ML18130A807

Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - Submittal of License Amendment Application to Remove Heaters from Ventilation System Technical Specifications

ML18130A807
Person / Time
Site:	Mcguire, Catawba, Harris, Robinson, McGuire
Issue date:	05/10/2018
From:	Capps S Duke Energy Carolinas, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18131A068	List: ML18130A807 RA-18-000, Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - Submittal of License Amendment Application to Remove Heaters from Ventilation System Technical Specifications RA-18-0001, Duke Energy Progress, LLC and Duke Energy Carolinas, LLC - License Amendment Application to Remove Heaters from Ventilation System Technical Specifications
References
RA-18-0001
Download: ML18130A807 (50)

Text

( -, DUKE ENERGY STEVEN CAPPS Senior Vice President Nuclear Corporate 526 South Church Street, EC-07H Charlotte, NC 28202 704-382-8162 Steven.Capps@duke-energy.com 10 CFR 50.90 Serial: RA-18-0001 May 10, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23

SUBJECT:

LICENSE AMENDMENT APPLICATION TO REMOVE HEATERS FROM VENTILATION SYSTEM TECHNICAL SPECIFICATIONS Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as "Duke Energy, hereby requests an amendment to the Technical Specifications (TS) for Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS), Units 1 and 2; Shearon Harris Nuclear Power Plant (HNP), Unit 1; and H.B. Robinson Steam Electric Plant (RNP), Unit 2.

The proposed amendment consists of the following changes:

1. The CNS, Units 1 and 2; and MNS, Units 1 and 2, removal of the ventilation system heaters from TS, consistent with the Westinghouse Owner's Group (WOG) Standard Technical Specifications (STS) (NUREG-1431 );

2. The CNS, Units 1 and 2, removal of the heaters from TS 3.9.3, "Containment Penetrations" and operate the Surveillance Requirement (SR) 3.9.3.2 for 15 continuous minutes, consistent with TSTF-522;

3. The HNP, Unit 1, increase of specified relative humidity (RH) for charcoal testing from the current 70% to 95% RH in several ventilation system SR and removal of heaters from the corresponding SR and Bases;

4. The RNP, Unit 2, increase of specified relative humidity (RH) for charcoal testing from the current 70% to 95% RH in the Ventilation Filter Testing Program (VFTP) and removal of heaters from the corresponding SR and Bases; and

U.S. Nuclear Regulatory Commission RA-18-0001 Page2

5. The correction of an inadvertent administrative error applicable to MNS TS 5.5.11, "Ventilation Filter Testing Program (VFTP)."

The Enclosure provides a detailed evaluation of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides existing TS Bases pages marked up based on the proposed changes (for information only).

The retyped TS pages will be provided to the NRG immediately prior to issuance of the approved amendments.

There are no regulatory commitments contained in this letter.

Duke Energy requests review and approval of this license amendment request within one year of acceptance. The amendment shall be implemented within 120 days following approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina and South Carolina state officials.

If you should have any questions regarding this submittal, or require additional information, please contact Art Zaremba, Manager-Nuclear Fleet Licensing, at 980-373-2062.

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

Executed on MAj IO I z.o I -&

Sincerely,

/JtO~

Steven Capps Senior Vice President - Nuclear Corporate NOE

Enclosure:

Evaluation of the Proposed Change Attachments: 1. Proposed Technical Specification Page Markups

2. Proposed Technical Specification Bases Page Markups (For Information Only)

U.S. Nuclear Regulatory Commission RA-18-0001 Page 3 cc (with Attachments):

C. Haney, USNRC Region II - Regional Administrator V. Cusumano, USNRC-Chief, TS Branch G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Zeiler, USNRC Senior Resident Inspector - HNP J. D. Austin, USNRC Senior Resident Inspector - CNS G. R. Eatmon, USN RC Senior Resident Inspector - RNP M. C. Barillas, NRR Project Manager - HNP M. Mahoney, NRR Project Manager - CNS & MNS D. Galvin, NRR Project Manager - RNP A. Gantt, Chief, Bureau of Radiological Health (SC)

A. Wilson, Attorney General (SC)

W. L. Cox, Ill, Section Chief, North Carolina Department of Health and Human Services, RP Section (NC)

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management (SC)

Chairman, North Carolina Utilities Commission

Enclosure:

Evaluation of the Proposed Change

Subject:

LICENSE AMENDMENT APPLICATION TO REMOVE HEATERS FROM VENTILATION SYSTEM TECHNICAL SPECIFICATIONS

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specifications Requirement 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3.

TECHNICAL EVALUATION

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions

5.

ENVIRONMENTAL CONSIDERATION

6.

REFERENCES

U.S. Nuclear Regulatory Commission RA-18-0001 Page2

1.

SUMMARY

DESCRIPTION Duke Energy requests a proposed change to the Technical Specifications (TS) for Catawba Nuclear Station, Units 1 and 2 (CNS); McGuire Nuclear Station, Units 1 and 2 (MNS); Shearon Harris Nuclear Power Plant, Unit 1 (HNP); and H. 8. Robinson Steam Electric Plant, Unit 2 (RNP).

The proposed amendments consist of the following changes:

2.

2.1

1. The CNS, Units 1 and 2; and MNS, Units 1 and 2, removal of the ventilation system heaters from TS, consistent with the Westinghouse Owner's Group (WOG) Standard Technical Specifications (STS) (NUREG-1431 );

2. The CNS, Units 1 and 2, removal of the heaters from TS 3.9.3, "Containment Penetrations" and operate the Surveillance Requirement (SR) 3.9.3.2 for 15 continuous minutes, consistent with TSTF-522;

3. The HNP, Unit 1, increase of specified relative humidity (RH) for charcoal testing from the current 70% to 95% RH in ventilation system SR and removal of heaters from the corresponding SR and Bases;

4. The RNP, Unit 2, increase of specified relative humidity (RH) for charcoal testing from the current 70% to 95% RH in the Ventilation Filter Testing Program (VFTP) and removal of heaters from the corresponding SR and Bases; and

5. The correction of an inadvertent administrative error applicable to MNS TS 5.5.11, "Ventilation Filter Testing Program (VFTP)."

DETAILED DESCRIPTION System Design and Operation Catawba Nuclear Station, Units 1 and 2 The proposed change modifies TS 3.6.10, "Annulus Ventilation System (AVS)," TS 3.7.10, "Control Room Area Ventilation System (CRAVS)", TS 3.7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)," TS 3.7.13, "Fuel Handling Ventilation Exhaust System (FHVES)," TS 3.9.3, "Containment Penetrations," TS 5.5.11, "Ventilation Filter Testing Program (VFTP)," and TS 5.6.6, "Ventilation Systems Heater Report."

The AVS is required by 1 O CFR 50, Appendix A, GDC 41, "Containment Atmosphere Cleanup",

to ensure that radioactive materials that leak from the primary containment into the reactor building (secondary containment) following a Design Basis Accident (OBA) are filtered and adsorbed prior to exhausting to the environment. The containment has a secondary containment called the reactor building, which is a concrete structure that surrounds the steel primary containment vessel. Between the containment vessel and the reactor building inner wall is an annulus that collects any containment leakage that may occur following a loss of coolant accident (LOCA) or rod ejection accident. This space also allows for periodic inspection of the outer surface of the steel containment vessel.

The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 3 The AVS consists of two separate and redundant trains. Each train includes a heater, prefilter/moisture separators, upstream and downstream high efficiency particulate air (HEPA) filters, an activated carbon adsorber section for removal of radioiodines, and a fan. Ductwork, valves and/or dampers, and instrumentation also form part of the system. The prefilters/moisture separators function to remove large particles and entrained water droplets from the airstream, which reduces the moisture content. A HEPA filter bank upstream of the carbon adsorber filter bank functions to remove particulates and a second bank of HEPA filters follow the adsorber section to collect carbon fines. Only the upstream HEPA filter and the carbon adsorber section are credited in the analysis. A heater is included within each filter train to reduce the relative humidity of the airstream, although no credit is taken in the safety analysis. The heaters are not required for OPERABILITY since the carbon laboratory tests are performed at 95% relative humidity, but have been maintained in the system to provide additional margin. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

The AVS initiates and maintains a negative air pressure in the reactor building annulus by means of filtered exhaust ventilation of the reactor building annulus following receipt of a safety injection (SI) signal.

The CRAVS ensures that the Control Room Envelope (CRE) will remain habitable for occupants during and following all credible accident conditions. This function is accomplished by pressurizing the CRE to ~ 1/8 (0.125) inch water gauge with respect to all surrounding areas, filtering the outside air used for pressurization, and filtering a portion of the return air from the CRE to clean up the control room environment.

The CRAVS consists of two independent, redundant trains of equipment. Each train consists of:

a pressurizing filter train fan a filter unit which includes moisture separator/prefilters, HEPA filters and carbon adsorbers the associated ductwork, dampers/valves, controls, doors and barriers Inherent in the CRAVS's ability to pressurize the control room is the CRE boundary. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and may encompass the non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The capability of the CRE boundary to perform its specified function must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of OBA consequences to CRE occupants. The CRE and its boundary must be intact or properly isolated for the CRAVS to function properly.

The ABFVES is a subsystem of the Auxiliary Building Ventilation System that helps maintain a suitable environment for the operation, maintenance and testing of equipment; and maintains a suitable environment for personnel access during normal plant operation and shutdown. During accident conditions the Auxiliary Building Ventilation System is designed to minimize the release

~----

U.S. Nuclear Regulatory Commission RA-18-0001 Page 4 of radioisotopes from the Emergency Core Cooling System (ECCS) pump rooms. ABFVES serves areas of the Auxiliary Building that are subject to potential contamination.

The ABFVES consists of two independent and redundant trains. Each train consists of a heater demister section and a filter unit section. The heater demister section consists of a prefilter/moisture separator (to remove entrained water droplets) and an electric heater (to reduce the relative humidity of air entering the filter unit). The filter unit section consists of a prefilter, an upstream HEPA filter, an activated carbon adsorber (for the removal of gaseous activity, principally iodines), a downstream HEPA filter and a fan. The downstream HEPA filter is not credited in the accident analysis, but serves to collect carbon fines. Ductwork, valves or dampers, and instrumentation also form part of the system. Following receipt of a SI signal, the system isolates non-safety portions of the ABFVES and exhausts air only from the ECCS pump rooms.

The ABFVES is normally aligned to bypass the system HEPA filters and carbon adsorbers.

During emergency operations, the ABFVES dampers are realigned to the filtered position, and fans are started to begin filtration. Also during emergency operations, the ABFVES dampers are realigned to isolate the non-safety portions of the system and only draw air from the ECCS pump rooms, as well as the Elevation 522 pipe chase and Elevation 543 and 560 mechanical penetration rooms.

The FHVES filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. The FHVES, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel pool area. The system consists of two independent and redundant trains with two filter units per train. Each filter unit consists of a heater, prefilters/moisture separators, HEPA filters, an activated carbon adsorber section for removal of gaseous activity, and a fan. Ductwork, valves or dampers, and instrumentation also form part of the system. The upstream HEPA filter bank functions to remove particulates and is credited in the safety analysis. A second bank of HEPA filters follows the adsorber section to collect carbon fines. The downstream HEPA filters are not credited in the analysis. A heater is included within each filter unit to reduce the relative humidity of the airstream. The heaters are not required for OPERABILITY, since the carbon laboratory tests are performed at 95% relative humidity, but have been maintained in the system to provide additional margin. The system initiates filtered ventilation of the fuel handling building following receipt of a high radiation signal. FHVES does not actuate on any Engineered Safety Feature (ESF) Actuation System signal. One train is required to be in operation whenever recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is being moved in the fuel handling building. The operation of one train of FHVES ensures, if a fuel handling accident occurs, ventilation exhaust will be filtered before being released to the environment. The prefilters/moisture separators remove any large particles in the air, and any entrained water droplets present.

The Containment Purge Exhaust System (CPES) is designed to maintain the environment of the containment within acceptable limits for personnel access during inspection, testing, maintenance, and refueling operations; and to limit the release of any contamination to the environment. CPES consists of two 50 percent capacity filter trains and fans. Purge air is exhausted from the containment through the Containment Purge Exhaust System to the unit vent where it is monitored for radioactivity level by the unit vent monitor prior to release to the atmosphere. There is one purge exhaust duct penetration through the Reactor Building wall

U.S. Nuclear Regulatory Commission RA-18-0001 Page 5 from the annulus area. There are three purge exhaust penetrations through the containment vessel, two from the upper compartment and one from the lower compartment. Two normally closed isolation valves at each penetration through the containment vessel provide containment isolation. One normally close isolation damper at the Reactor Building wall provides annulus isolation. The upper compartment purge exhaust ductwork is arranged to draw exhaust air into a plenum around the periphery of the refueling canal, effecting a ventilation sweep of the canal during the refueling process. The lower compartment purge exhaust ductwork is arranged so as to sweep the reactor well during the refueling process. CPES is isolated on a high radiation signal.

The VFTP is in the Administrative Controls section of the CNS TS. It is a program to implement required testing of ESF filter ventilation systems in accordance with RG 1.52, Revision 2 (Reference 2), and ANSI N510-1980. TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for AVS, CRAVS, ABFVES, CPES, and FHVES.

McGuire Nuclear Station, Units 1 and 2 The proposed change modifies TS 3.6.10, "Annulus Ventilation System (AVS)," TS 3.7.9, "Control Room Area Ventilation System (CRAVS)", TS 5.5.11, "Ventilation Filter Testing Program (VFTP)," and TS 5.6.6, "Ventilation Systems Heater Failure Report."

The AVS is required by 1 O CFR 50, Appendix A, GDC 41, "Containment Atmosphere Cleanup,"

to ensure that radioactive materials that leak from the primary containment into the reactor building (secondary containment) following a Design Basis Accident (OBA) are filtered and adsorbed prior to exhausting to the environment. The containment has a secondary containment called the reactor building, which is a concrete structure that surrounds the steel primary containment vessel. Between the containment vessel and the reactor building inner wall is an annulus that collects any containment leakage that may occur following a loss of coolant accident (LOCA) or rod ejection accident. This space also allows for periodic inspection of the outer surface of the steel containment vessel. The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment. Reactor building OPERABILITY is required to ensure retention of primary containment leakage and proper operation of the AVS.

The AVS consists of two separate and redundant trains. Each train includes a heater, mechanical demister, a prefilter/ moisture separator, upstream and downstream high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of radioiodines, and a fan. Ductwork, valves and/or dampers, and instrumentation also form part of the system.

The heaters and mechanical demisters function to reduce the moisture content of the airstream.

A second bank of HEPA filters follows the adsorber section to collect carbon fines and provide backup in case of failure of the main HEPA filter bank. Only the upstream HEPA filter and the charcoal adsorber section are credited in the analysis. The system initiates and maintains a negative air pressure in the reactor building annulus by means of filtered exhaust ventilation of the reactor building annulus following receipt of a Phase B isolation signal.

The prefilters remove large particles in the air, and the moisture separators remove entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal absorbers.

Heaters are included to reduce the relative humidity of the airstream. Periodic operation

U.S. Nuclear Regulatory Commission RA-18-0001 Page 6 ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The mechanical demisters cool the air to keep the charcoal beds from becoming too hot due to absorption of fission product.

The CRAVS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The CRAVS consists of two independent, redundant trains that draw filtered outside air and mix this air with conditioned air recirculating through the CRE. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. Each outside air pressure filter train consists of a prefilter, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity, and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines and provides backup in case of failure of the main HEPA filter bank. The CRAVS is an emergency system. During normal operation the CRE is provided with 100% recirculated air and the outside air pressure filter train is in the standby mode. Upon receipt of the actuating signal(s), the CRE is provided with fresh air through outside air intakes and is circulated through the system filter trains. A single CRAVS train can adequately pressurize the CRE relative to atmospheric pressure.

The VFTP is in the Administrative Controls section of the MNS TS. It is a program to implement required testing of ESF filter ventilation systems in accordance with RG 1.52, Revision 2 (Reference 2), and ANSI N510-1975. TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for AVS and CRAVS.

Shearon Harris Nuclear Power Plant, Unit 1 The proposed change modifies TS 3/4.7.6, "Control Room Emergency Filtration System," TS 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System," and TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System."

The Control Room Emergency Filtration System (CREFS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The system consists of two independent, redundant trains that recirculate and filter the air in the CRE and a CRE boundary that limits the inleakage of unfiltered air. Each CREFS train consists of a prefilter or demister, an electric heating coil, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity, and a fan.

A second bank of HEPA filters follows the adsorber section to collect carbon fines and provides backup in case of failure of the main HEPA filter bank. A heater is included within each filter train to reduce the relative humidity of the airstream. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions.

The CREFS is an emergency system, parts of which may also operate during normal unit operation in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters or demisters remove any large particles in the air, and any entrained

U.S. Nuclear Regulatory Commission RA-18-0001 Page 7 water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers.

The demister is important to the effectiveness of the charcoal adsorbers. Actuation of the CREFS places the system in the emergency mode (i.e., isolation with recirculation mode) of operation. Actuation of the system closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the air within the CRE through the redundant trains of HEPA and charcoal filters. The emergency mode also allows for pressurization and filtered ventilation of the air supply to the CRE.

The RAB Emergency Exhaust System serves to limit the post-accident radiological releases from selected potentially contaminated portions of the RAB. The system is provided to ensure that airborne leakage is filtered prior to release to the environment. It is designed with sufficient redundancy to meet single active failure criteria. The system consists of redundant 100 percent capacity fan and filter subsystems. Each of the two subsystem filter trains includes a motor operated butterfly valve, decay heat cooling air connection, demister, electric heating coil, medium efficiency filter, HEPA pre-filter, charcoal adsorber, and HEPA after-filter. A heater is included within each filter train to reduce the relative humidity of the airstream. On a Control Room Isolation Signal, initiated on either a Safety Injection Signal or following a detection of radioactivity or smoke at the Outside Air Intakes, the RAB Normal Ventilation system is secured, and the RAB Emergency Exhaust System is started. Either unit may be manually de-energized from the Control Room, and placed on standby.

The Fuel Handling Building Emergency Exhaust System (FHBEES) ensures that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. The system consists of redundant 100 percent capacity fan and filter subsystems. Each of the two subsystem filter trains includes a manually locked open inlet butterfly valve, demister, electric heating coil, medium efficiency pre-filter, HEPA pre-filter, charcoal adsorber, HEPA after-filter, and decay heat cooling air connection. A heater is included within each filter train to reduce the relative humidity of the airstream. Operation with the heaters on for~ 15 continuous minutes demonstrates OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The surveillance frequency is controlled under the Surveillance Frequency Control Program. The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the safety analyses. ANSI N510-1980 is used as a procedural guide for surveillance testing.

Criteria for laboratory testing of charcoal and for in-place testing of HEPA filters and charcoal adsorbers is based upon removal efficiencies of 95% for organic and elemental forms of radioiodine and 99% for particulate forms. The filter pressure drop was chosen to be half-way between the estimated clean and dirty pressure drops for these components. This assures the full functionality of the filters for a prolonged period, even at the TS limit.

H.B. Robinson Steam Electric Plant, Unit 2 The proposed change modifies TS 3.7.11, "Fuel Building Air Cleanup System (FBACS)."

The FBACS filters airborne radioactive particulates from the area of the spent fuel pool following a fuel handling accident in the Fuel Building. The FBACS, in conjunction with other normal operating systems, also provide environmental control of temperature and humidity in the spent fuel pool area. The FBACS is a single train system which consists of a heater, a prefilter, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity, and a fan.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 8 The FBACS is a manually initiated system, which may also be operated during normal plant operations. During movement of irradiated fuel in the fuel handling area, the FBACS is required to be OPERABLE and operating to alleviate the consequences of a fuel handling accident.

The VFTP is in the Administrative Controls section of the RNP TS. It is a program to implement required testing of ESF filter ventilation systems in accordance with RG 1.52, Revision 2 (Reference 2), and ANSI N510-1975 or N510-1980. TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for FBACS.

2.2 Current Technical Specifications Requirement Catawba Nuclear Station, Units 1 and 2 The CNS TS utilize different numbering and titles than the Westinghouse Owner's Group (WOG) Standard Technical Specifications {STS). These differences are administrative. The proposed change modifies TS 3.6.10, "AVS," TS 3.7.10, "CRAVS", TS 3.7.12, "ABFVES,"

TS 3.7.13, "FHVES," TS 3.9.3, "CPES," TS 5.5.11, "VFTP," and TS 5.6.6, "Ventilation Systems Heater Report." The following table summarizes the differences between the WOG STS numbering and titles and the corresponding CNS TS.

Technical Specification (WOG)

CNS Unit 1 and 2 Technical Specification STS 3.6.13 - Shield Building Air TS 3.6.10 - Annulus Ventilation Cleanup System (SBACS)(Dual System (AVS) and Ice Condenser)

STS 3. 7.1 O - Control Room TS 3. 7.10 - Control Room Area Emergency Filtration System Ventilation System (CRAVS)

(CREFS)

STS 3. 7.12 - Emergency Core TS 3.7.12 -Auxiliary Building Cooling System (ECCS) Pump Filtered Ventilation Exhaust Room Exhaust Air Cleanup System (ABFVES)

System (PREACS)

STS 3. 7.13 - Fuel Building Air TS 3. 7.13 - Fuel Handling Cleanup System (FBACS)

Ventilation Exhaust System (FHVES)

STS 3.9.4 - Containment TS 3.9.3 - Containment Penetrations Penetrations The WOG STS 3.6.13, "Shield Building Air Cleanup System (SBACS)" corresponds to the CNS TS 3.6.10, "Annulus Ventilation System (AVS)." The current CNS TS 3.6.10, "AVS," includes a Condition B where if one or more Annulus Ventilation System train(s) heater is inoperable, that train must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 9 The WOG STS 3.7.10, "Control Room Emergency Filtration System (CREFS)" corresponds to the CNS TS 3.7.10, "Control Room Area Ventilation System (CRAVS)." The current CNS TS 3.7.10, "CRAVS" includes a Condition C where if one or more CRAVS train(s) heater is inoperable, that train must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.

The WOG STS 3. 7.12, "Emergency Core Cooling System (ECCS) Pump room Exhaust Air Cleanup System (PREACS)" corresponds to the CNS TS 3. 7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)." The current CNS TS 3.7.12, "ABFVES" includes a Condition D where if one or more ABFVES train(s) heater is inoperable, that train must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.

The WOG STS 3.7.13, "Fuel Building Air cleanup System (FBACS)" corresponds to the CNS TS 3.7.13, "Fuel Handling Ventilation Exhaust System (FHVES)." The current CNS TS 3.7.13, "FHVES" includes a Condition B where if one or more FHVES train heaters is inoperable, that train heater must be restored to OPERABLE status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report within 7 days.

The WOG STS 3.9.4, "Containment Penetrations" corresponds to the CNS TS 3.9.3, "Containment Penetrations." However, the WOG STS 3.9.4 does not have a comparable system to the CNS TS 3.9.3, "CPES." TS 3.9.3 contains a Condition B where if one or more CPES train(s) heater is inoperable, the CPES train(s) heater must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report within 7 days. Moreover, SR 3.9.3.2, tests the CPES and currently requires heaters operating for a continuous 1 O hour period.

The CNS TS 5.5.11.e, "Ventilation Filter Testing Program (VFTP)" demonstrates that the heaters for each of the ESF systems dissipate the value specified when tested in accordance with ANSI N510-1980. The ESF systems are AVS, CRAVS, ABFVES, CPES, and FHVES.

The CNS TS 5.6.6, "Ventilation Systems Heater Report" is contained within the Programs and Manuals section of the TS. This TS requires a report be submitted within the following 30 days if any of the above mentioned Conditions are entered, that outlines the reason for the inoperability and the planned actions to return the systems to OPERABLE status. This reporting requirement does not appear in the WOG STS (NUREG-1431) (Reference 1).

McGuire Nuclear Station, Units 1 and 2 The MNS TS utilize different numbering and titles than the WOG STS. These differences are administrative. The proposed change modifies TS 3.6.10, "AVS," TS 3.7.9, "CRAVS,"

TS 5.5.11, "VFTP," and TS 5.6.6, "Ventilation System Heater Report." The following table summarizes the differences between the WOG STS numbering and titles and the corresponding MNS TS.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 10 Technical Specification (WOG)

STS 3.6.13 - Shield Building Air Cleanup System (SBACS)(Dual and Ice Condenser)

STS 3. 7.10 - Control Room Emergency Filtration System (CREFS)

MNS Unit 1 and 2 Technical Specification TS 3.6.10 - Annulus Ventilation System (AVS)

TS 3.7.9-Control Room Area Ventilation System (CRAVS)

The WOG STS 3.6.13, "SBACS" corresponds to the MNS TS 3.6.10, "AVS." The current MNS TS 3.6.10, "AVS," includes a Condition B where if one or more AVS train(s) heater is inoperable, that train must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.

The WOG STS 3.7.10, "CREFS" corresponds to the MNS TS 3.7.9, "CRAVS." The current MNS TS 3.7.9, "CRAVS" includes a Condition G where if one or more CRAVS train(s) heater is inoperable, that train must be restored to OPERABLE status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.

The MNS TS 5.5.11.c, "VFTP" demonstrates for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at the temperature and RH specified below. The ESF Ventilation Systems and their Penetrations, RHs, and Temperatures are shown below. Note the Containment Purge and Fuel Building Ventilation systems temperatures are 80°C.

ESF Ventilation System Penetration RH Temp.

Annulus Ventilation

<4%

95%

30°c Control Area Ventilation

< 0.95%

95%

30°c Aux. Bldg. Filtered Exhaust

<4%

95%

30°c Containment Purge (non-ESF)

<4%

95%

80°C Fuel Bldg. Ventilation (non-ESF)

<4%

95%

80°C The MNS TS 5.5.11.e, "VFTP" demonstrates that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1975. The ESF systems are AVS and CRAVS.

The MNS TS 5.6.6, "Ventilation Systems Heater Report" is contained within the Programs and Manuals section of the TS. This TS requires a report be submitted within the following 30 days if any of the above mentioned Conditions are entered, that outlines the reason for the inoperability and the planned actions to return the systems to OPERABLE status. This reporting requirement does not appear in the WOG STS (NUREG-1431) (Reference 1).

U.S. Nuclear Regulatory Commission RA-18-0001 Page 11 Shearon Harris Nuclear Power Plant, Unit 1 The HNP TS do not incorporate the format and structure of the WOG STS. The HNP TS utilize different numbering and titles than the STS. These differences are administrative. The proposed changes modify TS 3/4.7.6, "Control Room Emergency Filtration System," SR 4.7.6.a, 4.7.6.b.2, SR 4.7.6.c, and SR 4.7.6.d.4; TS 3/4.7.7, "Reactor Auxiliary Building (RAB)

Emergency Exhaust System," SR 4.7.7.a, SR 4.7.7.b.2, SR 4.7.7.c, and SR 4.7.7.d.5; and TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System," SR 4.9.12.a, SR 4.9.12.b.2, SR 4.9.12.c, and SR 4.9.12.d.5. The following table summarizes the differences between the WOG STS numbering and titles and the corresponding HNP TS.

Technical Specification (WOG)

HNP Unit 1 Technical Specification STS 3. 7.1 O - Control Room TS 3/4.7.6-Control Room Emergency Filtration System Emergency Filtration System (CREFS)

(CREFS)

STS 3. 7.12 - Emergency Core TS 3/4.7.7 - Reactor Auxiliary Cooling System (ECCS) Pump Building (RAB) Emergency Room Exhaust Air Cleanup Exhaust System System (PREACS)

STS 3.7.13 Fuel Building Air TS 3/4.9.12 - Fuel Handling Cleanup System (FBACS)

Building Emergency Exhaust System (FHBEES)

The WOG STS 3.7.10, "CREFS" corresponds to the HNP TS 3/4.7.6, "Control Room Emergency Filtration System." The current HNP TS 3/4.7.6 includes SR 4.7.6.a that tests each CREFS train to be OPERABLE at least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating.

The current HNP TS 3/4.7.6 also includes SR 4.7.6.b.2 to verify within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodide penetration of s 0.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. In addition, SR 4.7.6.c requires that after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, to verify within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodide penetration of S0.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. SR 4.7.6.d.4 verifies that the heaters dissipate 14 +/- 1.4 kW when tested in accordance with ANSI N510-1980.

The WOG STS 3.7.12, "ECCS PREACS" corresponds to the HNP TS 3/4.7.7, "Reactor Auxiliary (RAB) Emergency Exhaust System." The current HNP TS 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System" includes SR 4.7.7.a that tests each train to be OPERABLE

U.S. Nuclear Regulatory Commission RA-18-0001 Page 12 at the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating. SR 4.7.7.b.2 verifies, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodine penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. SR 4.7.7.c requires that after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, to verify within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. Finally, SR 4.7.7.d.5 verifies that the heaters dissipate 40 +/- 4 kW when tested in accordance with ANSI N510-1980.

The WOG STS ~.7.13, "FBACS" corresponds to the HNP TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System." The current HNP TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System" includes SR 4.9.12.a that tests each train to be OPERABLE at the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating. SR 4.9.12.b.2 verifies, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of AG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodine penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. SR 4.9.12.c requires that after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, to verify within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2, March 1978 (Reference 2), has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 70% in accordance with ASTM D3803-1989. Finally, SR 4.9.12.d.5 verifies that the heaters dissipate 40 +/- 4 kW when tested in accordance with ANSI N510-1980.

H. B. Robinson Steam Electric Plant, Unit 2 The RNP TS utilize different numbering and titles than the WOG STS. These differences are administrative. The proposed change modifies TS 3.7.11, "Fuel Building Air Cleanup System (FBACS)" and TS 5.5.11, "Ventilation Filter Testing Program (VFTP)." The following table summarizes the differences between the WOG STS numbering and titles and the corresponding RNP TS.

Technical Specification (WOG)

RNP Unit 2 Technical Specification STS 3.7.13 - Fuel Building Air TS 3. 7.11 - Fuel Building Air Cleanup System (FBACS)

Cleanup System (FBACS)

U.S. Nuclear Regulatory Commission RA-18-0001 Page 13 The WOG STS 3.7.13, "FBACS" corresponds to the RNP TS 3.7.11, "FBACS." The current RNP TS 3.7.11, "FBACS" includes a SR 3.7.11.1 that tests the FBACS train to be OPERABLE at least once per 31 days by verifying that the system operates for at least 15 continuous minutes with the heaters operating.

The RNP TS 5.5.11.c, "VFTP" demonstrates for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°) and the RH specified below.

The ESF Filter Systems and their Penetrations and RHs are shown below.

ESF Filter System Contror Room Emergency Spent Fuel Building Containment Purge Penetration S2.5%

S10%

S10%

RH 70%

70%

95%

The RNP TS 5.5.11.e, "Ventilation Filter Testing Program (VFTP)" demonstrates that the heaters for the Spent Fuel Building ventilation filter system maintains the filter inlet air at s 70%

relative humidity when tested in accordance with ASME N510-1975.

2.3 Reason for the Proposed Change During the processing of the license amendment application to Revise Technical Specifications to Adopt TSTF-522, Revision 0, dated September 27, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16273A042), it was determined that additional TS changes could be made to CNS and MNS to better align them with the WOG STS.

These additional TS changes were outside the scope of TSTF-522 Consolidated Line Item Improvement Process (CLIIP) (Reference 4) and were removed in a Supplement to the TSTF-522 application, dated November 22, 2016 (ADAMS Accession No. ML16327A325).

The CNS and MNS TS contain Conditions related to heater inoperability that are proposed to be removed, in order to better align the TS with the WOG STS (NUREG-1431) (Reference 1).

These proposed changes to the TS will prevent unnecessary costs being applied to meet a provision no longer recommended by the NRC.

HNP is proposing to modify the SR to remove the requirement of the heaters to be operating when testing the CREFS, RAB Emergency Exhaust System, and FHBEES. To support removal of the heaters from this testing, it is also required to change SR 4.7.6.b.2, 4.7.6.c, 4.7.6.d.4, 4.7.7.b.2, 4.7.7.c, 4.7.7.d.5, 4.9.12.b.2, 4.9.12.c, and 4.9.12.d.5 to increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 14 These proposed changes to the TS will prevent unnecessary costs being applied to meet a provision no longer recommended by the NRC.

RNP is proposing to modify the SR to remove the requirement of the heaters to be operating when testing the F8ACS. To support removal of the heaters from this testing, it is also required to change TS 5.5.11.c and TS 5.5.11.e to increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal. These proposed changes to the TS will prevent unnecessary costs being applied to meet a provision no longer recommended by the NRC.

During the processing of the license amendment application to Revise Technical Specifications to Adopt TSTF-522, Revision 0, dated September 27, 2016 (ADAMS Accession No. ML16273A042), it was identified that an administrative error affecting MNS TS 5.5.11, "Ventilation Filter Testing Program {VFTP)," had been inadvertently introduced during processing of a prior license amendment. Specifically, on November 2, 2000, the NRC issued MNS License Amendment Numbers 196 and 177, which, in part, revised the laboratory test temperature of the charcoal adsorber samples for the Containment Purge and the Fuel Building Ventilation systems, as specified in TS 5.5.11.c, from 80°C to 30°C. Subsequently, on March 1, 2007, with associated correction letter dated September 18, 2007, the NRC issued MNS License Amendment Numbers 237 and 219. These license amendments inadvertently changed the aforementioned laboratory test temperatures back to 80°C. This LAR revised TS related to the Steam Generator Tube Integrity Program, specifically TS 5.5.9. When License Amendment Numbers 237 and 219 were issued, several pages from TS 5.5.9 were deleted, which reformatted a large portion of TS 5.5, "Programs and Manuals." During the approval and process to provide clean, retyped TS pages, the test temperature for Containment Purge (non-ESF) and Fuel Bldg. Ventilation (non-ESF) was inadvertently changed back to 80°C. No other LARs have been submitted by MNS that revise TS 5.5.11, since 2000. The Containment Purge and Fuel Building Ventilation systems testing has been performed per ASTM-D3803-1989 at 30°C since 2000. The proposed changes correcting the laboratory test temperatures of the charcoal adsorber samples for these systems in MNS TS 5.5.11.c is administrative only.

2.4 Description of the Proposed Change 2.4.1 Catawba Nuclear Station, Units 1 and 2 Conditions related to heater inoperability are proposed to be removed from the TS. The CNS TS will be revised as follows and the TS markups that reflect the proposed change are contained in Attachment 1.

TS 3.6.1 0 Condition 8, Required Actions 8.1 and 8.2, and corresponding Completion Times are proposed to be deleted.

The existing TS 3.6.1 0 Condition C is renumbered to Condition "B." As well as, the existing Required Actions C.1 and C.2 to be renumbered to "8.1" and "8.2," respectively.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 15 TS 3.7.10 Condition G, Required Actions G.1 and G.2, and corresponding Completion Times are proposed to be deleted.

TS 3.7.12 Condition D, Required Actions D.1 and D.2, and corresponding Completion Times are proposed to be deleted.

TS 3.7.13 Condition 8, Required Actions 8.1 and 8.2, and corresponding Completion Times are proposed to be deleted.

TS 3.9.3 Condition 8, Required Actions 8.1 and 8.2, and corresponding Completion Times are proposed to be deleted.

SR 3.9.3.2 is revised to state: "Operate each CPES for;;:: 15 continuous minutes."

TS 5.5.11.e is proposed to be deleted.

TS 5.6.6 is proposed to be removed and replaced with the words: "Not used."

2.4.2 McGuire Nuclear Station, Units 1 and 2 Conditions related to heater inoperability are proposed to be removed from the TS. The MNS TS will be revised as follows and the TS markups that reflect the proposed change are contained in Attachment 1.

TS 3.6.10 Condition B, Required Actions 8.1 and 8.2, and corresponding Completion Times are proposed to be deleted.

The existing TS 3.6.10 Condition C is renumbered to Condition "B." As well as, the existing Required Actions C.1 and C.2 to be renumbered to "B.1" and "8.2," respectively.

TS 3.7.9 Condition G, Required Actions G.1 and G.2, and corresponding Completion Times are proposed to be deleted.

TS 5.5.11.c Containment Purge (non-ESF) and Fuel Bldg. Ventilation (non-ESF)

Temperatures are revised to 30°C, as shown below:

ESF Ventilation System Penetration RH Temp.

Annulus Ventilation

<4%

95%

30°c Control Area Ventilation

< 0.95%

95%

30°c Aux. Bldg. Filtered Exhaust

<4%

95%

30°c Containment Purge (non-ESF)

<4%

95%

30°c Fuel Bldg. Ventilation (non-ESF)

<4%

95%

30°c TS 5.5.11.e is proposed to be deleted.

TS 5.6.6 is proposed to be removed and replaced with the words: "Not used."

U.S. Nuclear Regulatory Commission RA-18-0001 Page 16 2.4.3 Shearon Harris Nuclear Power Plant, Unit 1 HNP proposes to remove the requirement to test the CREFS, RAB Emergency Exhaust System, and FHBEES heaters and to increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal.

SR 4.7.6.a is revised to state: "At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;"

SR 4.7.6.b.2 is revised to state: "Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s0.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803 -1989."

SR 4.7.6.c is revised to state: "After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s0.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989."

SR 4.7.6.d.4 is proposed to be removed and replaced with the word: "Deleted."

SR 4.7.7.a is revised to state: "At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;"

SR 4.7.7.b.2 is revised to state: "Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodine penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989."

SR 4.7.7.c is revised to state: "After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989."

SR 4.7.7.d.5 is proposed to be removed and replaced with the word: "Deleted."

U.S. Nuclear Regulatory Commission RA-18-0001 Page 17 SR 4.9.12.a is revised to state: "At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;"

SR 4.9.12.b.2 is revised to state: "Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989."

SR 4.9.12.c is revised to state: "After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989."

SR 4.9.12.d.5 is proposed to be removed and replaced with the word: "Deleted."

2.4.4 H.B. Robinson Steam Electric Plant, Unit 2 RNP proposes to remove the requirement to test the FBACS heaters and to increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal.

SR 3.7.11.1 is revised to state: "Operate the FBACS for~ 15 continuous minutes;"

TS 5.5.11.c Spent Fuel Building RH is changed to 95% as shown below.

ESF Filter System Control Room Emergency Spent Fuel Building Containment Purge TS 5.5.11.e is proposed to be deleted.

Penetration S2.5%

70%

S10%

95%

S10%

95%

U.S. Nuclear Regulatory Commission RA-18-0001 Page 18

3.

TECHNICAL EVALUATION CNS and MNS Heater Conditions The NRC staff issued NRC Generic Letter (GL) 99-02: "Laboratory Testing of Nuclear-Grade Activated Charcoal" (ADAMS Accession No. ML082350935 and errata sheet at Accession No. ML031110094). GL 99-02 requested licensees to confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability. GL 99-02 also requested the licensees to account for the effects of moisture accumulation in adsorbers. The NRC staff then issued a draft revision of RG 1.52, DG-1102, to solicit comments on changes to the RG. The NRC staff received comments from the Nuclear HVAC Utilities Group (NHUG), among others.

NHUG stated that 1 O continuous hours of system operation would dry out the charcoal adsorber for a brief period of time but, following heater de-energization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level.

Therefore, the NRC staff updated RG 1.52 to include the new information (ADAMS Accession No. ML011710176). RG 1.52, Revision 3 (Reference 3), Regulatory Position 6.1 states, "Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components."

One of the reasons for the previous 10-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. However, these effects are accounted for in a ventilation filter testing program (VFTP) by performing testing at a RH of 95 percent. The VFTP requires testing of charcoal adsorber in ESF systems to determine methyl iodide penetration when tested in accordance with ASTM D3803-1989 at 30°C and 95% RH. ASTM D3803-1989 is an accurate and realistic protocol for testing charcoal in safety-related ventilation systems. The use of the stringent RH test parameter (95%), which contains a safety factor of greater than 2, assures that the charcoal efficiency assumed in the accident analysis is still valid at the end of an operating cycle.

As reflected in the CNS TS 5.5.11 "VFTP," testing of charcoal adsorber material for AVS, CRAVS, ABFVES, Containment Purge (non-ESF), and FHVES is performed at a temperature of s 30°C and 95% relative humidity, in accordance with ASTM D3803-1989 and the MNS TS 5.5.11, "VFTP," testing of charcoal adsorber material for AVS and CRAVS is performed at a temperature of 30°C and 95% RH, in accordance with ASTM D3803-1989. The technical analysis for TSTF-522 (Reference 4) states:

Plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function consistent with Regulatory Position 4.9, given above. These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases. These plants may also subsequently pursue elimination of the heaters from the plant design under 1 O CFR 50.59.

The CNS and MNS TS contain Conditions related to heater inoperability that do not appear in the WOG STS (NUREG-1431) (Reference 1) and are proposed to be removed. This will better align the CNS and MNS TS with the WOG STS (NUREG-1431), without compromise to safety.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 19 Following the issuance of Amendment Nos. 289 and 285 for CNS and Amendment Nos. 296 and 275 for MNS on May 8, 2017, the SR's are no longer relied upon to ensure the effects of moisture on the adsorber's ability to capture gaseous activity are accounted for, and thereby the 10-hour heater operational requirement is unnecessary. Reducing the required minimum system operation time to 15 continuous minutes, consistent with RG 1.52, Revision 3 (Reference 3), in conjunction with the VFTP, is sufficient to justify operability of the system and all its components.

The above-mentioned Conditions proposed to be removed, require, in part, submittal of a report in accordance with TS 5.6.6, "Ventilation Systems Heater Report," for heater inoperability greater than 7 days. Associated with the removal of these Conditions, TS 5.6.6 is proposed to be removed from the CNS and MNS TS. Note that this reporting requirement does not appear in the WOG STS (NUREG-1431) (Reference 1).

CNS CPES CNS TS 3.9.3 "Containment Penetrations" is proposed to be revised. The SR 3.9.3.2, which tests the CPES and currently requires the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period, is proposed to be revised to require operation of the system for 15 continuous minutes. Purge air is exhausted from the containment through the CPES to the unit vent where it is monitored for radioactivity level by the unit vent monitor prior to release to the atmosphere. The containment penetration requirements are applicable during movement of recently irradiated fuel assemblies within containment. Containment Purge is a non-ESF system however, it is conservatively treated like an ESF system and tested in accordance with ASTM D3803-1989 and RG 1.52, Revision 2. The ASTM D3803-1989 Standard no longer requires operation for 1 O hours utilizing the heaters. The WOG STS does not have a comparable system, but the proposed changes to reduce the SR 3.9.3.2 to 15 continuous minutes without heaters operating, meets the intent of TSTF-522 (Reference 4). Testing the heaters for 15 continuous minutes is sufficient to verify that the safety function of the heaters is met and, thus, these changes do not reduce the safety of these systems.

HNP SR Heater Removal The HNP SR 4.7.6.a, SR 4.7.7.a, and SR 4.9.12.a proposes to remove the references to "heaters operating." SR 4.7.6.b.2, SR 4.7.6.c, SR 4.7.7.b.2, SR 4.7.7.c, SR 4.9.12.b.2, and SR 4.9.12.c proposes to change the RH from 70% to 95%. Heater output testing in SR 4.7.6.d.4, SR 4.7.7.d.5, and SR 4.9.12.d.5 are proposed to be removed. The TS markups that reflect the proposed changes are contained in Attachment 1.

The HNP proposed change will increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal. This proposed change is consistent with TSTF-522, Revision 0, "Revised Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," (Reference 4) as the Standard TS (NUREG-1431) on which the Traveler is based, contains both options of with and without humidity control (i.e., electrical heaters) as

U.S. Nuclear Regulatory Commission RA-18-0001 Page 20 bracketed versions of the Surveillance Requirement. The current NRC staff guidance says that plants that test ventilation system adsorption at a RH of 95 percent do not require heaters for the ventilation system to perform its specified safety function and the bracketed phrase "with heaters operating" is not included in the SR. The SR would no longer require heaters to be operated during the test. With the implementation of TSTF-522 (Reference 4) and the HNP use of the more stringent charcoal testing requirements from ASTM D3803-1989, specifically, charcoal sample testing at a RH of 95 percent, the requirement for an electric heater output test is no longer applicable. This proposed change is consistent with TSTF-522 Traveler (Reference

4) and model safety evaluation (Reference 5) and does not constitute a technical deviation.

RNP SR Heater Removal The RNP SR 3.7.11.1 proposes to remove the reference to "heaters operating." TS 5.5.11.c proposed to change the Spent Fuel Building RH from 70% to 95%. Heater testing in TS 5.5.11.e is proposed to be removed. The TS markups that reflect the proposed changes are contained in Attachment 1.

The RNP proposed change will increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal. This proposed change is consistent with TSTF-522, Revision 0, "Revised Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," (Reference 4) as the Standard TS (NUREG-1431) on which the Traveler is based, contains both options of with and without humidity control (i.e., electrical heaters) as bracketed versions of the Surveillance Requirement. The current NRC staff guidance says that plants that test ventilation system adsorption at a RH of 95 percent do not require heaters for the ventilation system to perform its specified safety function and the bracketed phrase "with heaters operating" is not included in the SR. The SR would no longer require heaters to be operated during the test. With the implementation of TSTF-522 (Reference 4) and the RNP use of the more stringent charcoal testing requirements from ASTM D3803-1989, specifically, charcoal sample testing at a RH of 95 percent, the requirement for a heater test is no longer applicable. This proposed change is consistent with TSTF-522 Traveler (Reference 4) and model safety evaluation (Reference 5) and does not constitute a technical deviation.

MNS VFTP Error The correction of an inadvertent error applicable to MNS TS 5.5.11.c, "Ventilation Filter Testing Program (VFTP)" is administrative only.

Conclusion Removal of the ventilation system heaters from the CNS, MNS HNP, and RNP TS, as well as, HNP and RNP increasing the testing requirement to 95% RH on the charcoal filters will better align the TS to the WOG STS (NUREG-1431) (Reference 1). These proposed changes will prevent any unnecessary costs being applied to meet a provision no longer recommended by the NRC staff, without compromise to safety.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 21 The TS change requests described above for CNS, MNS, HNP, and RNP are supported by changes to the TS Bases. In addition to reflecting the requested change to the TS, the corresponding TS Bases are revised for clarity and consistency. The regulation at 1 O CFR 50.36 states, "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." Changes to the TS Bases will be made in accordance with the Technical Specifications Bases Control Program following approval of the requested amendment. The proposed TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132). Therefore, the TS Bases changes are provided for information in Attachment 2 and approval of the TS Bases is not requested.

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the proposed change.

The regulations at Title 1 O of the Code of Federal Regulations (1 O CFR) Part 50.36 Technical specifications," establish the re_quirements related to the content of the TS. Section 50.36(c)(2) states:

Limiting conditions for operation. Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The regulatory requirements in 10 CFR 50.36 are not specific regarding the actions to be followed when TS requirements are not met other than a plant shut down. The proposed change revises the CNS Technical Specification (TS) 3.6.10, "Annulus Ventilation System (AVS),"

TS 3.7.10, "Control Room Area Ventilation System (CRAVS)", TS 3.7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)," TS 3.7.13, "Fuel Handling Ventilation Exhaust System (FHVES)," TS 3.9.3, "Containment Penetrations (CPES)," TS 5.5.11, "Ventilation Filter Testing Program (VFTP)," and TS 5.6.6, "Ventilation Systems Heater Report," in order to remove the heater inoperability from the Conditions. Therefore, the proposed change is consistent with the LCO category of 1 O CFR 50.36. The proposed change revises the MNS TS 3.6.10, "Annulus Ventilation System (AVS)," TS 3.7.9, "Control Room Area Ventilation System (CRAVS)", TS 5.5.11, "Ventilation Filter Testing Program (VFTP)," and TS 5.6.6, "Ventilation Systems Heater Failure Report," in order to remove the heater inoperability from the Conditions. Therefore, the proposed change is consistent with the LCO category of 1 O CFR 50.36. Section 50.36(c)(3) states:

Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, the facility operation will be within safety limits, and that the limiting conditions for operation will be met.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 22 The proposed change revises the HNP TS 3/4.7.6, "Control Room Emergency Filtration System," TS 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System,"

TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System," and the RNP TS 3.7.11, "Fuel Building Air Cleanup System (FBACS)" in order to increase the testing requirement on the charcoal filters from the current 70% RH to the more stringent requirement of 95% RH. With the proposed increase to 95% RH for charcoal filter testing, the heaters will no longer be required to reduce the humidity of the incoming air to below 70% RH for the charcoal. The technical analysis for TSTF-522 (Reference 4) states that plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters and may eliminate the reference to heaters in the SR and Bases. Therefore, the proposed change is consistent with the SR category of 10 CFR 50.36.

1 0 CFR 50, Appendix A, General Design Criterion 19 GDC 19, "Control room," states a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. The proposed change does not affect the CNS, MNS, HNP, and RNP compliance with the intent of GDC 19.

1 0 CFR 50, Appendix A, General Design Criterion 41, 42, and 43 GDC 41, 42, and 43 discuss the design, inspection and testing of containment atmosphere cleanup systems. These systems shall "reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained." The proposed change does not affect the CNS, MNS, HNP, and RNP compliance with the intent of GDCs 41, 42, and 43.

10 CFR 50, Appendix A, General Design Criterion 61 GDC 61, "Fuel storage and handling and radioactivity control," states that "the fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, ( 4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions." The proposed change does not affect the CNS, MNS, HNP, and RNP compliance with the intent of GDC 61.

NUREG-1431 (Reference 1)

NUREG-1431, "Standard Technical Specifications, Westinghouse Plants, Revision 4.0,"

contains the improved Standard Technical Specifications (STS) for Westinghouse plants. The

U.S. Nuclear Regulatory Commission RA-18-0001 Page 23 improved STS were developed based on the criteria in the Final Commission Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132), which was subsequently codified by changes to 1 O CFR 50.36 (60 FR 36953).

The Abstract for NUREG-1431 states the following, in part:

Licensees are encouraged to upgrade their technical specifications consistent with those criteria and conforming, to the practical extent, to Revision 4 to the improved STS. The Commission continues to place the highest priority on requests for complete conversions to the improved STS.

To the extent practical, the proposed change to remove the heaters from the CNS TS (3.6.10, 3.7.10, 3.7.12, 3.7.13, and 3.9.3), and the MNS TS (3.6.10 and 3.7.9), as well as, revising CNS SR 3.9.3.2 to operate for 15 continuous minutes, upgrades the TS consistent with the criteria in Revision 4 of the improved STS. Increasing the HNP and RNP testing requirement on the charcoal filters to the more stringent RH, thus removing the heaters from the SR and Bases, also upgrades the TS consistent with the criteria in Revision 4 of the improved STS. CNS, MNS, HNP, and RNP more closely conform to NUREG-1431 as a result of the proposed change.

Regulatory Guide 1.52 (References 2 and 3)

RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System in Light-Water-Cooled Nuclear Power Plants," provides guidance and criteria to implement the regulations in 10 CFR related to air filtration and adsorption systems. The NRC staff updated RG 1.52 in June 2011, to include new information (ADAMS Accession No. ML011710176). RG 1.52, Revision 3, Regulatory Position 6.1 states, "each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components." One of the reasons for previous 10-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. However, these effects are already accounted for by performing testing at a relative humidity of 95 percent. CNS and MNS currently perform charcoal adsorber testing at 95 percent RH and HNP and RNP have proposed changing the required RH to 95 percent to account for the effects of moisture on the adsorber's ability to capture gaseous activity. Therefore, CNS, MNS, HNP, and RNP proposed to remove the requirement to operate heaters from the TS.

The proposed change does not affect compliance with these regulations or guidance and will ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.

4.2 Precedent The proposed change is consistent with NRC-approved license amendment issued to NextEra Energy Duane Arnold on July 25, 2013 (Amendment Number 285) for the Duane Arnold Energy Center (NRC ADAMS Accession No. ML13189A071 ). The approved TS changes are similar to the changes proposed for HNP and RNP by increasing the RH to 95% and removing the requirement of heater operation from the SR.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 24 4.3 No Significant Hazards Consideration Analysis Duke Energy requests approval of a change to the Catawba Nuclear Station, Units 1 and 2 (CNS) Technical Specifications (TS). The proposed change will revise CNS TS 3.6.10, "Annulus Ventilation System (AVS)," TS 3.7.10, "Control Room Area Ventilation System (CRAVS)," TS 3.7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES),"

TS 3.7.13, "Fuel Handling Ventilation Exhaust System (FHVES)," and TS 3.9.3, "Containment Penetrations," to remove the Conditions related to heater inoperability (specifically, Condition B of TS 3.6.10, Condition C of TS 3.7.10, Condition D of TS 3.7.12, Condition B of TS 3.7.13, and Condition B of TS 3.9.3), including reporting requirements in accordance with TS 5.6.6, "Ventilation Systems Heater Report." These Conditions are proposed to be removed, with subsequent Conditions renumbered, as necessary, and TS 5.6.6 is proposed to be deleted, as it is no longer necessary. In addition, requirements for testing heaters in these systems, as described in TS 5.5.11.e of the Ventilation Filter Testing Program (VFTP), are proposed to be removed. The proposed change also modifies the Containment Purge Exhaust System (CPES)

Surveillance Requirement (SR) to operate for 15 continuous minutes without heaters, consistent with TSTF-522.

Duke Energy requests approval of a change to the McGuire Nuclear Station, Units 1 and 2 (MNS) Technical Specifications (TS). The proposed change modifies MNS TS 3.6.10, "Annulus Ventilation System (AVS)," and TS 3.7.9, "Control Room Area Ventilation System (CRAVS)" to remove the Conditions related to heater inoperability (specifically, Condition B of TS 3.6.10, and Condition G of TS 3.7.9), including reporting requirements in accordance with TS 5.6.6, "Ventilation Systems Heater Failure Report." These Conditions are proposed to be removed, with subsequent Conditions renumbered, as necessary, and TS 5.6.6 is proposed to be deleted, as it is no longer necessary. In addition, the requirements for testing heaters in the above-mentioned systems, as described in TS 5.5.11.e of the Ventilation Filter Testing Program (VFTP), are proposed to be removed. The proposed change also modifies TS 5.5.11.c to correct a change that was inadvertently introduced during processing of a previous license amendment.

Duke Energy also requests approval of a change to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) Technical Specifications (TS). The proposed change modifies HNP TS 3/4.7.6, "Control Room Emergency Filtration System," SR 4.7.6.a, 4.7.6.b.2, SR 4.7.6.c, and SR4.7.6.d.4; TS 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System" SR 4.7.7.a, SR 4.7.7.b.2, SR 4.7.7.c, and SR 4.7.7.d.5; and TS 3/4.9.12, "Fuel Handling Building Emergency Exhaust System," SR 4.9.12.a, SR 4.9.12.b.2, SR 4.9.12.c, and SR 4.9.12.d.5. The proposed change will remove the requirement to test the CREFS, RAB Emergency Exhaust System, and FHBEES heaters and to increase the specified relative humidity (RH) for the charcoal testing from the current 70% to 95% RH.

Duke Energy also requests approval of a change to the H.B. Robinson Steam Electric Plant, Unit 2 (RNP) Technical Specifications (TS). The proposed change modifies RNP TS 3.7.11, "Fuel Building Air Cleanup System (FBACS)," SR 3.7.11.1 and TS 5.5.11.c, "Ventilation Filter Testing Program (VFTP)." The proposed change will remove the requirement to test the FBACS heaters and to increase the specified relative humidity (RH) for the charcoal testing from the current 70% to 95% RH. In addition, the requirements for testing heaters in the FBACS, as described in TS 5.5.11.e of the VFTP, are proposed to be removed.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 25

-- ------------~~

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 1 O CFR 50.92, Issuance of Amendment," as described below:

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

Response: No.

The proposed change affects various CNS, MNS, HNP, and RNP ventilation system TS.

For both CNS and MNS, the proposed change removes the requirement to test the heaters in these systems, and removes the Conditions in the associated TS which provide Required Actions, including reporting requirements, for inoperable heaters. In addition, the proposed change revises the CNS Surveillance Requirement (SR) 3.9.3.2 to operate for 15 continuous minutes without heaters running. For HNP and RNP, the proposed change removes the operability of the heaters from the SR. In addition, the electric heater output test is proposed to be deleted and a corresponding change in the charcoal filter testing to be made to require the testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function, which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change affects various CNS, MNS, HNP, and RNP ventilation system TS.

For both CNS and MNS, the proposed change removes the requirement to test the heaters in these systems, and removes the Conditions in the associated TS which provide Required Actions, including reporting requirements, for inoperable heaters. In addition, the proposed change revises the CNS Surveillance Requirement (SR) 3.9.3.2 to operate for 15 continuous minutes without heaters running. For HNP and RNP, the proposed change removes the operability of the heaters from the SR. In addition, the electric heater output test is proposed to be deleted and a corresponding change in the charcoal filter testing to be made to require the testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

The change proposed for these ventilation systems do not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components

U.S. Nuclear Regulatory Commission RA-18-0001 Page 26 are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change affects various CNS, MNS, HNP, and RNP ventilation system TS.

For both CNS and MNS, the proposed change removes the requirement to test the heaters in these systems, and removes the Conditions in the associated TS which provide Required Actions, including reporting requirements, for inoperable heaters. In addition, the proposed change revises the CNS Surveillance Requirement (SR) 3.9.3.2 to operate for 15 continuous minutes without heaters running. For HNP and RNP, the proposed change removes the operability of the heaters from the SR. In addition, the electric heater output test is proposed to be deleted and a corresponding change in the charcoal filter testing to be made to require the testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

The proposed increase to 95% RH in the required testing of the charcoal filters for HNP and RNP, compensates for the function of the heaters, which was to reduce the humidity of the incoming air to below the currently-specified value of 70% RH for the charcoal. The proposed change is consistent with regulatory guidance and continues to ensure that the performance of the charcoal filters is acceptable.

The CNS and MNS ventilation systems are tested at 95% relative humidity, and, therefore, do not require heaters to heat the incoming air and reduce the relative humidity. The proposed change eliminates Technical Specification requirements for testing of heater operation, and removes administrative actions for heater inoperability.

The proposed changes are consistent with the regulatory guidance and do not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 1 0 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.

U.S. Nuclear Regulatory Commission RA-18-0001 Page 27

5.

ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 0 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, 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.

6.

REFERENCES

1.

NUREG-1431, Standard Technical Specifications Westinghouse Plants Revision 4.0, U.S. Nuclear Regulatory Commission, April 2012.

2.

Regulatory Guide 1.52, Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, Revision 2, U.S. Nuclear Regulatory Commission, March 1978.

3.

Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants, Revision 3, U.S. Nuclear Regulatory Commission, June 2001.

4.

TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month, dated March 30, 2010.

5.

Notice of Availability of the Model Safety Evaluation for Plant-specific Adoption of Technical Specification Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month, ' using the consolidated Line Item Improvement Process dated September 20, 2012.

PROPOSED TECHNICAL SPECIFICATION PAGE MARKUPS

3.6 CONTAINMENT SYSTEMS 3.6.10 Annulus Ventilation System (AVS)

LCO 3.6.10 Two AVS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A.

One AVS train A.1 Restore A VS train to inoperable.

OPERABLE status.

s..

GAe aF maFe ARRl:lll:ls 84 RestaFe AV-S tFaiR(s)

\\JeAtilatiaR System heateF ta QPERABLE (AV-S) traiR(s) heater status.

inaperable.

GR

~ Initiate aetian in assaFdanse with Spesifisatian 5.6.6.

~

~

~

Required Action and G.1 Be in MODE 3.

associated Completion Time not met.

A~

G.2 Be in MODE 5.

Catawba Units 1 and 2 3.6.10-1 AVS 3.6.10 COMPLETION TIME 7 days 7 days 7 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Amendment Nos. 173/165

No Changes. Included for information.

CRAVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Area Ventilation System (CRAVS)

LCO 3.7.10 Two CRAVS trains shall be OPERABLE.

---

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

The control room envelope (CRE) boundary may be opened intermittently under administrative controls.

APPLICABILITY:

MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One CRAVS train A.1 Restore CRA VS train to 7 days inoperable for reasons OPERABLE status.

other than Condition B.

B.

One or more CRAVS 8.1 Initiate action to implement Immediately trains inoperable due to mitigating actions.

inoperable CRE boundary in MODES 1, 2, 3, or 4.

AND 8.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND 8.3 Restore CRE boundary to 90 days OPERABLE status.

( continued)

Catawba Units 1 and 2 3.7.10-1 Amendment Nos. 250/245

No Changes. Included for information.

CRAVS 3.7.10 REQUIRED ACTIONS (continued CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and C.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4.

C.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> D.

Required Action and 0.1 Place OPERABLE CRAVS Immediately associated Completion train in operation.

Time of Condition A not met in MODE 5 or 6 or OR during movement of irradiated fuel 0.2 Suspend movement of Immediately assemblies.

irradiated fuel assemblies.

E.

Two CRAVS trains E.1 Suspend movement of Immediately inoperable in MODE 5 irradiated fuel assemblies.

or 6, or during movement of irradiated fuel assemblies.

OR One or more CRAVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.

F.

Two CRAVS trains F.1 Enter LCO 3.0.3.

Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

(continued)

Catawba Units 1 and 2 3.7.10-2 Amendment Nos. 260/255

REQUIRED ACTIONS (continued CONDITION One or more CRAVS train(s) heater inoperable.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION G4 Restore CRAVS train(s) heater to OPERABLE status.

G+/-

Initiate action in aooordanoe with Specification 5.6.6.

SURVEILLANCE SR 3.7.10.1 Operate each CRAVS train for~ 15 continuous minutes.

SR 3.7.10.2 Perform required CRAVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.7.10.3 Verify each CRAVS train actuates on an actual or simulated actuation signal.

SR 3. 7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

CRAVS 3.7.10 COMPLETION TIME 7 days 7 days FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Catawba Units 1 and 2 3.7.10-3 Amendment Nos. 289/285

3.7 PLANT SYSTEMS 3.7.12 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)

LCO 3.7.12 Two ABFVES trains shall be OPERABLE.

ABFVES 3.7.12

---

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

The ECCS pump rooms 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 train A.1 Restore ABFVES train to 7 days inoperable.

OPERABLE status.

B.

Two ABFVES trains 8.1 Restore ECCS pump 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable due to rooms pressure boundary inoperable ECCS pump to OPERABLE status.

rooms pressure boundary.

C.

Required Action and C.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met.

C.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

~

One or more ABFVES M

Restore ABJ;V~S train(s) 7days train(s) heater heater to OPERABLE inoperable.

status.

GR

~ Initiate aGtion in 7 days asGoFdanae with Spesifisation 5.e.e.

Catawba Units 1 and 2 3.7.12-1 Amendment Nos. 253/248

3.7 PLANT SYSTEMS 3.7.13 Fuel Handling Ventilation Exhaust System (FHVES)

FHVES 3.7.13 LCO 3.7.13 Two FHVES trains shall be OPERABLE and one train in operation.

APPLICABILITY:

During movement of recently irradiated fuel assemblies in the fuel building. I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more FHVES NOTE trains inoperable.

LCO 3.0.3 is not applicable.

A.1 Suspend movement of Immediately recently irradiated fuel assemblies in the fuel building.

~

ReE)uiFee FM}JES tFaiR 8:4 ResteFe FMVES tFaiR 7eays heateF inepeFable.

heateF te OPERi\\BLE status.

OR

~ I Ritiate astieR iR

+-Gay$

aeaeFeaRee *1,ith SpeeifieatieA e.6.6.

Catawba Units 1 and 2 3.7.13-1 Amendment Nos. 188/191

No changes. Included for information.

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a.

The equipment hatch closed and held in place by a minimum of four bolts;

b.

A minimum of one door in each air lock closed; and

c.

Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

1.

closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2.

exhausting through an OPERABLE Containment Purge Exhaust System (CPES) HEPA filter and carbon adsorber.

APPLICABILITY:

During movement of recently irradiated fuel assemblies within containment.

ACTIONS A.

CONDITION One or more containment penetrations not in required status.

Catawba Units 1 and 2 A.1 REQUIRED ACTION Suspend movement of recently irradiated fuel assemblies within containment.

3.9.3-1 COMPLETION TIME Immediately

( continued)

Amendment Nos. 227 /222

Containment Penetrations 3.9.3 ACTIONS (continued)

CONDITION REQUIRED ACTION One or more CPES train(s) heater inoperable.

S-4 Restore CPES train(s) heater to OPERABLE statYs.

s..-2 Initiate action in accordance with Specification 5.6.6.

SURVEILLANCE REQUIREMENTS SR 3.9.3.1 SR 3.9.3.2 SR 3.9.3.3 SURVEILLANCE Verify each required containment penetration is in the required status.

rminutesl

\\I J

Operate each CPES for~ +O continuous~ }.tJith the heaters operating.

Perform required CPES filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

COMPLETION TIME 7 days 7 days FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the VFTP Catawba Units 1 and 2 3.9.3-2 Amendment Nos. 263/259

No changes. Included for information only.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.10 5.5.11 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

Ventilation Filter Testing Program (VFTP}

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980, with exceptions as noted in the UFSAR.

a.

Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below+/- 10%.

(continued)

Catawba Units 1 and 2 5.5-12 Amendment Nos. 280/276

No changes. Included for information only.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program {VFTP) (continued)

ESF Ventilation System Annulus Ventilation Control Room Area Ventilation Aux. Bldg. Filtered Exhaust Containment Purge (non-ESF) (2 fans)

Fuel Bldg. Ventilation Penetration and System Bypass

< 1%

< 0.05%

< 1%

< 1%

< 1%

Flowrate 9000 cfm 6000 cfm 30,000 cfm 25,000 cfm 16,565 cfm

b.

Demonstrate for each of the ESF systems that an inplace test of the carbon adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below+/- 10%.

ESF Ventilation System Annulus Ventilation Control Room Area Ventilation Aux. Bldg. Filtered Exhaust Containment Purge (non-ESF) (2 fans)

Fuel Bldg. Ventilation Penetration and System Bypass

< 1%

< 0.05%

< 1%

< 1%

< 1%

Flowrate 9000 cfm 6000 cfm 30,000 cfm 25,000 cfm 16,565 cfm

c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the carbon adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803-1989 at a temperature of~ 30°C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH Annulus Ventilation

< 4%

95%

Control Room Area Ventilation

< 0.95%

95%

Aux. Bldg. Filtered Exhaust (Note 1)

< 4%

95%

Containment Purge (non-ESF)

< 6%

95%

Fuel Bldg. Ventilation

< 4%

95%

Note 1:

The Auxiliary Building Filtered Exhaust System carbon adsorber samples shall be tested at a face velocity of 48 ft/min instead of the 40 ft/min specified in ASTM D3803-1989. 48 ft/min is the nominal limiting velocity the carbon adsorber may be exposed to under post accident conditions as a result of certain postulated failures. The results from this test shall then be corrected to a 2.27 inch bed in accordance with the guidance provided in ASTM D3803-1989 prior to comparing them to the Technical Specification criteria. 2.27 inches is the actual bed depth for the filter unit.

(continued)

Catawba Units 1 and 2 5.5-13 Amendment Nos. 280/276

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 5.5.12 Ventilation Filter Testing Program (VFTP) (continued)

d.

Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the carbon adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below+/- 10%.

ESF Ventilation System Annulus Ventilation Control Room Area Ventilation Aux. Bldg. Filtered Exhaust Containment Purge (non-ESF) (2 fans)

Fuel Bldg. Ventilation Delta P 8.0 in wg 8.0 in wg 8.0 in wg 8.0 in wg 8.0 in wg Flowrate 9000 cfm 6000 cfm 30,000 cfm 25,000 cfm 16,565 cfm

~

Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N610 1980.

ESF Ventilation System Annulus Ventilation Control Room Area Ventilation Aux. Bldg. Filtered E>Ehaust Containment Purge (non ESF)

Fuel Bldg. Ventilation VVattage @ 600,,ac 46 +/- e.7 klN 26 +/- 2.6 kW 40 +/-. 4.0 kW 120 +/- 12.0 klN 80 + 8/ 17.3 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures".

(continued)

Catawba Units 1 and 2 5.5-14 Amendment Nos. 280/276

Reporting Requirements 5.6 5.6 Reporting Requirements {continued}

5.6.6 Not used.

5.6.7 Ventilation S>1<stems Heater Report VVhen a report is required by LCO 3.6.10, "Annulus Ventilation System (AVS),"

LCO 3.7.10, "Control Room Area Ventilation System (CRAVS)," LCO 3.7.12, Au*iliary Building Filtered Ventilation Exhaust System (ABFVES)," LCO 3.7.13, "Fuel Handling Ventilation E*haust System (FHVES)," or LCO 3.Q.3, "Containment Penetrations," a report shall be submitted >.t.<ithin the f.ollowing 30 days. The report shall outline the reason for the inoperability and the planned actions to return the systems to OPERABLE status.

PAM Report When a report is required by LCO 3.3.3, "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Catawba Units 1 and 2 5.6-5 (continued)

Amendment Nos. 275/271

3.6 CONTAINMENT SYSTEMS 3.6.10 Annulus Ventilation System (AVS)

LCO 3.6.10 Two AVS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A.

One A VS train A.1 Restore A VS train to inoperable.

OPERABLE status.

AVS 3.6.10 COMPLETION TIME 7 days s..

One or fflore AVS 8:4 Restore,~VS train(s) Reater 7 days train(s* Reater to OPERABLE status.

inoperable.

GR

~ Initiate aetion in aeeordanee witR 7 days

~

Speeifioation a.6.6.

~

'f it, G.

Required Action and G.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

A~

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G.2 Be in MODE 5.

McGuire Units 1 and 2 3.6.10-1 Amendment Nos. 184/166

No changes. Included for information.

AVS 3.6.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.10.1 Operate each AVS train for~ 15 continuous minutes.

SR 3.6.10.2 Perform required AVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.6.10.3 Verify each AVS train actuates on an actual or simulated actuation signal.

SR 3.6.10.4 Verify each AVS filter cooling bypass valve can be opened.

SR 3.6.10.5 Verify each AVS train flow rate is~ 7200 cfm and ~ 8800 cfm.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program McGuire Units 1 and 2 3.6.10-2 Amendment Nos. 296/275

No changes. Included for CRAVS information.

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.

---

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

The 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 A.

One CRAVS train A.1 Restore CRAVS train to inoperable for reasons OPERABLE status.

other than Condition B.

B.

One or more CRAVS 8.1 trains inoperable due to Initiate action to implement inoperable CRE mitigating actions.

boundary in MODE 1,2,3, or 4.

AND 8.2 Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND 8.3 Restore CRE boundary to OPERABLE status.

C.

Required Action and C.1 Be in MODE 3.

associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4.

C.2 Be in MODE 5.

COMPLETION TIME 7 days*

Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours

( continued)

McGuire Units 1 and 2 3.7.9-1 Amendment No. 282/261

CONDITION D.

Required Action and associated Completion Time of Condition A not met in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

E.

Two CRAVS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

OR One or more CRAVS trans inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.

Two CRAVS trains inoperable in MODE 1, 2, 3, or 4 (for reasons other than Condition B).

McGuire Units 1 and 2 D.1 OR D.2.1 AND D.2.2.

E.1 AND E.2 F.1 No changes. Included for information.

CRAVS 3.7.9 REQUIRED ACTION COMPLETION TIME Place OPERABLE CRAVS Immediately train in emergency mode.

Suspend CORE Immediately ALTERATIONS.

Suspend movement of Immediately irradiated fuel assemblies.

Suspend CORE Immediately ALTERATIONS.

Suspend movement of Immediately irradiated fuel assemblies.

Enter LCO 3.0.3.

Immediately (continued) 3.7.9-2 Amendment Nos. 249/229

CONDITION One or more CR/\\\\lS tFain (s) heater inoperable.

REQUIRED ACTION

~ Restore CRAVS train(s) l=leater to OPeRABLE

~

G: Initiate aGtion iR aeeoraanee witl=l Speci#ioation a.e.e.

CRAVS 3.7.9 COMPLETION TIME

---

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

• 'A' Train CRAVS 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 1A' 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 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 as described in MNS L.AR submittal correspondence letter MNS-17-031.

McGuire Units 1 and 2 3.7.9-3 Amendment No. 308J287

No changes. Included for information.

CRAVS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3. 7.9.1 Operate each CRAVS train for~ 15 continuous minutes.

SR 3.7.9.2 Perform required CRAVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

SR 3.7.9.3 Verify each CRAVS train actuates on an actual or simulated actuation signal.

SR 3.7.9.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program McGuire Units 1 and 2 3.7.9-4 Amendment No. 296/275

No changes. Included for information only.

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.10 5.5.11 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

Ventilation Filter Testing Program {VFTP}

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975, with exceptions as noted in the UFSAR.

a.

Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 (N510-1980 for Auxiliary Building Filtered Exhaust) at the flowrate specified below+/- 10%.

(continued)

McGuire Units 1 and 2 5.5-9 Amendment No. 237/219