes are in affect but not operable due to the unavailability of the NSW flow path from the 'A' SNSWP. These systems remain capable of meeting their individual safety functions for all design bases events excluding the loss of the LU caused by a significant seismic event. The 'B' Train NSWS and all supported SSCs are expected to remain operable during the time that the temporary TS changes would be enacted . No systems deviations for CSS or CRAVS are expected or planned NSWS TS 3.7.7 requires additional entry into TS 3.8.1 for the associated EOG and TS 3.4.6, "Reactor Coolant System Loops - Mode 4" for the associated Residual Heat Removal (RHR) Page 7 of 35

loop made inoperable by the inoperable NSWS Train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components . During the NSW System Train 'A' repair, Units 1 and 2 will be in Mode 1; therefore, the requirement to enter TS 3.4.6 should not be necessary. If entry into TS 3.4.6 becomes necessary, the associated Limiting Condition for Operation will be met. No other TSs are required by TS 3.7.7 to be directly entered . The NSW System is the safety-related source of water supply to the AFW system . During the 'A' NSW Train outage, this source will be inoperable but functional for all postulated events except for the seism ic event that takes away the Lake Norman water source. The normal non-safety related water sources for the 'A' Train AFW motor driven pumps will remain functional , as will the water source from the Standby Shutdown System . The 'B' Train motor driven AFW pumps and the turbine driven AFW pump on each unit will still have a safety-related source of water supply from the operable 'B' Train of NSW.

3.1 System Description

Nuclear Service Water System (NSWS): As discussed in Section 9.2.1 of the UFSAR, the NSW System provides an assured source of cooling water for various Auxiliary Building and Reactor Building heat exchangers during all phases of station operation. Each Unit has two redundant "essential-headers" serving two Trains of equipment necessary for safe station shutdown , and a "nonessential header" serving equipment not required for safe shutdown. In conjunction with the Ultimate Heat Sink [the Standby Nuclear Service Water Pond (SNSWP)], the NSW System is designed to meet design flow rates and heads for normal station operation and those required for normal safe station shutdown or shutdowns resulting from a postulated Loss of Coolant Accident (LOCA). The system is further designed to tolerate a single failure following a LOCA on one unit with a controlled shutdown on the alternate Unit concurrent with a loss-of-offsite power on both units, or a seismic event causing a loss of Lake Norman resulting in controlled shutdown on both Units concurrent with a LOOP on both Units. Portions of the NSW System are shared between the two McGuire Units (See Figure 1: Nuclear Service Water System in Attachment 4). The shared valves (designated by the prefix "O") associated with the main supply and discharge sections of the NSWS may be powered and controlled from either Unit 1 or 2. The motor control centers (MCCs) supplying these valves are safety related and are shared between both Units. Normally, the MCCs receive power from their respective Unit's 600 volt load center. However, if this normal source of power is lost then the operator can manually transfer the MCCs incom ing power to the opposite Unit's 600 volt load center through the use of a kirk key interlock. Normal Operation: The NSW System is made up of fi ve sections which , when put together in series, provide an assured source of water for all the station safety related water demands and some non-safety related demands. These sections are: the main supply section , the NSW strainer/pump section, the NSW heat exchanger section, the NSW main discharge section , and the crossover valving section . The NSW System is designed to meet single fa ilure criteria , with two redundant trains per unit to serve components essential for safe station shutdown . Train 'B' components and piping provide Page 8 of 35

100% backup to Train 'A' components. Engineered Safety Features provide for automatic valving and component actuation for both trains of the unit affected, while non-safety related components are isolated and shut off. Train 'A' and 'B' Main Supply and Discharge Crossover double valving is also closed by an Engineered Safety Feature assuring train integrity. The five basic sections of the NSW System are discussed in the following paragraphs:

1. Main Supply Section:

The main supply section of the NSW System includes the Low Level Intake (LLI) Cooling Water System, the Condenser Circulating Water System (CCW), the Standby Nuclear Service Water Pond (SNSWP) and all piping and valves up to and including the train supply isolation valves preceding the NSWS strainers.

a. As the normal source of water from Lake Norman, the single line from the LLI Cooling Water system, the inlet of which is located at approximately 650 foot elevation, provides water to both trains of NSWS pumps . Covering the inlet is a macro-fouling barrier comprised of a stainless steel mesh 3/4 inch center to center measurement in a square pattern . These panels are inspected periodically. Should any of the Train 'A' redundant safety-related components malfunction, the corresponding Unit's 'A' NSWS pump is shut down and the "B' NSWS pump started , supplying the Unit's Train 'B' heat exchangers. As an Engineered Safety Feature, this LLI supply is automatically aligned to supply the

               'A' Trains of both Units following a Safety Injection signal from either unit or a LOOP on either unit.

Alewife fish have tended to concentrate at elevations similar to the LLI structure during very brief periods in summer. Since velocities at the LLI are low, the intake structure macro-fouling barrier acts as a "fence" to prevent movement of Alewife into the LLI structure.

b. A secondary source of water is available from the CCW supply cross-over.

However, this alignment is not normally used .

c. Two lines are provided from the SNSWP to meet single failure criteria should a seismic event cause loss of Cowan's Ford Dam and resulting loss of Lake Norman . As an Engineered Safety Feature, the Train 'B' SNSWP supply is automatically aligned to supply the 'B' Trains of both Units following a Safety Injection signal from either unit or a LOOP on either unit. The Train 'A' SNSWP supply then acts as a 100% backup should any Train 'B' component fail to function property. Each Train is of sufficient size to provide total station flow for a Unit LOCA and a Unit cooldown . For accidents or design events where Lake Norman remains available , it is highly probable that Train 'B' would be realigned to Lake Norman since it would provide the highest system performance .

The corrective actions taken to eliminate macro-fouling of the NSWS strainers from the SNSWP are discussed in Duke Energy's letter of April 1, 2011 (ADAMS Accession ML111020305). These include periodic hydro acoustic surveys and the installation of a macro-fouling barrier at the NSWS intake pipes in the SNSWP. In addition , underwater live cameras were installed in June 2015 and are used to Page 9 of 35

monitor fish concentrations in the area above the LLI structure.

2. NSW Strainer and Pump Section:

a. Strainers are of the automatic backwash type , and backwash discharge is automatically in service when the respective Nuclear Service Water pump is started . The normal backwash discharge pump flow path returns to the NSW return header, thus preventing any unnecessary loss of water from the SNSWP for all design basis events that require the use of the UHS. Backwash Supply is provided by NSW from the NSW pump discharge when a pressure drop across the strainer reaches a predetermined value . Safety related assured air supply is available to the strainer supply isolation valve to permit operation in the event of a Safety Injection Signal or a Loss of Instrument Air. The strainer drum motors and strainer backwash discharge pumps are powered by normal and emergency sources . The strainer function is in service during normal and accident conditions .

b. Normally, only one NSWS pump per unit is in operation, as each pump meets system maximum flow requirements, but as an Engineered Safety Feature , all available pumps are automatically started upon a Safety Injection signal or loss of station and offsite power. Only one train is necessary, so the redundant train is maintained in standby. Each NSWS pump is supplied with power from separate normal and emergency sources. Emergency power is provided to each NSWS pump from its corresponding train EOG, thereby assuring a continuous flow of water under all conditions . Each NSWS pump motor receives cooling water from its corresponding NSWS pump discharge at all times while that pump is in operation.

3. Heat Exchanger Section:

a. The following components and emergency water supplies are essential for safe plant shutdown , therefore they are redundant for each Unit and served by corresponding redundant trains of the NSWS. The following are also designed for operation during and after seismic conditions :

i. Coolers for:

1. Component Cooling Pump Motors

2. Centrifugal Charging Pump Motors

3. Safety Injection Pump Motors

4. Residual Heat Removal Pump Motors

5. Containment Spray Pump Motors

6. Nuclear Service Water Pump Motors

7. Auxiliary Feedwater Pump Motors

8. Fuel Pool Cooling Pump Motors ii. Containment Spray Heat Exchangers iii. Diesel Generator Heat Exchangers iv. Component Cooling Heat Exchangers

v. Centrifugal Charging Pump Bearing Oil Coolers vi . Centrifugal Charging Pump Gear Oil Coolers vi i. Assured Auxiliary Feedwater Supplies viii . Assured Diesel Generator Cooling Supplies Page 10 of 35

ix. Assured Fuel Pool Makeup Supplies (normal makeup from FWST)

x. Assured Component Cooling Supplies xi. Safety Injection Pump Bearing Oil Coolers xii. Control Room Area Chilled Water System Chiller Condensers (shared between Units)

b. Each Train of the NSWS provides assured auxiliary feedwater to the AFW System. Each motor driven AFW pump motor is cooled and supplied with suction from its corresponding train of the NSW System. The steam turbine driven AFW Pump (suction) is supplied from whichever train of the NSW System is in operation . Nuclear Service Water is used for feedwater only when the normal condensate supplies for the AFW System are unavailable.

c. The following components are not redundant since they are not essential for safe shutdown. Water is supplied to these components during normal operation , but are automatically isolated from the NSW supply and return on receipt of a Safety Injection Signal:

i. Reciprocating Charging Pump Bearing Oil Cooler ii. Reciprocating Charging Pump Fluid Drive Oil Cooler iii. The Upper Containment Ventilation Units iv. The Lower Containment Ventilation Units

v. The Auxiliary Build ing Ventilation Units The Reactor Coolant Pump motor air coolers are not essential for safe shutdown , but are set up to receive cooling water flow until the Containment high/high pressure setpoint of 3 psig is received.

4. Main Discharge Section:

a. During normal operation with supply from the LLI at Lake Norman , water returns to Lake Norman via the NSW system CCW return line to the CCW crossover header in the Turbine Building .

When NSWS requirements are being supplied by 'B' Train NSWS supply line from the SNSWP, NSWS flow return to the pond is accomplished by the 'B' Train NSWS return line. Complete , 100% redundancy of safety related components and piping is provided by Train 'A' component heat exchangers, supply, and return piping to the SNSWP.

5. Crossover Valving :

At the interface of each section of the Nuclear Service Water System with the next section, there are crossover lines with double isolation valves . These are identified as follows :

a. Main Supply Crossover valves

b. Pump Discharge Header Crossover valves

c. Main Discharge Crossover valves Page 11 of 35

These valves give the system added flexibility to operate should more than one malfunction occur. As an Engineered Safety Feature, the Main Supply and Main Discharge Crossover valves have electric motor actuators that close upon a Safety Injection signal. This assures Train isolation and properly aligned supply and return to the CCW crossover and SNSWP as outlined previously. Normal NSWS Response to a Safety Signal : Upon receipt of a Safety Injection signal , the following will occur:

1. Both NSWS pumps start (respective strainer backwash discharge pumps start on signal from its main NSWS pump start).

2. The safety related valves associated with 'A' Train NSWS automatically align to Lake Norman via the LLI .

3. The safety related valves associated with NSW Train 'B' automatically align to the SNSWP.

4. The Main Supply and Discharge Crossover valves close .

5. Isolation valves for all heat exchangers which are needed open automatically.

6. All loads on the non-essential header are isolated with the following exceptions:

a. The Reactor Coolant Pump motor air coolers

b. The containment ventilation units (these units are isolated from the NSWS on a safety injection signal ; however the Containment Ventilation Cooling water system will continue to supply these units until a Phase B signal , Containment high-high pressure)

Lake Norman/Low Level Intake (LLI): As an Engineered Safety Feature, the Lake Norman/LLI source is automatically aligned to supply the 'A' Train NSWS for both units following a Safety Injection signal from either unit or the LOOP on either unit. The Cowan 's Ford Dam, impounding Lake Norman , and the LLI are qualified for an Operating Basis Earthquake (0.08g), or approximately one-half Safe Shutdown (Design Basis) Earthquake (0.15g). From the McGuire plant seismicity curves , the 'mean ' ground acceleration curve indicates a 0.08g level earthquake has a probability of exceedance of approximately 5E-4/year. Although this is the estimated probability of exceedance, it is conservative in that it is only the value of exceedance and not the value for causing failure of Cowan 's Ford Dam . Duke Energy performed a Seismic Fragility Assessment of the McGuire Low Level Intake Water Pipeline in December of 2011 . Although not credited in the Current Licensing Basis (CLB) the Page 12 of 35

Fragility Assessment demonstrates that the LLI piping and the associated dam are capable of withstanding the Safe Shutdown Earthquake (SSE). The Cowan's Ford Dam is inspected on an annual frequency by the Federal Energy Regulatory Commission (FERC). In a letter to Duke Energy, dated May 21 , 2015, the following conclusion was documented for the annual inspection completed on April 22, 2015:

        "Based on our site inspection and document review, the development (Cowan 's Ford) has been properly operated and maintained since the previous dam safety inspection .

The Cowan 's Ford development meets Commission engineering dam safety standards and criteria based on site inspection, review of the files , documentation provided by Duke Energy, and discussions with employees on site." Standby Nuclear Service Water Pond (SNSWP): The UHS for McGuire is the SNSWP, with an approximate volume of 550 acre-feet. Lake Norman, with an approximate volume of 1,093,000 acre-feet, provides the highest net positive suction head to the NSWS Pumps, and normally serves as the heat sink/cooling water reservoir. The Standby Nuclear Service Water Pond (SNSWP), which is qualified for a Safe Shutdown Earthquake (SSE), serves as the most severe natural phenomena heat sink/cooling water reservoir. Two lines (Train 'A' and Train 'B') are provided from the SNSWP to meet single failure criteria should a seismic event cause loss of Cowan 's Ford Dam and result in loss of Lake Norman. All supply and discharge piping for the SNSWP is seismically qualified . As an Engineered Safety Feature, the Train 'B' SNSWP supply is automatically aligned to supply the 'B' Trains of both units following a Safety Injection signal from either unit or a LOOP on either unit. SNSWP thermal performance (heat dissipation and flow rate capacity) is verified in calculations showing that the NSW System can adequately handle a large break LOCA on one unit and a controlled shutdown on the other unit with both units aligned to the SNSWP. The system design meets or exceeds the regulatory position requirements as detailed in NRC Regulatory Guide 1.27, "Ultimate Heat Sink for Nuclear Power Plants,' Revision 1, dated March 1974, along with the requirements of 10 CFR Part 100 and GDC 2. The SNSWP is the assured source of water for the NSWS. Emergency Core Cooling System (ECCS): The ECCS consists of three separate subsystems: Centrifugal Charging (high head) pumps, Safety Injection (SI) (intermediate head) pumps, and RHR (low head) pumps. 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 a Loss of Coolant Accident (LOCA), RCS Coolant leakage greater than the capability of the normal charging system ; a Rod Ejection Accident; a Loss of Secondary Coolant Accident, including uncontrolled steam or feedwater release ; or Steam Generator Tube Rupture (SGTR). The major components of each subsystem are the Centrifugal Charging pumps, the RHR pumps, heat exchangers, and the Safety Injection pumps. Each of the three subsystems consists of two 100% capacity trains that are interconnected and redundant such that either Page 13 of 35

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. Containment Spray System (CSS): The Containment Spray System provides containment atmosphere cooling to limit post-accident pressure and temperature in containment to less than the design values, in the event of a Design Basis Accident (OBA). The Containment Spray System also removes fission product iodine from the post-accident containment atmosphere . 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 one 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 . Auxiliary Feedwater System (AFW): The AFW System assures required feedwater flow to the steam generators for reactor coolant thermal energy dissipation when the normal feedwater system is not available through loss of power or other malfunctions . The AFW System is required to operate until normal feedwater flow is restored or until the reactor coolant temperature is lowered to the point where the Residual Heat Removal System can be utilized . The AFW System flow and emergency water supply capacity is sufficient to remove core decay heat, Reactor Coolant Pump heat, and sensible heat during the plant shutdown . The AFW System also serves as an alternate feedwater system during hot standby and shutdown operations whenever conditions are such that shutting down the normal feedwater system appears advantageous. The AFW System can also be used to adjust steam generator water levels to establish wet layup conditions in the steam generators prior to and during plant startup. The AFW System consists of two motor driven AFW pumps and a turbine driven pump configured into three trains . The AFW Pumps can take suction from three different sources. In order of preference, they are the auxiliary feedwater storage tank, the NSW System and the RC System via the NSW System. The auxiliary feedwater storage tank provides the AFW System with condensate grade water and is considered non-safety related . The NSW System provides the safety-related source of water and is considered the assured water source under design basis accident scenarios. The auxiliary feedwater storage tank (one 300,000 gallon tank per unit) is the normally aligned non-safety related condensate quality water source available to the AFW System . The auxiliary feedwater storage tank is continuously kept full with water discharged by the hotwell pumps. Overflow from the auxiliary feedwater storage tank is routed to the auxiliary feedwater condensate storage tanks . The SNSWP serves as the ultimate long-term safety related source of water for the AFW System . The automatic detection and transfer controls of the AFW System will detect and transfer the pump suctions to Nuclear Service Water when suction pressure drops below an Page 14 of 35

acceptable limit. The instrumentation and controls utilized in the switchover logic are safety grade. Component Cooling Water System (CCW): The CCW System provides a heat sink for the removal of process and operating heat from safety related components during a OBA or transient. During normal operation the CCW System also provides this function for various nonessential components, as well as the spent fuel storage pool. The CCW System serves as a barrier to the release of radioactive byproducts between potentially radioactive systems and the NSWS, and thus to the environment. The CCW System is arranged as two independent, full capacity cooling loops, and has isolable nonsafety related components . Each safety related train includes two pumps, surge tank, heat exchanger, piping, valves and instrumentation . Each safety related train is powered from a separate ESF bus. Control Room Area Ventilation System (CRAVS): The CRAVS consists of two independent, redundant trains that draw in filtered outside air and mix this air with conditioned air recirculating through the Control Room Envelope (CRE). Each outside air pressure filter train consists of a 2-stage heater, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal absorber section for removal of gaseous activity (principally iodides), and a fan. The CRAVS is shared between the two units. The system must be operable for each unit when that unit is in the Mode of Applicability. Additionally, both normal and emergency power must also be operable because the system is shared. If a CRAVS component becomes inoperable, or normal or emergency power to a CRAVS component becomes inoperable, then the required actions of the Technical Specifications must be entered independently for each unit that is in the Mode of applicability. Control Room Area Chilled Water System (CRACWS): The CRACWS consists of two independent and redundant trains that provide cooling water to cool recirculated control room air. Each train consists of cooling coils, chillers , instrumentation and controls to provide chilled water for control room temperature control. The CRACWS is a subsystem of the CRAVS and provides air temperature control for the control room . The CRACWS is shared between the two units . The system must be operable for each Unit when that unit is in the Mode of Applicability. Additionally, both normal and emergency power must also be operable because the system is shared . If a CRACWS component becomes inoperable, or normal or emergency power to a CRACWS component becomes inoperable, then the required actions of the Technical Specifications must be entered independently for each unit that is in the Mode of applicability. TS 3.7.10, "Control Room Area Chilled Water System (CRACWS)," Condition A Completion Time allows one Train of CRACWS to be inoperable for a 30 day period. Therefore , regulatory relief is not required . Page 15 of 35

Auxiliary Building Filtered Ventilation Exhaust System (ABFVES): The ABFVES filters air from the area of the active ECCS components during the recirculation phase of a LOCA. The ABFVES, in conjunction with other normally operating systems (NSWS), also provides environmental control of temperature and humidity in the ECCS pump room area and the auxiliary building. The ABFVES consists of a system , made up of prefilter, a HEPA filter, a carbon absorber section for removal of gaseous activity (principally iodides), and two fans. Upon receipt of the actuating Engineered Safety Feature Actuation System signal(s), air is pulled from the mechanical penetration area and the ECCS pump rooms, and the stream of ventilation air discharges through the system filters . The prefilters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA filters and carbon absorbers. The ABFVES is shared between the two units. The system must be operable for each unit when that unit is in the Mode of Applicability. Additionally, both normal and emergency power must also be operable because the system is shared . If an ABFVES component becomes inoperable, or normal or emergency power to an ABFVES component becomes inoperable, then the required actions of the Technical Specifications must be entered independently for each unit that is in the Mode of applicability. Emergency Diesel Generators (EOG): Each train of the 4.16 kV Essential Auxiliary Power System is provided with a separate and independent EDG to supply the Class 1E electrical loads required to safely shut down the unit following a DBA. Each EDG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus under voltage . Each EDG must also be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions. The Diesel Generator Engine Cooling Water System for each diesel includes a jacket water-intercooler water heat exchanger located within the Diesel Room, which is supplied with cooling water from the Nuclear Service Water System . The Diesel Generator Engine Cooling Water System is designed to maintain the temperature of the diesel generator engine within an optimum operating range. The system is also designed to supply cooling water to the engine lube oil cooler, the turbocharger and the governor lube oil cooler. Additional Plant Systems Standby Shutdown System (SSS): The SSS is designed to mitigate the consequences of certain postulated fire incidents, sabotage, or station blackout events by providing capability to achieve and maintain hot standby conditions by controlling and monitoring vital systems from locations external to the main control room. This capability is consistent with the requirements of 10 CFR Part 50, Appendix R and 10 Page 16 of 35

CFR 50.63 . By design, the SSS is intended to respond to those low probability events which render both the control room and automatic safety systems inoperable. The SSS is not seismically designed . As such, the seismic capability of the system is not credited. The SSS power supply consists of an independent, diesel-electric generating unit located in the Standby Shutdown Facility (SSF). The auxiliaries required to assure proper operation of the diesel-generator unit are supplied with power from the appropriate buses of the SSF Power System . This unit has a starting 24V battery system with storage to provide at least two starts. Following loss of normal power, the diesel-electric generating unit shall be manually started and connected to the 600V SSF Power System load center bus. By manually closing the 600V generator breaker, the entire SSF Power System is provided with its backup source of power. The Standby Makeup Pump (SMP) functions as part of the SSS to provide makeup capacity to the reactor coolant system and cooling flow to the reactor coolant pump (RCP) seals. During normal operation the RCP seals are supplied from the Centrifugal Charging Pump (CCP) drawing from the Volume Control Tank (VCT). During the SSS event, the SMP draws water from the Spent Fuel Pool (SFP). The turbine driven AFW pump can be controlled from the SSF and is utilized during an SSS event to maintain adequate secondary side heat removal. FLEX Strategy MNS transmitted a notification of full compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and with Order EA-12-051, "Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" for McGuire Unit 1 in a letter dated November 18, 2014. MNS transmitted a Final Notification of Full Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events" and with Order EA-12-051, "Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation" For McGuire Nuclear Station . The FLEX strategy for MNS was developed in accordance with NEI 12-06 which was endorsed by the NRC in JLD-ISG-2012-01 , Interim Staff Guidance (ISG) Japan Lessons-Learned Project Directorate (JLD), Compliance with Order EA 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, ADAMS Accession No. ML12229A174. The key aspects of the strategy are as follows :

• A large seismically robust reservoir of water that is automatically aligned to the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) if the normal supply is lost due to a severe seismic event and emergency supplies are lost due to a loss of all power event.
• FLEX Support Guidelines that can be used by operations to cool down and de-pressurize the Reactor Coolant System and minimize Reactor Coolant Pump (RCP) seal leakage within the assumptions evaluated in the strategy for preservation of the core cooling function.
• An array of portable water supply equipment and electrical equipment that can be aligned to provide a source of reactor makeup and reactivity control , restore power to vital batteries and provide an even longer term source of secondary heat removal from the UHS.
• Staffing and communications and associated training to support all near term and long term actions that are part of the strategy.
• Additional equipment and procedures from a Regional Response center within a few days of event initiation that can re-establish some electrical power needs and containment cooling.

Page 17 of 35

3.2 Non-Conforming Condition The 'A' and 'B' Train NSWS suction piping configuration to the SNSWP and layout is essentially the same. However, testing indicated that the pressure drop across 'A' train SNSWP suction path is significantly higher than the pressure drop across the 'B' train SNSWP suction path. Additional testing indicated that the Unit 1 and 2 'A' Train NSWS pumps are close to or at the required net positive suction head (NPSH) when both the Unit 1 and 2 'A' Trains are operated at maximum accident flowrate conditions . Historical records indicate that a noticeable difference in pressure drop between the two headers has existed since prior to 1988 when the anomaly was documented in a Design Study. The 'A' suction path has been flushed numerous times since the discovery of this anomaly. Numerous high flow rate flushes support the conclusion that the non-conforming condition causing this pressure drop is stable. The goal of the activities to be performed during the 14 day TS completion time requested by this submittal is to identify the anomaly and correct if possible thereby restoring NPSH margin. Achievement of the goal will be determined following the inspection, repair activities as necessary, and testing of the system by measuring the 'A' Train NSWS inlet pressure and NPSH during the performance of a flush test. The inspection may identify a condition that cannot be resolved within the 14 day completion time. Should such a condition be identified then the system will be restored to its current OBDN condition. If the inspection presents any opportunities for a less intrusive or less time consuming solution for addressing the OBDN condition , then these opportunities will be pursued , as appropriate. Page 18 of 35

3.3 Description of Activities The length of time needed to identify and resolve the 'A' Train NSWS piping non-conforming condition will exceed the 72 hour Completion Time that one NSWS Train can be inoperable as defined in TS 3.7.7. The significant work tasks for removing the obstruction are grouped below under four major activities with duration estimates. ACTIVITY TIME REQU IRED Tagout and Prestaging 12 hours

• Tag out valve ORN-7A and remove 'A' Train Suction piping from service .
• Remove Missile Shield & ORNFA0002 Flange .
• Establish Confined Space & FME controls .
• Install pre-built work platform and Diver retrieval equipment.

Perform Inspection of A RN Piping 12 hours

• Diver to enter 'A' Train piping via ORNFA0002 flange to locate and characterize obstruction .

Extract Blockage 168 hours

• Divers remove obstruction as required from 'A' Train suction piping through ORNFA0002 (limited stay time &

multiple entries) using pre-staged equipment.

• After removal of obstruction, Divers to inspect and repair affected piping, IF required.
• Divers to remove equipment and foreign material from affected piping.
• Divers to perform final FME inspection from ORNFA0002 to ORN-7 A to ensure no foreign material remains.
• Maintenance verify piping is ready for restoration .

Recovery and Restoration 24 hours

• Confirm all FME logs have been reconciled prior to closing ORNFA0002 flange.
• Maintenance to restore system boundary (close ORNFA0002 flange and restore missile shield).
• Ops to remove tag out.
• Ops to perform reverse system flush .
• Perform system testing, as required .

Contingency for repair scope unknown 120 hours Requested Allowed Outage Time (AOT) 336 hours The results of a separately planned survey may indicate that a less intrusive, less time consuming set of activities is required than that outlined above. These opportunities will be pursued, as appropriate . As stated the survey wi ll be performed outside of the 14 day completion time requested by this submittal. The 14 day completion time extension is based on the most likely scenario for the OBDN condition which is that some type of construction artifact is restricting system flow in the 'A' Train NSWS suction piping from the SNSWP. Planning for this activity includes actions to locate the restriction, dislodge and extract the debris and complete any minor repairs associated with removal of the debris. Page 19 of 35

Based on evaluation results to date, it is believed that the restriction is located in the NSWS piping under the Unit 2 EOG building. The scope of work covered under this LAR does not include major excavation, or activities affecting SSCs not described in this request. Identification of a condition in which repairs could impact the ability SSC to perform their function would result in suspending activities in order to plan for the unexpected finding . This activity will be controlled under the Infrequently Performed Test or Evolution (IPTE) process defined in Fleet Directive AD-OP-ALL-106, "Conduct of Infrequently Performed Tests or Evolutions", and Duke Energy's Work Management and Execution procedures. The IPTE process establishes controls and processes such as IPTE Manager, IPTE, Coordinator, considers Just in Time Training (JITT), formal briefings, evolution termination criteria , clear roles and responsibilities including the role of Operations and the Shift Manager. 3.4 Defense in Depth Considerations Prior to removing the 'A' Train NSWS from service, the following defense-in-depth items will be established for both units 1 and 2:

1. The 'B' NSWS pumps suctions will be pre-aligned to the SNSWP. This alignment eliminates potential failures should there be a demand (ESFAS signal) for auto transfer of 'B' NSWS pump suction from the LLI to the SNSWP.

2. Procedures and designated operators will be available to align the 'B' SNSWP suction path to the 'A' Train NSWS pump will be available should a 'B' Train NSWS become unavailable following a seismic event that damages the Cowan 's Ford Dam or LU.

3. The NRC Order EA 12-049 FLEX strategy (modifications, portable equipment, FLEX Support Guidelines, training , etc.) will be available for both units.

Pre-Alignment of the 'B' NSWS pump suction to the SNSWP During normal operation both 'A' and 'B' Train NSWS are aligned to the LLI . Upon the actuation of an ESFAS the 'A' Train NSWS will remain aligned to the LLI as previously discussed but the

'B' Train NSWS automatically aligns to the SNSWP. The 'B' Train NSWS for both units will be aligned to the SNSWP prior to the start of activities described in this LAR. This defense in depth action will eliminate the potential failure of several motor operated valves during a demanded (ESFAS) transfer to the SNSWP. An ESFAS signal opens valve ORN-9B providing suction from the SNSWP to both unit 'B' Train NSWS pumps and closes valves ORN-1 OAC and ORN-11 B, which isolates the LLI supply to both units 'B' Train NSWS pumps.(see Figure 6:

NSWS Alignment During 14 Day Out of Service Window in Attachment 4 ). Procedures and Designated Operators will be available to align 'B' SNSWP suction path to the

'A' Train NSWS pump suction Following an earthquake that exceeds OBE, or causes visible damage to the Cowan 's Ford Dam or LLI piping the 'A' Train NSWS pumps will be stopped prior to loss of suction from the lake in accordance with existing abnormal operating procedures. These pumps will not be transferred to the SNSWP due to the unavailability of the 'A' Train NSWS suction piping to the SNSWP.

Page 20 of 35

If a failure of a '8' Train NSWS pump occurs subsequent to the initiating conditions described above, an additional defense in depth contingency will be available. Procedures and designated operators will be available to align the affected unit 'A' NSWS pump to the SNSWP via the shared '8' NSWS piping to restore NSW flow to the affected unit. This contingency will utilize the main supply crossover line and open the supply header crossover valves , ORN-14A and ORN-158. The example shown in Figure 7 of Attachment 4 depicts the alignment for a loss of 18 NSWS pump. A similar alignment would be used as a contingency for a failure of 28 NSWS pump. Prior to opening the main supply crossover, the procedure will ensure that NSWS conditions are maintained within design limits. The NSWS supply lines from the SNSWP are only designed to supply a maximum of two NSWS pumps; therefore, the procedure will provide actions to ensure only one NSWS pump is running on each unit when the main supply crossover flowpath is used . System configuration will ensure that the failed pump and equipment are isolated from the NSWS main supply crossover to preserve the integrity and independence of the equipment providing NSW flow to each unit. For example, the discharge valve closed on the affected pump to ensure that full flow will be delivered to the applicable unit and prevent losses due to bypass flow on the failed train or components. Further, the breaker will be opened to ensure that the design requirement that only two NSWS pumps running on a train is maintained . This alignment will result in the '8' train SNSWP supply feeding the '8' Train NSWS pump on one unit and the 'A' train NSWS pump on the affected unit. As stated above, one of the '8' Train NSW pumps will be running and one of the 'A' Train NSW pumps will be running with both pump suctions aligned to the SNSWP through the "8 " NSWS supply pipe. The specific pumps will be dependent on which '8' Train NSWS pump fails (See Figure 7: "Contingency for Loss of '8 ' NSWS pump After Response to Loss of Lake Norman" which shows the alignment for a failure of 18 NSWS pump). The main supply crossover piping is normally isolated by motor operated isolation valves ORN-14A ('A' Train) and ORN-158 ('8' Train). Each valve receives an ESFAS signal from both units to close even though the valves are normally maintained closed . See Figure 6: NSWS Alignment During 14 Day Out of Service Window in Attachment 4. Also see Figure 7: Contingency for Loss of '8' NSWS pump After Response to Loss of Lake Norman in shows the contingency alignment for a failure of 18 NSWS pump. In support of the contingency the following conditions will be established before the start of activities in the LAR:

• The 'A' train supply header crossover valve (ORN-14A) will be opened prior to the evolution and power will be removed from the valve operator.
• The '8' train supply header crossover valve (ORN-158) will be maintained closed with the ESFAS signal from each unit blocked prior to the evolution. Maintaining valve ORN-158 closed with power removed satisfies operability requirements for the '8 ' Train NSWS. Valve ORN-158 can be opened from the control room after power is restored if conditions warrant the use of this contingency.

The Main Supply Crossover is not normally operated . Nevertheless, biological growth and corrosion or sediment is not anticipated in this short section of pipe for the following reasons :

• The section of pipe is oxygen depleted which halts the corrosion process. There is no motive force to cause flow through the pipe. Therefore there is no means of replenishing oxygen.

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• The section of piping between the isolation valves is a vertically inverted U bend and therefore has no means of capturing sediment.

FLEX Strategy The FLEX strategy is summarized in section 3.1. The FLEX strategy provides another level of defense-in-depth that will provide a seismically qualified source (SNSWP) of water to the Turbine Driven Auxiliary Feedwater (TDAFW) pumps and procedures to cool down and depressurize the Reactor Coolant System to preserve the RCP seals should NSWS be interrupted on both trains . The strategy also includes guidelines that initiate actions to maintain long term containment integrity based on long duration RCP seal releases . Defense-in-Depth Principles: McGuire intends to isolate and repair the 'A' Train NSWS supply from the SNSWP. This activity will require that NSW Train 'A' be aligned to Lake Norman until the system is ready for post maintenance testing. This action maintains the NSW 'A' Train's normal and automatic alignment to Lake Norman but will result in the inability to manually align the 'A' Train directly to the SNSWP subsequent to a seismic event resulting in damage to the supply piping from Lake Norman or the highly improbable loss of Lake Norman. Although considered inoperable, 'A' Train NSWS will be technically capable of performing its intended function for all events except the seismic event that causes loss of the Lake Norman water supply. Station procedures require that the 'A' and 'B' Trains of NSWS be aligned to the SNSWP on the loss of Low Level Intake from Lake Norman or an earthquake equal to or greater than an OBE. Other than normal maintenance and periodic testing , these are the only occasions requiring the alignment of the 'A' Train NSWS to the SNSWP. In all other cases, the 'A' Train is aligned to Lake Norman . In addition to the TS, Work Control Program and Work Process Manual and the associated procedures and programs that implement the Maintenance Rule Program under 10CFR 50.65(a)(4) provide for controls and assessments to preclude the possibility of simultaneous planned outages of redundant Trains and ensure system reliability. This proposed LAR meets the defense-in-depth principle consisting of a number of elements. These elements and the impact of the proposed change on these elements are as follows :

• A reasonable balance among prevention of core damage, prevention of containment failure and consequence mitigation is preserved.

Although inoperable, the 'A' Train NSWS and the SSCs supported by it remain fully functional. The proposed LAR will not affect mission time requirements for the 'A' Train NSWS for all events excluding the loss of the Lake Norman water supply because the proposed activities do not affect the functionality or performance 'A' Train NSWS. The 'B' Train NSWS will remain operable. Because the 'B' Train NSWS will be pre-aligned to the SNSWP during the proposed activities, the manual operator actions associated with transferring the train to the SNSWP during a seismic event and any potential equipment failures associated with repositioning of valves during an ESFAS are eliminated . Procedures to align the 'B' SNSWP suction path to the 'A' Train NSWS pump will be available should a 'B' Train NSWS become unavailable following a seismic event that damages the Cowan 's Ford Dam or LLI provides additional defense in depth for prevention of core damage, and containment failure. Page 22 of 35

The capability to implement FLEX strategies adds additional defense in depth and will be available for deployment on Unit 1 and Unit 2 prior to the proposed evolution . These defense-in-depth measures are aimed at ensuring availability of the UHS function during the proposed activity and preventing core damage, containment damage and preservation of consequence mitigation .

• Avoidance of over-reliance on programmatic activities to compensate for weaknesses in plant design.

The proposed change involves a one-time extension of TS 3.5.2, Emergency Core Cooling System (ECCS) - Operating ; 3.6.6, Containment Spray System (CSS); 3.7.5, Auxiliary Feedwater (AFW) System; 3.7.6, Component Cooling Water (CCW) System; 3.7.7, Nuclear Service Water System (NSWS); 3.7.9, Control Room Area Ventilation System (CRAVS); 3.7.1 1, Auxiliary Building Filtered Ventilation Exhaust System (ABFVES), and 3.8.1, AC Sources - Operating for McGuire Nuclear Station Units 1 and 2 to allow the 'A' Train NSWS supply from the SNSWP to be taken out of service up to a total of 14 days for pipe repair. The only programmatic features are those associated with risk management actions described in Section 3.5, Compensatory Measures and Commitments. The defense-in-depth measures to be taken rely on existing and new proceduralized actions.

• System redundancy, independence and diversity are maintained commensurate with the expected frequency and consequences of challenges to the system .

The 'B' Train NSWS will remain completely operable and capable of performing the necessary safety functions consistent with accident analysis assumptions during the period of time the 'A' Train NSWS Suction path from the SNSWP is isolated . Additionally, the 'A' Train NSWS remains functional and capable during this period for all normal and ESFAS functions. NRC Generic Letter 80-30, "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by TS states," there is no requirement to assume a single failure while operating under a Technical Specification (TS) required action. Therefore , there will be no effect on the analysis of any accident or the progression of the accident since the operable NSW 'B' train is capable of serving 100 percent of all the required heat loads. The contingency for a 'B' NSWS pump failure following the seismic event that takes away the Lake Norman water source provides defense in depth for a low probability seismic event followed by the additional failure of a 'B' Train NSWS pump . The configuration used for this alignment will ensure that there will be no adverse interaction between the trains . Each aspect of using the Main Supply Crossover piping to restore flow to the affected unit will be proceduralized and designated operators will be available to execute the manual actions associated with aligning the affected unit's 'A' Train NSWS pump to the 'B' NSWS SNSWP via the Main Supply Crossover piping . Any adverse impact due to the unavailability of the

 'A' SNSWP water source is offset by the compensatory measures and commitments listed in Attachment 5.

Page 23 of 35

Additionally, use of the 14 day Completion Time requested by the proposed amendment will not exceed the baseline unavailability time established under 10 CFR 50.65 , Maintenance Rule guidance and monitored via the plant system performance indicators.

• Independence of barriers is not degraded .

The proposed 'A' Train NSWS activity does not directly impact any of the three principle safety barriers (Fuel Cladding , Reactor Coolant System , Containment Building) or otherwise cause their degradation. Independence of barriers is not degraded because the proposed TS Completion Time extension has no impact on the physical barriers.

• Defenses against human errors are preserved .

Defense-in-depth measures will be proceduralized and personnel training for the temporary TS change will be conducted in accordance with the Systematic Approach to Training process. Compensatory measures will be in place. Pre-job briefs will be conducted prior to and during the evolution to reinforce good human performance behaviors and barriers that will reduce risk . In addition , 'A' Train NSWS evolution will be controlled under the IPTE process defined in Fleet Directive AD-OP-ALL-0106 , "Conduct of Infrequently Performed Tests or Evolutions" (IPTE). The IPTE process establishes an IPTE Manager, and an IPTE Coordinator. The process also establishes controls and processes such as JITT, Formal briefings, evolution termination criteria , clear roles and responsibilities including the role of Operations and the Shift Manager. As such , defenses against human errors are preserved.

• The intent of the plant's Design Criteria is maintained .

This activity does not modify the plant design or the design criteria applied to systems, structures, or components (SSCs) during the licensing process. The NSWS is designed to be operated in the proposed manner. Additional details regarding compl iance with the GDCs are provided in Section 4.1. 3.5 Compensatory Measures and Commitments

1. The 'A' Train NSWS pumps will remain aligned to Lake Norman during the extended completion time (CT) until the system is ready for post maintenance testing .

2. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS piping from the SNSWP is not available will be evaluated for impact on the ability of the system to operate while taking suction from the Lake Norman Low Level Intake (LLI) and wil l be limited to a 72 hour completion time.

3. The 'B' Train NSWS will be placed in its ESFAS alignment to the SNSWP water source prior to starting the LAR activity and remain in this alignment until the 'A' Train NSWS SNSWP water source is restored and ready for post maintenance testing .

4. Procedures will be established to provide an additional defense in depth contingency that could be used in the event of an extremely low probability of a loss of the Lake Norman water source due to a seismic event. The procedures will ensure that system operation is maintained withi n design limits (less than or equal to 2 NSWS pumps runn ing on a header),

Page 24 of 35

control of maximum system flow, and that system configuration prevents interaction of the degraded equipment with the functional equipment.

5. FLEX strategies will be available for implementation as additional defense-in-depth on both units.

6. During the period in which the 'A' NSWS suction path from the SNSWP is non-functional, no discretionary maintenance or discretionary testing will be planned on the following:

a. 1A EOG

b. 2A EOG

c. The 'A' Train of NSWS excluding the activities described in the LAR for the 'A' Train NSWS piping to the SNSWP.

d. The 'B' Train of NSWS, ECCS, CSS, AFW, CCW, CRAVS , ABFVES or the EDGs

e. The switchyard and other offsite power sources

f. The SSF

7. A condition in which repairs could impact the ability of other SSCs to perform its Safety Function would result in termination of activities. The inspection may identify a condition that cannot be resolved within the 14 day completion time . Should such a condition be identified then the NSW system will be restored to its current OBDN condition . If the survey presents any opportunities for a less intrusive or less time consuming solution for addressing the OBDN condition , then these opportunities will be pursued , as appropriate.

8. This activity will be controlled under the Infrequently Performed Test or Evolution (IPTE) process defined in Fleet Directive AD-OP-ALL-0106 , "Conduct of Infrequently Performed Tests or Evolutions", and Duke Energy's Work Management and Execution procedures.

9. McGuire will communicate with the Transmission Control Center (TCC) to ensure that the McGuire Control Room is notified in the event of potential grid disturbances in order that an appropriate plant response can be formulated .

10. The Work Control Center or OCC will monitor weather forecasts and radar during the activities that require the NSWS piping personnel access points to be open to assess the potential for severe weather conditions (tornado, thunderstorms).

11. Training will be provided in accordance with the Systematic Approach to Training (SAT) process to Operations personnel on this TS change and the associated evolution to inspect and correct the non-conforming condition in the 'A' NSWS supply piping from the SNSWP.

12. Operations will review applicable abnormal operating procedures related to the response to an earthquake, the loss of the Lake Norman and the loss of NSWS prior to making 'A' NSWS suction path from the SNSWP inoperable and each shift until 'A' Train NSWS operability is restored .

13. The repair work on the NSWS 'A' Train suction from the SNSWP will be scheduled during a period in which hurricanes and tornadoes have a lower likelihood of occurrence.

14. The Outage Command Center (OCC) will be manned while performing the activities authorized by th is amendment.

15. The following list of equipment will be protected:

a. 'B' Train NSWS Page 25 of 35

b. 1B EOG

c. 2B EOG

d. 1B ECCS

e. 2B ECCS

f. 1B CSS

g. 2B CSS

h. 1B AFW

i. 2BAFW

j. 1B CCW

k. 2B CCW I. B CRAVS

m. B ABFVES

n. SSF including Standby Makeup pumps for Unit 1 and Unit 2

o. Unit 1 TDCAP

p. Unit 2 TDCAP

q. Unit 1 Containment Ventilation Cooling Water System (RV)

r. Unit 2 Containment Ventilation Cooling Water System (RV)

s. Switchyard

16. Foreign Material Exclusion (FME) will be controlled during the proposed activities in accordance with AD-MN-ALL-0002, Foreign Material Exclusion (FME). Any debris resulting from the obstruction removal activity will be mechanically cleaned out before the system is closed for return to service per FME plan developed in accordance with the above procedure. The 'A' NSWS piping will also be inspected prior to closeout. The system will then be reversed flushed from the LLI to the SNSWP with isolation to downstream components to force any sediment back to the SNSWP.

17. Prior to entering the 14 day CT, perform an evaluation to ensure that there will be no anticipated impact to 'A' NSWS water supply from the LLI from Alewife fish during the 14 day CT.

18. Designated operators will be available to execute the manual actions associated with aligning the affected unit's 'A' Train NSWS pump to the 'B' NSWS SNSWP via the Main Supply Crossover piping .

19. In support of the contingency the following conditions will be established before the start of activities in the LAR:

• The 'A' train supply header crossover valve (ORN-14A) will be opened prior to the evolution and power will be removed from the valve operator.
• The 'B' train supply header crossover valve (ORN-15B) will be maintained closed with the ESFAS signal from each unit blocked prior to the evolution. Maintaining valve ORN-15B closed with power removed satisfies operability requirements for the 'B' train NSWS. Valve ORN-15B can be opened from the control room after power is restored if conditions warrant the use of this contingency.

3.6 Compliance with Current Regulations This LAR itself does not propose to deviate from existing regulatory requirements, and compliance with existing regulations is maintained by the proposed one time change to the Page 26 of 35

plant's Technical Specification requirements . Additional details may be found in the Regulatory Evaluation section of this LAR. 3.7 Evaluation of Safety Margins

• Codes and standards or alternatives approved for use by the NRC are met (e.g., proposed LAR not in conflict with approved codes and standards).

The design and operation of the NSWS is not altered by the proposed TS completion time extension. The alignment of the system is currently allowed by the McGuire Technical Specifications for a limited period of time.

• Safety analysis acceptance criteria in the plant licensing basis are met or proposed revisions provide sufficient margin to account for analysis and data uncertainties.

The safety analysis acceptance criteria stated in the UFSAR are not impacted by this change . The proposed change will not allow plant operation in a configuration outside the design basis. The requirements regarding the NSWS credited in the accident analysis will remain the same. As such, it can be concluded that safety margins are not impacted by the proposed change . 3.8 Configuration Risk Management 10 CFR 50.65 (a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," requires that prior to performing maintenance activities, risk assessments shall be performed to assess and manage the increase in risk that may result from proposed maintenance activities. These requirements are applicable for all plant modes. The proposed LAR will not result in any changes to the current configuration risk management program . The existing program uses a blended approach of quantitative and qualitative evaluation of each configuration assessed . The McGuire on-line computerized risk software , Electronic Risk Assessment Tool (ERAT), considers both internal and external initiating events with the exception of seismic events. Thus, the overall change in plant risk during maintenance activities is expected to be addressed adequately considering the proposed amendment. McGuire has Duke Energy's Work Management and Execution procedures that are in place to ensure that risk significant plant configurations are avoided . These documents are used to address the Maintenance Rule requirements, including the on-line (and off-line) Maintenance Policy requirement to control the safety impact of combinations of equipment removed from service. The key documents are as follows:

• AD-WC-ALL-410, "Work Activity Integrated Risk Management"
• AD-WC-ALL-0420, "Shutdown Risk Management"
• NSD 415, "Operational Risk Management (Modes 1-3) per 10 CFR 50.65 (a)(4)"
• WPM-608, "Outage Risk Assessment Utilizing Electronic Risk Assessment Tool (ERAT)"

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• WPM-609, "On-Line Risk Assessment Utilizing Electronic Risk Assessment Tool (ERAT)"

More specifically, the Directives referenced above address the process; define the program , and state individual group responsibilities to ensure compliance with the Maintenance Rule . The Work Process Manual procedures provide a consistent process for utilizing the computerized software assessment tool , ERAT, which manages the risk associated with equipment inoperability. The Electronic Risk Assessment Tool (ERAT) is a computer program used to facilitate risk informed decision making associated with station work activities. Its guidelines are independent of the requirements of the Technical Specifications and Selected Licensee Commitments and are based on probabilistic risk assessment studies and deterministic approaches. The "A" Train NSWS will remain in its normal alignment and will be capable of mitigating the accidents that are modeled in ERAT. The 'B' Train NSWS will be placed in its ESFAS alignment and will remain operable and capable of mitigating the accidents modelled in ERAT. Additionally, prior to the release of work for execution , operations personnel must consider the effects of severe weather and grid instabilities on plant operations. This qualitative evaluation is inherent of the duties of the Work Control Center Senior Reactor Operator (WCC SRO). Responses to actual plant risk due to severe weather or grid instabilities are programmatically incorporated into applicable plant emergency or response procedures (RP/O/N5700/006 , Natural Disasters ; AP/1 (2)/N5500/05, Generator Voltage and Grid Disturbances). Foreign Material Exclusion will be controlled during the proposed activities in accordance with AD-MN-ALL-0002 , Foreign Material Exclusion (FME). Any debris resulting from the obstruction removal activity will be mechanically cleaned out before the system is closed for return to service per FME plan developed in accordance with the above procedure. The 'A' NSWS piping will also be inspected prior to closeout. The system will then be reversed flushed from the LLI to the SNSWP with isolation to downstream components to force any sediment back to the SNSWP. Following system cleanup and restoration a final test will be performed to identify any downstream effects caused by debris blockage. The key safety significant systems impacted by this proposed LAR are currently included in the Maintenance Rule program , and as such , availability and reliability performance criteria have been established to assure that they perform adequately. 3.9 Conclusions The results of the deterministic engineering justification described above provide assurance that the systems and equipment requ ired to safely shutdown the plant and mitigate the effects of a design basis accident will remain capable of performing their safety functions . The proposed TS Completion Time extension is consistent with NRC guidance and meets the following principles of:

1. Current regulations

2. Defense-in-depth philosophy

3. Sufficient safety margins Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such Page 28 of 35

activities will be conducted in compliance with NRC regulations , and (3). the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria During the applicable period of this proposed license amendment, McGuire will maintain the ability to meet the applicable General Design Criteria (GDC) as outlined in 10 CFR 50, Appendix A. The applicable GDCs are:

• GDC-2, Design Basis for Protection Against Natural Phenomena: -

Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes , hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions . The design bases for these structures, systems, and components shall reflect: (1) Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated , (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and (3) the importance of the safety functions to be performed. The 'A' and 'B' suction piping from the SNSWP is buried approximately 25 feet below the surface of the ground in the vicinity of the manway access well. The piping is separated by approximately two feet between the two trains. The manway access well is normally covered by a concrete missile barrier that protects the 'A' train piping from potential tornado missiles. Because of the depth of the well, the adjacent 'B' piping is not susceptible to a missile strike.

• GDC-4. Environmental and Dynamic Effects Design Basis Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation , maintenance, testing , and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic.effects, including the effects of missiles, pipe whipping , and discharging fluids , that may result from equipment failures and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping .

The 'B' suction piping from the SNSWP is not susceptible to turbine missiles for the same reasons discussed under GDC 2 above.

• GDC-5. Sharing of Structures, Systems and Components:

Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions , including , in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units. The 'A' and 'B' NSWS suction paths from the SNSWP are normally shared between Units 1 Page 29 of 35

and 2. This shared SSC was previously reviewed and approved by the NRC during plant licensing. The additional defense-in-depth measure to use the Main Supply Crossover line will allow the SNSWP to provide suction to the affected unit 'A' Train NSWS pump via the 'B' NSWS SNSWP piping in the very unlikely event that a 'B' Train NSWS pump fails subsequent to an earthquake that takes away the ability to use 'A' Train NSWS. Prior to opening the main supply crossover, the procedure will ensure that NSWS conditions are maintained within design limits. The NSWS supply lines from the SNSWP are only designed to supply a maximum of two NSWS pumps; therefore, the procedure will provide actions to ensure only one NSWS pump is running on each unit when the main supply crossover flowpath is used . Maximum NSWS flow during execution of this contingency will be limited to ensure that positive pressure is maintained at the suction of the running NSWS pumps. System configuration will ensure that the failed pump and equipment are isolated from the NSWS main supply crossover to preserve the integrity and independence of the equipment providing NSW flow to each unit. For example, the breaker will be opened and the discharge valve closed on the affected pump to ensure that full flow will be delivered to the applicable unit and prevent losses due to bypass flow on the failed train or components . This alignment may result in the 'B' train SNSWP supply feeding the 'B' Train NSWS pump on one unit and the 'A' Train NSWS pump on the affected unit. This defense in depth contingency does not alter the degree to which Units 1 and 2 share this suction path.

• GDC-44. Cooling Water:

A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided . The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions . Suitable redundancy in components and features , and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished , assuming a single failure. As stated previously although the 'A' Train NSWS will be inoperable during the proposed 14 day Completion Time, the train and the equipment it supports will rema in in its normal ESFAS configuration and be functional. The 'B' Train NSWS will remain operable. The NSWS remains functionally capable of meeting single failure criteria for all non-seismic postulated events. As previously stated , NRC Generic Letter 80-30, "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by TS states," there is no requirement to assume a single failure while operating under a Technical Specification (TS) required action . For defense in depth following the seismic event that causes a loss of the LLI and a subsequent 'B' Train NSWS pump failure procedures will be available to restore cooling water to the affected unit with an 'A' Train NSWS pump. The 'A' NSWS pump will be aligned to the SNSWP via the 'B' Train NSWS piping . These procedures will ensure that configuration of the failed 'B' Train NSWS will not adversely affect NSWS operation on either unit. There will be no permanent changes to the design of the ECCS, CSS, NSWS, AFW , CCW, CRAVS , ABFVES and the EOG such that compliance with any of applicable design criteria would come into question. The evaluations provided within this proposed amendment confirm that the plant will continue to comply with the applicable design criteria. Page 30 of 35

During the requested 14 day period, 'A' Train NSWS will be aligned to Lake Norman until the system is ready for post maintenance testing. This action maintains the 'A' Train's NSWS normal and automatic alignment to Lake Norman but will result in the inability to manually align the 'A' Train directly to the SNSWP subsequent to a seismic event resulting in damage to the supply piping from Lake Norman or the highly improbable loss of Lake Norman. The operability of 'B' Train NSWS is not affected by the proposed change . During this period, no discretionary maintenance or discretionary testing will be planned on either NSWS Train except for the 'A' Train NSWS piping to the SNSWP, described in this proposed amendment. Any adverse impact is offset by defense in depth actions and other compensatory measures listed in this submittal. Additionally, no discretionary maintenance or discretionary testing will be planned on the 'B' Trains of ECCS, CSS, AFW, CCW, CRAVS, ABFVES, and EDGs. In this configuration, the operable Trains will respond as designed during design basis events. Cooling water for Train 'A' heat exchangers and pump motor coolers will be supplied from Lake Norman via 'A' Train NSWS. Although considered inoperable, the affected Train 'A' systems will be capable of performing their intended functions . The one time requested period of 14 days to complete the Required Actions of the affected Technical Specifications is reasonable considering the redundant capabilities of the above systems, the defense in depth measures that will be available, and the compensatory measures that will be in place as discussed within this proposed amendment. 4.2 Precedents This proposed license amendment is similar to the amendment request submitted by McGuire Nuclear Station and approved by the NRC on March 16, 2016 (ADAMS Accession No. ML15306A141 ). The approved amendment allowed a temporary change to the TSs to allow the inoperability of the 'A' Train of the NSWS for a total of up to 14 days with an expiration date of March 1, 2017. An effort was undertaken to resolve the non-conforming condition by accepting the condition as-is and bringing it into the MNS licensing basis under 10 CFR 50 .59. That effort was not successful. As a result, the piping inspection was not performed by the 2017 deadline. The amendment contained additional activities with regard to installing a second manway for personnel access between the auxiliary building wall and the first isolation valve in the 'A' Train SNSWP supply piping for a personnel egress/ingress path. This proposed license amendment project scope has been simplified by removing the planned installation of a second manway. This proposed license amendment was also modeled after similar amendments submitted by Catawba Nuclear Station and approved by the NRC on January 7, 2003 (ADAMS Accession No ML030070375) and November 17, 2005 (ADAMS Accession No ML053250121 ). The Catawba amendment temporarily modified their Technical Specifications to allow the NSWS headers for each Unit to be taken out of service for up to 14 days each for system upgrades . This proposed license amendment was also modeled after a similar amendment submitted by South Texas Project Unit 1 where extensive, unplanned repairs were necessary for the 'B' Train Essential Cooling Water pump. The STP request for a 7 day extension (up to 14 days) was approved by the NRC on January 10, 2005 (ADAMS Accession No ML050100291 ). The proposed amendment was modeled after similar Callaway Nuclear Station amendment requests for an extension of the Technical Specification ESW and EOG Completions Times from 72 hours to 14 days to replace ESW piping , approved October 31, 2008 (ADAMS Accession No ML082810643) and February 24, 2009 (ADAMS Accession No ML090360533). Page 31 of 35

4.3 Significant Hazards Consideration Pursuant to 10 CFR 50.90, Duke Energy Carolinas , LLC (Duke Energy) proposes a license amendment request (LAR) for the Renewed Facility Operating License (FOL) and Technical Specifications (TS) for McGuire Nuclear Station, Units 1 and 2. The proposed LAR would revise the McGuire TS 3.7.7 and associated TS supported by the Nuclear Service Water System (NSW) to address a non-conforming condition affecting the NSW system performance on the 'A' Train supply piping. The proposed LAR would be applicable on a one time basis as described below. The activity cannot be accomplished within the current TS completion time of 72 hours. The proposed amendment will permit the 'A' Train NSWS to be inoperable for a total of 14 days to allow for the identification and resolution of a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity or by March 31 , 2019, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time . The latter will not count against the 14 day completion time . Duke Energy has concluded that operation of the McGuire Nuclear Station Units 1 & 2, in accordance with the proposed changes to the Technical Specifications, does not involve a significant hazards consideration . Duke Energy's conclusion is based on its evaluation, in accordance with 10CFR50.91 (a) (1), of the three standards set forth in 10CFR50.59(c) as discussed below:

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

Response : No. The 'B' Train NSWS and supported equipment will remain fully operable during the 14 day CT. The alignment of the 'A' Train NSWS will remain consistent with the NSWS normal and ESFAS alignment. Although not fully operable the 'A' Train NSWS and its supported equipment will be capable of performing their functions during the 14 day CT. The 'A' NSWS and supported equipment function as accident mitigators. Removing 'A' Train SNSWP supply piping from service for a limited period of time does not affect any accident initiator and therefore cannot change the probability of an accident. The proposed changes and the 'A' Train NSWS repair evolution have been evaluated to assess their impact on the systems affected and ensure design basis safety functions are preserved . The risk analysis for the proposed NSW system alignment during the 14 day CT shows no delta risk for any ESF actuation event that does not involve an earthquake. The most significant risk contributor is a seismic event with a magnitude great enough to cause the failure of Cowan 's Ford dam and subsequent loss of Lake Norman or LLI during the 14 day CT. The estimated Incremental Conditional Core Damage Probability (ICCDP) due Page 32 of 35

to the seismic event is much less than the limits associated with Regulatory Guide 1.177. In addition , as previously stated, a Seismic Fragility Assessment of the McGuire Low Level Intake Water Pipeline in December of 2011 indicates that the dam and water supply would withstand a SSE. Therefore for the short duration of this proposed alignment the increase in risk is deemed to be negligible. Risk associated with tornado/high winds was assessed . The months of November through February have been the seasonal low for tornado frequency. This evolution is currently scheduled for the spring February 2018 time frame. The risk contribution from tornado and high wind events is negligible during the proposed NSWS configuration described in this LAR and therefore, the calculated Core Damage Frequency (CDF) or the Large Early Release Fraction (LERF) contribution due to high wind and tornado events is negligible with respect to overall risk. The activities covered by this LAR also include a defense-in-depth action to cease activities and close the personnel access opening in the event of a tornado warning . Weather patterns will be monitored and this activity will be modified if tornado/high wind conditions become imminent. The overall increase in risk for the 14 day CT is solely due to the seismic event which results in a loss of Lake Norman or LU . However, this risk is reduced by the defense in depth strategy described in the LAR that provides a contingency for the loss of a 'B' Train NSWS pump after the loss of the Lake Norman water supply. This defense in depth contingency effectively offsets the unavailability of the 'A' Train NSWS SNSWP supply. In addition, pre-aligning the 'B' Train NSWS to the SNSWP water supply in advance of the proposed activities prevents the introduction of potential equipment failures during an ESFAS demanded transfer. This action also eliminates the time it would take operators to perform the transfer following a seismic event. The quantified impact of defense in depth measures and compensatory actions on CDF/LERF cannot be precisely determined, yet it is agreed that the implementation of these actions would only serve to improve these risk parameters. Not included in the overall risk evaluation is the additional margin identified by the Fragility Assessment discussed previously that concluded that the Lake Norman Dam and LU would survive a SSE. As stated in NRC Generic Letter 80-30, "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by TS," there is no requirement to assume a single failure while operating under a Technical Specification (TS) required action . Therefore , there will be no effect on the analysis of any accident or the progression of the accident since the operable NSW 'B' train is capable of serving 100 percent of all the required heat loads. As such, there is no impact on consequence mitigation for any transient or accident. In light of the above discussion, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Page 33 of 35

Response : No. The proposed amendment is the one time extension of the required CTs from 72 hours for the ECCS, CSS, NSWS, AFW , CCW and the EOG systems and from 168 hours for the CRAVS and ABFVES systems to 336 hours. The requested change does not involve the addition or removal of any plant system, structure, or component. The proposed temporary TS changes do not affect the basic design , operation , or function of any of the systems associated with the TS impacted by the amendment. Implementation of the proposed amendment will not create the possibility of a new or different kind of accident from that previously evaluated. McGuire intends to isolate, inspect, and repair the 'A' Train NSWS supply from the SNSWP. This activity will require that 'A' Train NSW be aligned to Lake Norman until the system is ready for post maintenance testing . This action maintains the NSW 'A' Train's normal and automatic alignment to Lake Norman but will result in the inability to manually align the 'A' Train NSWS to the SNSWP subsequent to a seismic event that results in damage to the supply piping from Lake Norman or the highly improbable loss of Lake Norman. Although considered inoperable, the 'A' Train NSWS and supported systems will be technically capable of performing their intended functions . Throughout the repair project, compensatory measures will be in place to provide additional assurance that the affected systems will continue to be capable of performing their intended safety functions. No new accident causal mechanisms are created as a result of the requested changes creating the possibility of a new or different kind of accident from any accident previously evaluated . In conclusion , this proposed LAR does not impact any plant systems that are accident initiators and does not impact any safety analysis. Therefore , the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated .

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

Response : No. Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding , the reactor coolant system , and the containment system . The performance of the fuel cladding , reactor coolant and containment systems will not be impacted by the proposed LAR. Additionally, the proposed amendment does not involve a change in the design or operation of the plant. The activity only extends the amount of time the 'A' NSW system is allowed to be inoperable to correct the non-conforming condition on the 'A' NSWS supply piping from the SNSWP. As stated previously, the 'A' Train NSWS and supported equipment will remain in its Normal and ESFAS alignment during the extended CT and be functionally capable for all postulated events except a seismic event that results in loss of the Lake Norman water supply. Page 34 of 35

Defense-in-depth measures involving use of the Main Supply Crossover piping to supply suction to affected unit's 'A' Train NSWS pump from the 'B' train SNSWP suction piping and the ability to implement the FLEX strategy on both units provide additional safety margin for this event. Use of the Main Supply Crossover line is only needed in the unlikely event that one unit's 'B' Train NSWS pump fails after loss of 'A' Train NSWS due to an earthquake. The estimated ICCDP during the 14 day CT extension is much less than the limits associated with Regulatory Guide 1.177. Therefore, it is concluded that the proposed changes do not involve a significant reduction in the margin of safety. Based upon the above evaluation , Duke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and , accordingly, a finding of "no significant hazards consideration" is justified. 4.4 Conclusions In conclusion , based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission 's regulations , and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

S A review by Duke Energy has determined that the proposed amendment would temporarily change a requirement with respect to use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed amendment does not involve (i) a significant hazards consideration , (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released onsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22( c) (9). Therefore , pursuant to 10 CFR 51 .22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment. Page 35 of 35

ATTACHMENT 2 Marked-Up McGuire Technical Specification Pages

ECCS -Operating 3 .5 .2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS-Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE . APPLICABILITY : MODES 1 , 2 , and 3 .

                            --------------------------------N 0 TE---------------------------------------

1n MODE 3 , both safety injection (SI) pump or RHR pump flow paths may be isolated by c losing the isolation va lves for up to 2 hours to perform pressure isolation valv e testing per SR 3.4.14.1 . ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains A.1 Restore train(s) to 72 hours*t inoperable. OPERABLE status. AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available . B. Required Action and B.1 Be in MODE 3 . 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours JMarch 31, 2019 --NOTE--~to address l rlnon-conforming I

• 'A' Train ECCS is allowed to be inoperable for a total o 4 days fer rrestieA ef a _ -~ondition on the 'A' Train NSWS supply piping from the Standby Nuclear Servi Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the act1v1ty , or by Marsl'l 1, 2017 , whichever occurs first. Dunng the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available wi ll be limited to a 72 hour completion time. The latter will not count against the 14 day completion time . Allowance of the extended Completion Time is contingent on meeting the Compensatory Measu.;.;.re..;;..;s;;_a;;;.;.n.;.;;d'------~

Commitments 86 described in MNS LAR submittal correspondence letter M~J~ 1e 009 . ~ IMNS-17-031 t For Unit 1 only, the Completion Time for Required Action A.1 may be extended one-time to 10 days during the 1A RHR AHU repair evolution and is contingent on meeting the compensatory measures described in MNS correspondence letter MNS-15-093. Upon completion of the repair evolution , this footnote is no longer applicable and will expire on March 31 , 2016. McGuire Units 1 and 2 3 .5 .2-1 Amendment Nos. 2g21201

Containment Spray System 3.6.6 3.6 CONTAI NMENT SYSTEMS 3.6 .6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours* train inoperable. train to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours !March 31, 2019 I lnon-conformingl to

            --- -----------------------J-- ----------------------N 0 TE--------------------------------------------------   ------
          * 'A' Train Cont9 inmen Spray is allowed to be inoperable for a total of 14 days for the oorreotion ef-a degradedrondition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNS~P) . The 14 days may be taken consecutively or in parts until completion of the activity, or b9 Marsh 1, 2017 , whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments described in MNS LAR submittal correspondence letter Mfl.Jg 10 005 . ~MNS-17-031                                         I SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                  FREQUENCY SR 3.6. 6. 1       ---------------------------------N 0 TE--------------------------------

Not required to be met for system vent flow paths opened under administrative control. Verify each containment spray manual and power In accordance with operated valve in the flow path that is not locked , sealed , the Surveillance or otherwise secured in position is in the correct position. Frequency Control Pro ram (continued) McGuire Units 1 and 2 3.6.6-1 Amendment Nos. 2~5/204

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

                           -------------------------------------------- N 0 TE-----------------------------------------

0 nly one AFW train , which includes a motor driven pump, is required to be OPERABLE in MODE 4. APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal. ACTIONS

---

N 0 TE------------------------------------------------------------------------

LCO 3.0.4.b is not applicable when entering MODE 1. CONDITION REQUIRED ACTION COMPLETION TIME A. One steam supply to A.1 Restore steam supply to 7 days turbine driven AFW OPERABLE status . pump inoperable. 10 days from discovery of failure to meet the LCO B. One AFW train B.1 Restore AFW train to 72 hours* inoperable in MODE 1, 2 OPERABLE status. or 3 for reasons other than Condition A. 10 days from discovery of failure to meet the LCO (continued) McGuire Units 1 and 2 3.7.5-1 Amendment Nos 282/261

AFW System 3.7.5 ACTIONS (continued) CONDITION REQU IRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time for Condition A AND or B not met. C.2 Be in MODE 4. 12 hours OR Two AFW trains inoperable in MODE 1, 2, or 3. D. Three AFW trains D.1 -------------N 0 TE------------- inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status. Initiate action to restore Immediately one AFW train to OPERABLE status. E. Required AFW train E.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status. Inon-conforming !March 31 , 2019 I ~

             ------------------------------------------------------ N0 TE------------------------------- - ---------------------------
           *'A' Train AFW is allowed to be inoperable for a total of 14 days for the correction of a degraded condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSW P). The 14 days may be taken consecutively or in parts until completion of the activity ,
          ~ ~ :- r::h 1, ~'::' ~' , wh ichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSW P is not available, the 'A' Trai n NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing . Any maintenance that is performed on the remain ing portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP su pply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments described in MNS LAR submittal correspondence letter MNS 16 005 .~MNS 031                                            I McGuire Units 1 and 2                                 3.7.5-2                           Amendment Nos. 282/261

CCW System 3.7.6

3. 7 PLANT SYSTEMS 3.7.6 Component Cooling Water (CCW) System LCO 3.7.6 Two CCW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train A.1 -------------N 0 TE-------------- inoperable. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by ccw. Restore CCW train to 72 hours* OPERABLE status . B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A not AND met. B.2 Be in MODE 5. 36 hours

     !March 31, 2019          I                                                                            ,--/to address        I
                   -------------------------------------------------- N0 T E----------------------------"'rj,r-Jaaaaaaaawa--a-a------
                 * 'A' Train CCW is allowed to be inoperable for a total of 14 days for the correction of a
              -~ de g ra d ed  condition on the 'A' Train supply piping from the Standby Nuclear Service I       Water Pond (SNSWP). The 1~ days may be taken consecutively or in parts until lnon-conformingl completion of the activity, orb)' March 1, 2017 , whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of
                 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments as described in MNS LAR submittal correspondence letter MNS 16 005 . ~MNS- 17 _ 031 McGuire Units 1 and 2                                 3.7.6-1               Amendment Nos. 282/261

NSWS 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Nuclear Service Water System (NSWS) LCO 3.7.7 Two NSWS trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One NSWS train A.1 -------------N 0 TES------------ inoperable. 1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources- Operating ," for emergency diesel generator made inoperable by NSWS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by NSWS.

Restore NSWS train to 72 hours* OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A not AND met. B.2 Be in MODE 5. 36 hours McGuire Units 1 and 2 3.7.7-1 Amendment Nos. 282/261

NSWS March 31, 2019 3.7.7 to address non-conforming '------.--.-....-- ------------------------------------------- N0 TE-------------------------------- --------------------------

         *'A' Train NSWS is allowed to be inoperable for a total of 14 days for the correction of a ondition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP) ;fhe 14 days may be taken consecutively or in parts until completion of the activity ,

or by March 1, 2017, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments as described in MNS LAR submittal correspondence letter Mt>JS 16 005.

                                                                     ~MNS-17-031 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                 FREQUENCY SR 3. 7. 7. 1   --------------------------------N 0 TE----------------------------------

1sola tion of NSWS flow to individual components does not render the NSWS inoperable. Verify each NSWS manual , power operated , and In accordance with automatic valve in the flow path servicing safety related the Surveillance equipment, that is not locked, sealed, or otherwise Frequency Control secured in position , is in the correct position. Program SR 3.7.7.2 Verify each NSWS automatic valve in the flow path In accordance with servicing safety related equipment, that is not locked, the Surveillance sealed, or otherwise secured in position, actuates to the Frequency Control correct position on an actual or simulated actuation Program signal. SR 3.7.7.3 Verify each NSWS pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program McGuire Units 1 and 2 3.7.7-2 Amendment Nos. 282/261

CRAVS 3.7.9

3. 7 PLANT SYSTEMS 3.7.9 Control Room Area Ventilation System (CRAVS)

LCO 3.7.9 Two CRAVS trains shall be OPERABLE.

      ----------------------------------------- N 0 TE-----------------------------------------------

T he control room envelope (CRE) boundary may be opened intermittently under administrative control. APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies , During CORE ALTERATIONS. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRAVS train A.1 Restore CRAVS train to 7 days* inoperable for reasons OPERABLE status. other than Condition B. B. One or more CRAVS B.1 Immediately trains inoperable due to Initiate action to implement inoperable CRE mitigating actions. boundary in MODE 1,2,3, or 4. AND 24 hours B.2 Verify mitigating actions ensure CRE occupant exposures to radiological , chemical , and smoke hazards will not exceed limits. AND 90 days B.3 Restore CRE boundary to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours (continued) McGuire Units 1 and 2 3.7.9-1 Amendment No. 282/261

CRAVS 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME G. One or more CRAVS G.1 Restore CRAVS train(s) 7 days train(s) heater heater to OPERABLE inoperable. status. G.2 Initiate action in 7 days accordance with Specification 5.6.6. March31 , 2019 ~

              ----------------------------------------N 0 TE-----------------------------+ --= = = = =--------

RA VS is allowed to be inoperable for a total of 14 days f.or the correction of a ondition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond The 14 days may be taken consecutively or in parts until completion of the activity, or by , whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing . Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time . Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments as described in MNS LAR submittal correspondence letter MNS 16 005.

                                                             ~MNS-17-031 McGuire Units 1 and 2                                3.7.9-3                         Amendment No. 282/261

ABFVES 3.7.11

3. 7 PLANT SYSTEMS 3.7 .11 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)

LCO 3.7.11 Two ABFVES shall be OPERABLE.

          -------------------------------------------------- N0 TE---------------------------------------------------

The Auxiliary Building pressure boundary may be opened intermittently under administrative controls. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ABFVES A.1 Restore ABFVES to 7 days* inoperable. OPERABLE status. B. Two ABFVES B.1 Restore one ABFVES to 24 hours inoperable. OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. C.2 Be in MODE 5. 36 hours !March 31 , 2019 I non-conforming I Ito address I

           --------------- -----------------------------------N 0 T E--------------------------------------------7 -----------t
          * 'A' Train BFVES is allowed to be inoperable for a total of 14 days +-:: ~ *h -::                       _        ~+

a degraded condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The ~ days may be taken consecutively or in parts until completion of the activity, or oy March 1, 2017, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of

           'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments as described in MNS LAR submittal correspondence letter MNS 16 005.
                                                                             ~MNS- 17-031 McGuire Units 1 and 2                                3.7.11-1                      Amendment No. 282/261

AC Sources - Operating 3.8.1 ACTI ONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore offsite circuit to 72 hours OPERABLE status . AND 6 days from discovery of failure to meet LCO B. One DG inoperable. B.1 Perform SR 3.8.1 .1 for the 1 hour offsite circuit(s) . AND Once per 8 hours thereafter AND B.2 Declare required feature(s) 4 hours from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable. redundant required feature(s) AND B.3.1 Determine OPERABLE DG 24 hours is not inoperable due to common cause failure. OR B.3.2 Perform SR 3.8.1 .2 for 24 hours OPERABLE DG. AND (continued) McGuire Units 1 and 2 3.8.1-2 Amendment No. 184/166

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.4 Restore DG to OPERABLE 72 hours ** status . AND 6 days from discovery of failure to meet LCO C. Two offsite circuits C.1 Declare required feature(s) 12 hours from inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required feature(s) AND C.2

• Restore one offsite circuit 24 hours to OPERABLE status .

(continued) March 31, 2019 non-conforming ~

          **'A' Train EDGs are allowed to be inoperable for a total of 14 days for the correction of a i':le~raded ondition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). he 14 days may be taken consecutively or in parts until completion of the activity ,

or by March 1, 2017 whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing . Any maintenance that is performed on the remain ing portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time . The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments as described in MNS LAR submittal correspondence letter M~la 10 005 . MNS-17-031 McGuire Units 1 and 2 3.8.1-3 Amendment No. 293/272

ATTACHMENT 3 Marked-Up McGuire Technical Specification Bases Pages

NSWS B 3.7.7 B 3.7 PLANT SYSTEMS B 3.7.7 Nuclear Service Water System (NSWS) BASES BACKGROUND The NSWS provides a transfer mechanism for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation , and a normal shutdown , the NSWS also provides this function for various safety related and nonsafety related components. The safety related function is covered by this LCO. The NSWS is normally supplied from Lake Norman as a non-seismic source , through a single supply line as shown in Figure B 3.7.7-1 . An additional safety-related and seismic supply of water to the NSWS, in the event of a loss of Lake Norman, is the Standby Nuclear Service Water Pond (SNSWP). The supply line from Lake Norman separates into two supply headers; each header is capable of being isolated by two , independently powered , motor operated valves. The two supply headers feed into two separate supply trains. The "A" train supplies water to the "A" pump on each unit and the "B" train to the "B" pump on each unit. During normal operation , only one pump , per unit, is in operation to supply NSWS flow to the essential and non-essential headers for each unit. The "B" train supply is automatically realigned to the SNSWP and supplies the "B" header on an SI signal from either unit. The "A" train supply is automatically realigned to the low-level supply from Lake Norman and supplies the "A" header on an SI signal from either unit. Essential headers provide flow to the following safety related components and systems :

1. Component Cooling (CCW) Heat Exchangers and Pump Motor Coolers,

2. Containment Spray Heat Exchangers and Pump Motor Coolers,

3. Control Room Area Chiller Condensers,

4. Diesel Generator Heat Exchangers,

5. Centrifugal Charging Pump Motor, Bearing Oil and Gear Oil Coolers,

6. Nuclear Service Water Pump Motor Coolers ,

7. Auxiliary Feedwater Pump Motor Coolers,

8. Safety Injection Pump Motor and Bearing Oil Coolers,

9. Residual Heat Removal Pump Motor Coolers,

10. Fuel Pool Pump Motor Coolers, 11 . Assured Auxiliary Feedwater Supply,

12. Assured Component Cooling System Makeup,

13. Assured Fuel Pool Cooling System makeup, and

14. Assured Diesel Generator Engine Cooling System makeup.

McGuire Units 1 and 2 B 3.7.7-1 Revision No. jt4G

NSWS B 3.7.7 BASES BACKGROUND (continued) The non-essential channel supply comes from the "A" and "B" train crossover piping and isolates on an SI or Blackout signal. The Reactor Coolant Pump Motor Air Coolers are not essential for safe shutdown , but are set up to receive cooling flow until the Containment, High-High signal is received . The pumps and valves are remote and manually aligned, except in the unlikely event of a loss of coolant accident (LOCA) . The pumps aligned to the critical loops are automatically started upon receipt of a safety injection or Station Blackout signal , and all essential valves are aligned to their post-accident positions. Additional information about the design and operation of the NSWS, along with a list of the components served, is presented in the UFSAR, Section 9.2 (Ref. 1). The principal safety related function of the NSWS is the removal of decay heat from the reactor via the CCW System. APPLICABLE The design basis of the NSWS is for one NSWS train , in conjunction with SAFETY ANALYSES the CCW System and the Containment Spray system , to remove core decay heat following a design basis LOCA as discussed in the UFSAR, Section 6.2 (Ref. 2). This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a gradual reduction in the temperature of this fluid as it is supplied to the Reactor Coolant System by the ECCS pumps. The NSWS is designed to perform its function with a single failure of any active component, assuming the loss of offsite power. The NSWS, in conjunction with the CCW System, also removes heat from the residual heat removal (RHR) system , as discussed in the UFSAR, Section 5.4 (Ref. 3), from RHR entry conditions to MODE 5 during normal and post-accident operations. The time required for this evolution is a function of the number of CCW and RHR System trains that are operating . One NSWS train is sufficient to remove decay heat during subsequent operations in MODES 5 and 6. This assumes a maximum NSWS inlet temperature of 102°F is not exceeded . The NSWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4 ). LCO Two NSWS trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post-accident McGuire Units 1 and 2 B 3.7.7-2 Revision No. !MG

NSWS B 3.7.7 BASES LCO (continued) heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power. An NSWS train is considered OPERABLE during MODES 1, 2, 3, and 4 when :

a. The associated unit's pump is OPERABLE ; and

b. The associated piping , valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

Portions of the NSWS system are shared between the two units (Figure B 3.7.7-1). The shared portions of the system must be OPERABLE for each unit when that unit is in the MODE of Applicability. Additionally, both normal and emergency power for shared components must also be OPERABLE. If a shared NSWS component becomes inoperable , or normal or emergency power to shared components becomes inoperable , then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of applicability of the LCO. APPLICABILITY In MODES 1, 2, 3, and 4, the NSWS is a normally operating system that is required to support the OPERABILITY of the equipment serviced by the NSWS and required to be OPERABLE in these MODES. In MODES 5 and 6, the requirements of the NSWS are determined by the systems it supports . ACTIONS If one NSWS train is inoperable , action must be taken to restore OPERABLE status within 72 hours. In this Condition , the remaining OPERABLE NSWS train is adequate to perform the heat removal function . However, the overall reliability is reduced because a single failure in the OPERABLE NSWS train could result in loss of NSWS function . Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating ," should be entered if an inoperable NSWS train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6 , "RCS Loops-MODE 4," should be entered if an inoperable NSWS train results in an inoperable decay heat removal train. McGuire Units 1 and 2 B 3.7.7-3 Revision No . ~

NSWS B 3.7.7 BASES ACTIONS (continued) This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour Completion Time is based on the redundant capabilities afforded by the OPERABLE train , and the low probability of a OBA occurring during this time period . A onetime change to TS 3.7.7 extends Action A.1 completion time (CT) from 72 hours to 14 days in order to address_£ an 'A' Train Operable but Degraded Nnon-GQonforming (OBDN) condition...Qn that affects the 'A' Train NSWS supply piping from the Standby Nuclear Service Water Pond (SNSWP) pump NPSH. The change also affects TS 3.5.2, Emergency Core Cooling System (ECCS) - Operating ; TS 3.6.6, Containment Spray System (CSS) ; TS 3.7.5 , Auxiliary Feedwater (AFW) System; TS 3.7 .6, Component Cooling Water (CCW) System; TS 3.7.7, Nuclear Service Water System (NSWS); TS 3.7.9, Control Room Area Ventilation System (CRAVS); TS 3.7.11 , Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) , and TS 3.8.1 , AC Sources-Operating . A Note similar to the following is placed in each of the above listed TS:

                    "*'A' Train NSWS is allowed to be inoperable for a total of 14 days for tho correction of a degraded to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity, or by March ;21, 201 ~+. whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available , the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Commitments described in MNS LAR submittal correspondence letter MNS-17-03116 005 ."

B.1 and B.2 If the NSWS train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. McGuire Units 1 and 2 B 3.7. 7-4 Revision No. ~

NSWS B 3.7.7 The allowed Completion Times are reasonable , based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. McGuire Units 1 and 2 B 3.7.7-5 Revision No. 1+4G

NSWS B 3.7.7 BASES The following table identifies those actions committed to by Duke Energy in letter MNS-17-03116 005, dated February 10, 2016 September 14, 2017 for the approval of License Amendments ~ and ~ for Units 1 and 2 respectively.

1. REGULATORY COMMITMENTS 1 The 'A' Train NSWS pumps will remain running and aligned to Lake Norman during the extended CT until the system is ready for post maintenance testing .

2 Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS piping from the SNSWP is not available will be evaluated for impact on the ability of the system to operate while taking suction from the Lake Norman Low Level Intake (LLI) and will be limited to a 72 hour completion time. 3 The 'B' Train NSWS will be placed in its ESFAS alignment to the SNSWP water source with the '8' Train pumps in standby prior to starting the LAR activity and remain in this alignment until the 'A' Train NSWS SNSWP water source is restored and ready for post maintenance testinq . 4 Procedures will be established to provide an additional defense in depth contingency that could be used in the event of an extremely low probability of a loss of the Lake Norman water source due to a seismic event. The procedures will ensure that system operation is maintained within design limits (less than or equal to 2 NSWS pumps running on a header), control of maximum system flow, and that system configuration prevents interaction of the degraded equipment with the functional equipment. 5 Fukushima Response FbeX medifisatiens will be installed and the FLEX strategies will be available for implementation as additional defense-in-depth on both units. 6 During the period in which the 'A' NSWS suction path from the SNSWP is non-functional , no discretionary maintenance or discretionary testing will be planned on the following :

• 1AEDG
• 2AEDG
• The 'A' Train of NSWS excluding the activities described in the LAR for the 'A' Train NSWS piping to the SNSWP.
• The 'B' Train of NSWS, ECCS, CSS, AFW , CCW, CRAVS , ABFVES or the EDGs
• The switchyard and other offsite power sources
• The SSF McGuire Units 1 and 2 B 3.7 .7-6 Revision No. j1.4G

NSWS B 3.7.7 BASES 7 A condition in which repairs could impact the ability of aR--Other SSC.§. to perform its Safety Function would result in termination of activities. The inspection may I identify a condition that cannot be resolved within the 14 day completion time . Should such a condition be identified then the NSW system will be restored to its current OBDN condition. If the RGV-survey presents any opportunities for a less intrusive or less time consuming solution for addressing the OBDN condition , then I these opportunities will be pursued , as appropriate. g IA aR astivity plaRRes to Be peFfaFrnes sepaFate fFarn tt:ie ~ 4 say sornpletioR tirne FopaiF astivity, ORN 7A will BO testes foF leakage aRs asjustes if Rosossary to rniRirni~e leakage. g IA aR astivity plaRRes to Be poFfoFrnes sepaFate fForn tl=le ~ 4 say sornpletioR tirne FepaiF astivity tl=le St>JSWP isolatioR flaRge will BO test fittes to tl=lo 'A' St>JSWP pipe. I 4-0 PFOSOSUFO guisaRSO 1.vill estaBlisl=I SORtFols to lirnit evasuatioR aiF pFOSSUFO to less tl=laR a pmseteFrniROS value iR OFSOF to pFOVORt aiF iRtFUSiOR iRtO tl=le opeFatiRg t>JSl/!JS . 44 b)esisates peFSORROI 1.-.iitl=I pFOSOSUFO guisaRSO will Be pF01,iises to slose tl=le NSl/iJS assess rnaR 11tay iR tl=le au~@ai:y BuilsiRg iR tl=le e11eRt of aRy of tl=le followiRg :

• AR eRgiReeFes Safety i;:eatum (E:SF) astuatioR
• eRhy iRto RP,lO,Wa700,lOOa NatuFal QisasteFs
• eRtFy iRto RP,lQ,t,AJe700,l007 E:aFtl=IEjuake

~ This activity will be controlled under the Infrequently Performed Test or Evolution {IPTE) process defined in Fleet Directive AD-OP-ALL-106, "Conduct of I Infrequently Performed Tests or Evolutions", and Duke Energy's Work Management and Execution procedures. McGuire Units 1 and 2 B 3.7.7-7 Revision No. jt4G

NSWS B 3.7.7 BASES

 ~   QuFiR§ flSFieEls wl=leR U:ie auxiliaPf euilEliR§ NSVVS f)ifliR§ maRway is 9fl9R, EleElisateEl i:ierseRRel AaYiR§ semmuRisatieR te tl=le maiR seRtrnl rnem witA flF960SUF0S te 69RtiRueusly meRiteF aREl FeSf)9RS te QR~J 7A leal~a§e will ee iR i:ilase. If leaka§e iRGFeases aREl Feasl::ies tl::ie flFe EleteFmiReEl leak Fate limit, tl::ie Fei:iaiF asti 1.iity will ee stei:ii:iea, aREl tl=le maRway will ee sleseEl. If 69REliti9RS flFe 11eRt tl::ie flFemi:it slesuFe ef tl::ie maRway, tl=leR ei:ieFatieRs will i:ilase tl::ie '13' NSWS trniR iR ei:ierntieR, sesurn 'A ' NSVVS ei:ierntieRs aREl iselate tl::ie 'A' NSVVS tFaiR te stei:i tl::ie leaka§e as felle1+11s:

If tl::ie maRway saRRet ee immeEliately sleseEl tl=leR i:ieFfeFm tl::ie fellewiR§ astieRs te iselate tl::ie flewi:iatl::i fFem bake ~JeFmaR witAiR ~ § miRutes:

• Stei:i tl=le A NSWS f)umi:is frem tl::ie seRtrnl rnem
• Giese QR~J ~~AG aREl QR~J ~ d,I\ frnm tl=le seRtrnl rnem te iselate tl::ie flewi:iatA fFem bake ~JeFmaR
• StaFt 13 +FaiR ~JSWS i:iumi:is

 -14  If tl::ie NSWS f)if)iR§ ma Away iR tl::ie auxiliaP,* euilEliR§ is ei:ieReEl tl::ieR f)FieF te tl::ie 9Feasl::i ef tl::ie NSWS i:iifliR§ aR e>w*aluatieR ef QR~J 7A leaka§e will ee i:ieFfeFmeEl te 1.ialiElate flF9fl9F iselatieR aREl tl::iat leaka§e is witAiR assei:itaele limits.

4-e~ McGuire will communicate with the Tra nsmission Control Center (TCC) to ensure I that the McGuire Control Room is notified in the event of potential grid disturbances in order that an appropriate plant response can be formulated . 4-&10 The Work Control Center or OCC will monitor weather forecasts and radar during the activities that require the NSW S piping personnel access points to be open to I assess the potential for severe weather conditions (tornado, thunderstorms). 47.11 Tra ining will be provided in accordance with the Systematic A pproach to Trai ning I (SAT) process to Operations personnel on this TS cha nge and the associated evolution to inspect and correct the Ele§rnEloEl non-conforming condition in the 'A' I NSWS supply piping from the SNSWP. 4-812 Operations will review applicable abnormal operating procedures related to the I response to an earthquake, the loss of the Lake Norman and the loss of NSWS prior to making 'A' NSWS suction path from the SNSWP inoperable and each shift until 'A ' Train NSWS operability is restored . McGuire Units 1 and 2 B 3.7.7-8 Revision No. jt4o

NSWS B 3.7.7 BASES W13 The repair work on the NSWS 'A' Train suction from the SNSWP will be scheduled during a period in which hurricanes and tornadoes have a lower likelihood of occurrence. ~14 The Outage Command Center (OCC) will be manned while performing the activities authorized by this amendment. 24~ The following list of equipment will be protected:

          *    'B' Train NSWS

• 18 EDG
• 28 EDG
• 18 ECCS
• 28 ECCS
• 18 css
• 28 css
• 18AFW
• 28AFW
• 1BCCW
• 28CCW
• 8 CRAVS
• 8 A8FVES
• Auxiliary Building WZ Sump and equipment supporting function of sump
• SSF including Standby Makeup pumps for Unit 1 and Unit 2
• Unit 1 TDCAP
• Unit 2 TDCAP
• Unit 1 Containment Ventilation Cooling Water System (RV)

_* _ Unit 2 Containment Ventilation Cooling Water System (RV)

• Switch~ard 22 If FoquiFed to Bo installed tl:le new peFSonnel access opening to Bo located on tl:le

      'A' +Fain ~SV\IS piping in tl:le auxiliai:y Building will Bo designed and installed in accoFElance witl:l tl:le ~ngineeFing Gl:lan§o PFocess.

McGuire Units 1 and 2 8 3.7.7-9 Revision No. jt4G

NSWS B 3.7.7 BASES ~16 Foreign Material Exclusion (FME) will be controlled during the proposed activities in accordance with AD-MN-ALL-0002, Foreign Material Exclusion (FME). Any debris resulting from the obstruction removal activity will be mechanically cleaned out before the system is closed for return to service per FME plan developed in accordance with the above procedure. The 'A' NSWS piping system will also be ¥i6ee-inspected prior to closeout. The s~stem will then be aRG-reversed flushed from the LLI to the SNSWP with isolation to downstream components to force any sediment back to the SNSWP. 24 FellewiA§ 'A' +raiA NSVVS FesteFatieA, testiA§ will Be 13eFfeFmeEI te veFify tl:iat tl'le as left NS\'VS 13eFfeFmaAce meets eF exceeEls 13m activity 13eFf9FmaAce iAcluEliA§

     'A' +FaiA NSW 13um13 NPSl=l ceAElitieAs.

~1l Prior to entering the 14 day CT perform an evaluation to ensure that there will be no anticipated impact to 'A' NSWS water supply from the LLI from Alewife fish during the 14 day CT .

~    +Fie Aew 13eFseAAel access 13i13iA§ e13eAiA§ (iA tl:ie auxiliary BuilEliA§) will Be C9AtrnlleEI BY usiA§ J3F9CeEIUFOS Elevele13eEI 9F Fe1,iiseEI feF tl:iis J3UFJ39Se te maiAtaiA 13esiti11e ceAtrnl ef tl:ie e13eAiA§ aAEI te 13FeveAt a A uAmeAiteFeEI Felease.

2+ +Fie eRA+ J3F9§Fam iAcluEles tl:ie e13tieA te use a SSA (Safety Si§AificaAt Activity) ceEle wl:iicl:i will cause tl:ie Fisk ceAElitieA celeF te Be "¥ebbG\0,1. MNS will use tl:iis ceEle EluFiA§ tl:ie acti11ities ElescFiBeEI iA tl:iis bAR ~18 Designated operators will be available to execute the manual actions associated with aligning the affected unit's 'A' Train NSWS pump to the 'B' NSWS SNSWP via the Main Supply Crossover piping .

~     If tl:ie ceAtiA§eAcy 13eFseAAel access e13eAiA§ is iAstalleEI , tl:ieA SecuFity 13eFseAAel will estaBlisA tl:ie J3F9J3eF CSAtFels aAEI cem13eAsater:y meaSUFOS J3FOSCFiBeEI BY secuFity J3F9C9EIUF9S aAEI tl:ie secuFity 13laA.

McGuire Units 1 and 2 B 3.7.7-10 Revision No. ~

NSWS B 3.7.7 BASES W19 In support of the contingency the following conditions will be established before the start of activities in the LAR:

• The 'A' train supply header crossover valve (ORN-14A) will be opened prior to the evolution and power will be removed from the valve operator.
• The 'B' train supply header crossover valve (ORN-158) will be maintained closed with the ESFAS signal from each unit blocked prior to the evolution. Maintaining valve ORN-158 closed with power removed satisfies operability requirements for the 'B' Train NSWS. The 'B' vY:alve fO RN-15Bj can be opened from the control room after power is restored if conditions warrant the use of this contingency.

J4 Operations will utilize the concurrent dual verification process when operating QRN +A.

~    In order to prei.1ent inad11ertent operation of QRl'IJ +A, MNS will perform the fellowing actions to ensure that the position of this 11al11e is physically restrained with several Barriers in place to prevent operation or movement of the valve while the l'IJS\fl/S piping access rnanway in the auxiliary Building is open :

• The operating hand wheel fer QRN +A will Be in the closed position and restrained with a lock and tag .
• A mechanical stern locking device will Be installed on QRN +A to prevent ANY movement of tho val11e disk.
• electrical isolation of the QRN +A motor operator will Be estaBlished BY rerno11ing its electrical supply Breaker from its MGG cuBical , and the CU Biele door tagged to prevent installation of tho Breaker while tho auxiliary Building rnanway is open.
• A dedicated person with no other duties will BO stationed in tho room where QRN +A and the access rnanway are located to monitor fer QRN

              +A leakage and to prevent anyone from operating QRN +A while the NSVVS piping rnanway is open .

McGuire Units 1 and 2 B 3.7.7-11 Revision No. 1i-4G

NSWS B 3.7.7 BASES SURVEILLANCE SR 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the NSWS components or systems may render those components inoperable, but does not affect the OPERABILITY of the NSWS. Verifying the correct alignment for manual, power operated , and automatic valves in the NSWS flow path provides assurance that the proper flow paths exist for NSWS operation . This SR does not apply to valves that are locked, sealed , or otherwise secured in position , since they are verified to be in the correct position prior to being locked, sealed , or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position . This SR does not apply to valves that cannot be inadvertently misaligned , such as check valves. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. SURVEILLANCE REQUIREMENTS (continued) SR 3.7.7.2 This SR verifies proper automatic operation of the NSWS valves on an actual or simulated actuation safety injection signal. The NSWS is a normally operating system that cannot be fully actuated as part of normal testing . 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 3.7 .7.3 This SR verifies proper automatic operation of the NSWS pumps on an actual or simulated actuation signal. The NSWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation . 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 3.7.7-12 Revision No. j+4Q

NSWS B 3.7.7 BASES REFERENCES 1. UFSAR, Section 9.2 .

2. UFSAR, Section 6.2.

3. UFSAR, Section 5.4.

4. 10 CFR 50.36, Technical Specifications, (c)(2)(ii) .

5. 10 CFR 50, Appendix A, GDC 5, "Sharing of Structures, Systems, and Components".

McGuire Units 1 and 2 B 3.7.7-13 Revision No . .:t.4G

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                                                                                  - - - - AAI           A. 8 ~ SHARED RC OISOl Note:

NSWS is the McGuire system designation for the Nuclear Service Water System

Figure 2: Nuclear Service Water System Normal 100°/o Lineup for Both Units: INFORMATION ONLY CIRC WATE R DISCHARGE TO LAKE N ORMA N RC NORMAL 100% NSWS ALIGNMENT OISIX BOTH UNITS & BOT H TRAI NS TAKE SUCTION FROM AN D RETURN TO LAKE NOR MAN VA RC YU lit!' Sl.PPl.'f

                                        ~         i£lfl CCCl.£RS             CROSSO'iEll y y                                                                        Normally only one Train in ope r ation with one pump running on each unit.

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Figure 3: Engineered Safety Feature Actuation System (ESFAS) Lineup: INFORMATION ONLY 'A' TRAIN Discharge to lake Norma ~ RC ES FAS LINEUP (e.g. Safety Injection or loss ofOffs lt e Power) 01$0!. 'A' Train NSWS Pumps take suction from and return flow to Lake Norman

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• NSWS Pumps take suction from and return flow to the SNSWP eR\2!! elilOA A TRAIN IJIN1 47A. C Bot h Tra ins and all Pum ps o perating.

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Figure 4: Operating Basis Earthquake, Loss of Lake Norman Dam or LLI Lineup: INFORMATION ONLY POST OPERATING BASIS EARTHQUAKE (QBE), FAILURE OF LAKE AC OISOl NORMAN DAM OR LOSS OF LU LINEUP (Both NSWS Trains aligned to SNSWP) Running Pumps depenctof Offsite Power Status:

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Figure 5: Piping to Be Removed from Service during the Extended Completion Time: INFORMATION ONLY PIPING TO BE REMOVED FROM SERVICE fie OISOt ( 'A ' NSWS Train Suction Piping to the SNSWP) llllN 14811, c PIPIN G TO BE REM OVED FROM SERVICE

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                                                                                ~B~                                                                                         ess
                                                                                                                                                                            }Ql 2Rl'l419 IAICl8   C 0                                         ess
                                                                                                                                           ! - - - - ' ' - - - - - ' - --   }Ql 29
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                                          ~    VII    t.'t~        I I I I I I I TRAIH 8 SHAAEO VEllT VEllT COOl.ERS
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Figure 6: NSWS Alignment During 14 Day Out of Service Window: INFORMATION ONLY NSWS ALIGNMENT DURING 14 DAY OUT OF SERVICE WINDOW 'A ' NSWS Traon ..?fAC return to Lake / DISOI. No rman PC St.PP CllOSSINEJI ~~.i.14--4.W:f-..,

                                                                                                   'A' TRAIN STAYS IN. NORMAL I ESFAS
                                                     ' A' NSWS Train Suction                          ALIGNMENT drawing from LLI and Path ID SNSWP NOT                                    returning to Lake Norman AVAILABLE Ru     ng                                ESS ESS                                                                                             /

HOR r--ill~~~~.i.--r-~-.,..-~-.----<:>"<)---{ 1--..-----~--- HM 2A IA IAIC33 C ~

                                                                                                                                                        - --    ESS IUI ESS lM38r                                                                                              ,}..._.......__ _ _- ' - --     ESS IOI HOR                                                                                                                                        18 IA     1.:nr :

IO.'"'ESS o w er Rem oved ORN l SB Closed with E FAS Signal Bl o cked ESS HOR ESS IB --~------ t(ll 2A tOf

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IR'rnl78 ~ ESS ESS HOR "'>--Dl<:w-4.+<~+-+-+++++-t.rM"+-l--HH-l-'"'+-<:>'<l++i 1 ' l - - - ' - - -- --'-- - - IOI 28 28

                                                                                                  'B ' TRAIN IS PRE-ALIGNED TO THE SNSWP FOR wDEFENSE IN DEPTH" (Eliminates potential failures during transfer for ESFAS)

AC OISOI. 5

Figure 7: Contingency for Loss of 'B' NSWS pump After Response to Loss of Lake Norman: INFORMATION ONLY AC CONTINGENCY for 'B' TRAIN NSWS PUMP FAILURE OISOl. AFTER OBE AND LOSS OF LAKE NORMAN DAM OR LU (e.g. loss of 18 NSWS pump) 1481\ c " DEFENS~ IN DEPTH "

                                                                                                                    ' A' Train NSWS pump can be aligned to eflHI 47A. C                                                                                        SNSWP via the NSWS Supply Crossover ESS HOR 2A 2    ISOA IRN631lr                                                                                  H-ID'<>---< "'-l !~-----4---'---- IOI ESS ESS                                                                           s HOR                                                                           u                                                                   IB IA                                                                          p p                     LOSS OF 18 NSWS PUMP18:

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• Pump discharge vatve dosed c ESFAS Signals to Supply Cross ver Va lves Blocked

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      £SS HOR ~-~14--11-4-<~+.+.-1-4--144-4.......,~~l--l-IJ~::kl~                                                                                                           IOI 29                                                                                                                                                                 2B A failure of 28 NSWS pump could be addre sed s lmllat1y
                                                                  ** * * * **

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Figure 8: Nuclear Service Water System - Piping Diagram

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                                                                                                                                                                                   ~*-*

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Figure 9: Personnel Access Manway: I _J_ RH ~IE O PI P I NG 0£F'CCT RE PAIR 0Cl"IL J5-{ / I 15-c===========>

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ATTACHMENT 5 Regulatory Commitments

REG ULATORY COMMITMENTS The following table identifies those actions committed to by Duke Energy in this document. Any other statements made in this licensing submittal are provided for informational purposes only and are not considered to be regulatory commitments . Please direct any questions you may have in this matter to Jeff Thomas at 980-875-4499.

  #                                  REGULATORY COMMITMENTS 1     The 'A' Train NSWS pumps will remain aligned to Lake Norman during the extended CT until the system is ready for post maintenance testing .

2 Any maintenance that is performed on the remai ning portions of 'A' Train NSWS during the period in which the 'A' NSWS piping from the SNSWP is not available will be evaluated for impact on the ability of the system to operate while taking suction from the Lake Norman Low Level Intake (LU) and will be limited to a 72 hour completion time 3 The 'B' Train NSWS will be placed in its ES FAS alignment to the SNSWP water source prior to starting the LAR activity and remain in this alignment until the 'A' Train NSWS SNSWP water source is restored and ready for post maintenance testing . 4 Procedures will be established to provide an additional defense in depth contingency that could be used in the event of an extremely low probability of a loss of the Lake Norman water source due to a seismic event. The procedures will ensure that system operation is maintai ned within design limits (less than or equal to 2 NSWS pumps running on a header), control of maximum system flow, and that system configuration prevents interaction of the degraded equipment with the functional equipment. 5 FLEX strategies will be available for implementation as additional defense-in-depth on both units. 6 During the period in which the 'A' NSWS suction path from the SNSWP is non-functional , no discretionary maintenance or discretionary testing will be planned on the fo llowing :

a. 1A EOG

b. 2AEDG

c. The 'A' Train of NSWS excluding the activities described in the LAR for the

                      'A' Train NSWS piping to the SNSWP.

d. The 'B' Train of NSWS, ECCS, CSS, AFW, CCW, CRA VS, ABFVES or the EDGs

e. The switchyard and other offsite power sources

f. The SSF 7 A condition in which repairs could impact the abi lity of other SSCs to perform its Safety Function would resu lt in termination of activities. The inspection may identify a conditi on that cannot be resolved within the 14 day completion time. Should such a condition be identified then the NSW system will be restored to its current OBDN condition. If the survey presents any opportunities for a less intrusive or less time consuminq sol ution for addressing the OBDN condition, then these opportunities wi ll

be pursued , as appropriate. 8 This activity will be controlled under the Infrequently Performed Test or Evolution (IPTE) process defined in Fleet Directive AD-OP-ALL-0106 , "Conduct of Infrequently Performed Tests or Evolutions", and Duke Energy's Work Management and Execution procedures . 9 McGuire will communicate with the Transmission Control Center (TCC) to ensure that the McGuire Control Room is notified in the event of potential grid disturbances in order that an appropriate plant response can be formulated . 10 The Work Control Center or OCC will monitor weather forecasts and radar during the activities that require the NSWS piping personnel access points to be open to assess the potential for severe weather conditions (tornado , thunderstorms). 11 Training will be provided in accordance with the Systematic Approach to Training (SAT) process to Operations personnel on this TS change and the associated evolution to inspect and correct the non-conforming condition in the 'A' NSWS supply piping from the SNSWP. 12 Operations will review applicable abnormal operating procedures related to the response to an earthquake, the loss of the Lake Norman and the loss of NSWS prior to making 'A' NSWS suction path from the SNSWP inoperable and each shift until 'A' Train NSWS operability is restored. 13 The repair work on the NSWS 'A' Train suction from the SNSWP will be scheduled during a period in which hurricanes and tornadoes have a lower likelihood of occurrence. 14 The Outage Command Center (OCC) will be manned while performing the activities authorized by this amendment. 15 The following list of equipment will be protected :

a. '8 ' Train NSWS

b. 18 EOG

c. 28 EOG

d. 18 ECCS

e. 28 ECCS

f. 18 css

g. 28 css

h. 18AFW

i. 28AFW j . 18CCW

k. 28CCW I. 8 CRAVS m . 8 A8FVES

n. SSF including Standby Makeup pumps for Unit 1 and Unit 2 0 . Unit 1 TDCAP

p. Unit 2 TDCAP

q. Unit 1 Containment Ventilation Cooling Water System (RV)

r. Unit 2 Containment Ventilation Cooling Water System (RV)

s. Switch yard

16 Foreign Material Exclusion (FME) will be controlled during the proposed activities in accordance with AD-MN-ALL-0002, Foreign Material Exclusion (FME). Any debris resulting from the obstruction removal activity will be mechanically cleaned out before the system is closed for return to service per FME plan developed in accordance with the above procedure. The 'A' NSWS piping will also be inspected prior to closeout. The system will then be reversed flushed from the LLI to the SNSWP with isolation to downstream components to force any sediment back to the SNSWP. 17 Prior to entering the 14 day CT perform an evaluation to ensure that there will be no anticipated impact to 'A' NSWS water supply from the LLI from Alewife fish during the 14 day CT. 18 Designated operators will be available to execute the manual actions associated with aligning the affected unit's 'A' Train NSWS pump to the '8' NSWS SNSWP via the Main Supply Crossover piping. 19 In support of the contingency the following conditions will be established before the start of activities in the LAR:

• The 'A' train supply header crossover valve (ORN-14A) will be opened prior to the evolution and power will be removed from the valve operator.
• The '8' train supply header crossover valve (ORN-158) will be maintained closed with the ESFAS signal from each unit blocked prior to the evolution .

Maintaining valve ORN-158 closed with power removed satisfies operability requirements for the '8 ' train NSWS. Valve ORN-158 can be opened from the control room after power is restored if conditions warrant the use of this contingency.}}