ML20151T941

Submits Markup of Draft SE W/Annotated Comments.Encl 2 of Ltr Provides Changes Necessary to ITS Submittal,As Amended to Resolve Open Items Identified within Draft SE & Items Identified by Util.Encl 4 Provides Final Proposed TS

ML20151T941
Person / Time
Site:	Catawba
Issue date:	09/08/1998
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20151T945	List: ML20151T941 ML20151T949
References
TAC-M95298, TAC-M95299, NUDOCS 9809100218
Download: ML20151T941 (100)

Text

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g Duks Enirgy Corporation ;J 526 South Church Street j -l' J "'

PO. Box 1006 (EC07H)

_ Charlotte, NC 28201-1006  ;

M. S. Tuckman I7 " l382'2200 " $1 Executive Vice hnident II#E 3#I 60 " -

Llear Generation .

1 September 8, 1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

Subject:

Duke Energy Corporation

( Catawba Nuclear Station Decket Numbers 50-413, and -414

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Improved Technical Specifications, Supplement 9 TAC Nos. M95298 and M95299 By letter dated August 11, 1998, the NRC transmitted the draft 7 Safety Evaluation (SE) for the conversion to Improved Technical =

Specifications. The letter requested comments on the draft SE and also requested that the licensee propose appropriate license conditions for the relocated material from the current technical specifications and for the scheduling of new more restrictive requirements. Finally, the letter requested a certified copy of the proposed Technical Specifications and Bases.

Enclosure 1 of this letter provides a markup of the draft SE with annotated comments. Enclosure 2 of this letter provides the changes necessary to the ITS submittal, as amended, to resolve open items identified within the draft SE and items identified by Duke Energy during the review. Enclosure 3 of this letter provides proposed license conditions to address the material proposed for relocation from the current technical specifications and to address the scheduling of new more restrictive surveillance requirements. These proposals are consistent with license conditions incorporated into other Facility Operating Licenses for recently approved technical specification conversions. Enclosure 4 provides the final proposed Technical Specifications and Bases.

The proposed changes are administrative in nature and have been determined to be within the scope of the original PORC and NSRB reviews.

Pursuant to 10 CFR 50.91(b)(1), a copy of this amendment has been provided to the appropriate State of South Carolina officials.

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Do,cvUd 9909100218 990908 ! '

PDR ADOCK 05000413g P PDR L.

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LU. S. Nuclear Regulatory Commission ,

September 8,J1998  ;

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If'any additional information is needed, please call Lee A.  ;

Keller at 704-382-5826.

Very truly yours, l l

.h ^

M. S. Tuckman l

Enclosure  !

xc: w/ enclosures  ;

l Mr. L. A. Reyes' i Administrator, Region II  !

U. S. Nuclear Regulatory Commission  !

Atlanta Federal Center 61.Forsyth St., SW, Suite 23T85

-Atlanta, GA 30303 Mr. P. S. Tam

.U. S. Nuclear Regulatory Commission Mail'Stop O-14 H25 Washington, DC: 20555 Mr. D. J. Roberts Senior Resident Inspector Catawba Nuclear Station Max Batavia, Chief i Bureau'of Radiological Health S. C. Department of' Health & Environmental Control 2600 Bull Street Columbia, SC 29207

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U. S. Nuclear Regulatory Commission September 8, 1998 Page 3 1

1 M. S. Tuckman, being duly sworn, states that he is Executive Vice President of Duke Energy Corporation; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission revisions to the Facilicy Operating Licenses of Catawba l Nuclear Station; and that all the statements and matters set forth herein are true and correct to the best of his knowledge.

M. S. Tuckman, Executive Vice President Subscribed and sworn to before me this N day of b i4xc/>Lt.,

1998 ' I th .

Notarh Public My Commission Expires:

SA d 2 2, 200l l

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! ENCLOSUREI i

CATAWBA NUCLEAR STATION COMMENTS ON THE ITS DRAFT SAFETY EVALUATION J

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l DRAFT SAFETY EVALUATION BY ThE OFFICE OF NUCLEAR REACTOR REGULATION B_El ATED TO AMENDMENT NO. TO FACILIT/ OPERATING LICENSE NPF-35 AND AMENDMENT NO. TO FACILITY OPERATING LICENSE NPF-52 CATAWBA NUCLEAR STATION. UNITS 1 AND 2 DUKE ENERGY CORPORATION. ET AL.

DOCKET NOS. 50-413 AND 50-414 AND AMENDMENT NO. TO FACILITY OPERATING LICENSE NPF-9 AND AMENDMENT NO. TO FACILITY OPERATING LICENSE NPF-17 MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DUKE ENERGY CORPORATIO DOCKET NOS. 50-369 AND 50-370 l

1. INTRODUCTION /)fg Catawba Nuclear Station (CNS), Units 1 and 2, and McGuire Nuclear Station (MNS) Units 1 and 2, have been operating with technical specifications (TS) issued with the origina perating i' licenses on January 17,1985, May 15,1986, June 12,1981, and March 3,1983 respectively, as amended from time to time. By separate letters for each facility datedtf0 M7,1997, as supolemer ted by separate letters dated March 9, March 20, April 20, @a?)6) June 3, June 24, July 7, uly 21, Duke Energy Corporation (DEC or the licensee) proposed to convert l

-I N the exi@ sting TS to the improved l'S. The improved TS are based upon NUR 1 PStandard Technical Specifications for Westinghouse Plants," Resisjon 1, dated April 1995, and

1. M upon guidance in the 'NRC Final Policy Statement on Technical Specification improvements for Sr/rA/yg 9uclear Power Reactors" (Final Policy Statement), published on July 22,1993 (58 FR 39132),

and 10 CFR 50.36, as amended July 19,1995 (60 FR 36953). The overall objective of the ffff .

proposed amendments, consistent with the Final Policy Statement, was to rewrite, reformat, and streamline the TS for CNS and MNS to be in accordance with 10 CFR 50.36, " Technical l Specifications."

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l Hereafter, the improved TS are the ITS, the existing or current TS are the CTS, and the improved standard TS, such as in NUREG-1431, are the STS. The corresponding TS Bases are the ITS Bases, CTS Bases, and STS Bases, respectively. For discussions applying to just i one of the two facilities, the acronyms ITS and CTS are preceded by CNS or MNS, as appropriate.

In addition to basing the ITS on the STS, the Commission's Final Policy Statement, and the requirements in 10 CFR 50.36, the licensee retained portions of the CTS as a basis for the ITS.

Plant-specific issues, including design features, requirements, and operating practices, were discussed with the licensee during a series of conference calls and meetings that concluded on July 10,1998, (the meeting summaries were issued on November 26,1997, and June 1, June 29, and July 13,1998)./ sed on these discu ions, the lic ce proposed tiers of a generi ature that we not in STS. The staff requ ed that the lic

{ gen c issues as a oposed change to S through e NRC/ Nuclear ergy Institu s ee submit ch M'hk T hnical Specifi tions Task Force TF). The generic issues re considered or specific applic ns in the CNS a NS ITS./ Consistent with the Final Policy Statement, the licensee proposed transferring some CTS requirements to licensee-controlled documents such as the Updated Final Safety Analysis Repor1(UFSAR) for the CNS and MNS, for which changes by licensees to the documents are controlled by a' regulation such as 10 CFR 50.59.

These licensee controlled-documents may be changed without prior staff approval, whereas NRC-controlled documents, such as the TS, may not be changed by the licensee without prior staff approval. In addition, human factors principles were emphasized to add clarity to the CTS requirements being retained in the ITS and to define more clearly the appropriate scope of the ITS. Further, significant changes were proposed to the CTS Bases to make each ITS requirement clearer and easier to understand.

SorMl)NS, The Commission's proposed actions on th CNS and MNS applications for amendments both .

dated May 27,1997, were published in the FederalRegisteron July 14,1997 (62 FR 37628) for l CNS, and on July 15,1997 (62 FR 37940 The staff's evaluation of these applications, including l l the supplements listed above, that resulted from NRC requests for additional information (RAls) and discussions with the licensee during the NRC staff review, is presented in this safety evaluation. The staff issued RAls dated January 16, January 30, March 27, April 15, April 28, May 14, May 22, and July 6f 1998. The plant-specific changes contained in these supplements l g serve to clarify the ITS with respect to the guidance in the Final Policy Statement and STS.

(CM'J i Therefore, these plant-specific changes are within the scope of the action described in the

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dhd Federa/ Register notices, except for the beyond scope changes that were the subject of l I July 7 separate notices. These notices were issued on May 6,1998 (63 FR 25106), May 20,1998 (63 g FR 27760), and July 13,1998 (63 FR 40553) for CNS, and on May 6,1998 (63 FR 25107), and also on May 6,1998 (63 FR 25108) in two separate notices, May 20,1998 (63 FR 27761), and July 29,1998 (63 FR 40554) for MNS.

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I i Following the initial May 27,1998, applications for operating license amendments to convert the CTS to the ITS for CNS and MNS, the NRC staff approved other amendments to the CNS and

, MNS operating licenses. These amendments, which DEC has incorporated as appropriate into ,

the ITS, are the following l

Catawba Nuclear Station, Units 1 and 2 i Date Amendment No.

l Issued Unit 1 Unit 2 Description 7/21/97 160 152 Revised TS requirements for the standby shutdown system.

These requirements are not retained in the ITS but are .

l l ' relocated to Chapter 16 of the FSA ~ lTabl e

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DisEU5516riToflC.hsiidf3%_

8/22/97 161 153 Char.ged licensee name from Duke Power Company to l Duke Energy Corporation in operating licenses.

10/9/97 162 -

Allowance to permit natural circulation testing in Mode 3 following steam generator replacement in 1996. Not retained in the Unit 1 ITS because this allowance has

! expired.

11/13/97 -

154 Deletion of steam generator tube repair criteria -

incorporated into Unit 2 ITS 5.5.9.

l 3/2/98 163 155 Revised references to COLR methodologies - incorporated into ITS 5.6.5.

4/23/98 164 156 Revised operating licenses to delete outdated license l conditions and exemptions, and to correct errors. l l 4/27/98 165 157 Revised qualifications of Safety Review Group (SRG). Not retained in the ITS - relocated to the Quality Assurance Topical Report; see Table LA, Discussion of Change 5.0 -

LA.3. i 6/17/98 166 158 Revision of surveillance requirements for pressurizer heaters to be consistent with current plant design - l incorporated into ITS 3.4.9. [hjfh l 7/9/98 167 159 Relaxed Applicability of control room area ventilation "MW actuation in trumentation function -incorporate 41ntn U (6 3 3,7J

ITS 3.3.7. us vise Bas or ITS 3.7 to discu ack l yo start rCRAVS" tside Mod ^ 1;2,3la 41 continued i

?  ?  ? Deletion of ASME pressure test of diesel generator fuel oil system - incorporated in ITS 3.8.3.

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4 Catawba Nuclear Station, Units 1 and 2 i

Date Amendment No.

i issued Unit 1 Unit 2 Description

?  ?  ? Revised TS reagirements for low temperature overpressure i protection (LTOP) - incorporated into j i ITS 3.4.3 and 3.4.12. l i

?  ?  ? Revised trip t ra point and allowable value for nuclear service water suc* ion transfer on low pit level - incorporated into ITS 3.3.2 and Taole 3.3.2-1.

? 7 7 Relaxed TS requirements for stored ice weight -

Incorporated into ITS 3.6.12.

l}h -+ k__ % $ C hente M freturnC V bor inspecfiens ofice cos6stser to McGuire Nuclear Station, Units 1 and 2 #"'##

'Mef A'/MWr15#//'ord CNS SIMfare ord heniQ peresa l pj Date issued Amendment No.

Unit 1 Unit 2 Descrintinn 11/25/97 177 159 Revised trip set point @rI eq c switchover to recirculatio -incorporated into ITS 3.3.2 and Table 3.3.2-1. Id5T/ eve /j 4/8/98 178 160 $rvisedreferences to COL 9Lrnetfwdelogics - incorporatedinto FIS 5.6.5. hnh 7/30/98 179 161 Revised CTS Figure 5.1-1 regarding location of the meteorological tower. Not retained in ITS - 55sLTibM1A:

DiiE6sij6n of CfiahdQ l 7 7 7 Added allowance for 72 cumulative hours of operation with elevated temperatures in the containment lower compartment - incorporated into ITS 3.6.1.5 7 7 7 Remove references to steam line low pressure safety injection function - incorporated into ITS 3.3.2 and Table -

3.3.2-1.

7 7 7 Revised the trip set points of the power range neutron flux high trip function in the event of inoperable main steam safety valves - incorporated into ITS 3.7.1. t 4 1  !

During its review, the NRC staff relied on the Final Policy Statement and the STS as guidance for acceptance of CTS changes. This SE provides a summary basis for the NRC staff conclusion that CNS and MNS can develop ITS based on STS, as modified by plant-specific changes, and that the use of the ITS is acceptable for continued operation. The NRC staff also  !

acknowledges that, as indicated in the Final Policy Statement, the conversion to ITS based on ]

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5 the STS is a voluntary process. Therefore, it is acceptable that the ITS differs from the STS, reflecting the current licensing bases for CNS and MNS. The NRC staff approves the licensee's changes to the CTS with meviificatinns documented in the supplemental submittals.

&e fember 4D in the letter ofMst XXJi998, the licensee proposed license conditions for the implementation of the ITS. Also, in this letter, the licensee submitted revised ITS pages. The i license conditions and revised ITS pages do not change the notices in the Federal Rooister on July 14,1997 (62 FR 37628) and July 15,1997 (62 FR 37940), for the conversion from the CTS to the ITS for CNS and MNS, respectively. In addition to these notices, there were three notices for CNS and six notices for MNS in the Federal Reoister for the beyond scope issues associated with the conversion, a 3 listed previously, that are discussed in Section Ill.G of this safety evaluation (SE).

For the reasons stated Infra in this SE, the NRC staff finds that the CNS ITS and MNS ITS issued with these license amendments comply with Section 182a of the Atomic Energy Act, 10 CFR 50.36, and the guidance in the Final Policy Statement, and that they are in accord with the common defense and security and provide adequate protection of the health and safety of the public.

11. BACKGROUND Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating licenses will state:

[S]uch technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, doom necessary in order to enable it to find that the utilization . . . of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public. Such technical specifications shall be a part of any license issued.

In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." Statement of Consideration, " Technical Specifications for Facility Licenses; Safety Analysis Reports,"

33 FR 18610 (December 17,1968). Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.

Catawba and McGuire Draft Safety Evaluation

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g gff yh/ fib comments were document as request. r additional information (RAls) and forwarded in letters dated January 16, anuary 50 arch 27, April 15, April 28, May 14, May 22, and July 6, l 1998. The licensee prov' ed res ses in letters dated March 9, March 20, April 20, June 3, 1 June 24, July 7, July 21, an 1998. The letters clarified and revised the licensee basis for l translating the CTS requirements into ITS. The NRC staff finds that the licensee's submittals including responses to RAls provida suffic;eni detail to allow the staff to reach a conclusion regarding the adequacy of the licensee's proposed changes to the CTS. l The license amendment application was organized such that changes were included in each of the following CTS change categories, as appropriate:

• Administrative Changes, (A), i.e., non-technical changes in the presentation of CTS requiremert; ,

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• Technical Changes - More Restrictive, (M), i.e., new or additional CTS requirements; l l

• Technical Changes - Less Restrictive (specific), (L), i.e., changes, deletions and relaxations of CTS requirements; l

• Technical Changes - Less Restrictive (generic), (LA), i.e., deletion of CTS requirements by movement of information and requirements from existing specifications (that are otherwise being retained) to licensee-controlled documents, including the ITS Bases; and

• Relocated Specifications, (R), i.e., relaxations in which whole specifications (the LCO and associated action and surveillance requirements) are removed from the CTS (an NRC-controlled document) and placed in licensee-controlled documents.

These general categories of changes to the licensee's CTS requirements and STS differences i may be better understood as follows:

A. Administrative Changes l Administrative (non-tcchnical) changes are intended to incorporate human factors principles into the form and structure of the ITS so that plant operations personnel can use them more easily. These changes are editorialin nature or involve the reorganization or reformatting of CTS requirements without affecting technical content or operational restrictions. Every section of the ITS reflects this type of change. In order to ensure consistency, the NRC staff and the licensee have used the STS as guidance to reformat and make other administrative changes. l Among the changes proposed by the licensee and found acceptable by the NRC staff are:

(1) providing the appropriate numbers, etc., for STS bracketed information (information that must be supplied on a plant-specific basis and that may change from plant to plant);

. (2) identifying plant-specific wording for system names, etc.;

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-10 advancements and operating experience, or (3) resolution of the Owners Groups comments on the STS. The NRC staff reviewed generic relaxations contained in the STS and found them acceptable because they are consistent with current licensing practices and the Commission's regulations. The CNS and MNS designs were also reviewed to determine if the specific design bases and licensing bases for CNS and MNS are consistent with the technical basis for the model requirements in the STS, and thus provide a basis for the ITS.

A significant number of changes to the CTS involved changes, deletions and relaxations to portions of the CTS requirements evaluated in Categories I through Vill as follows:

l Category i Relaxation of Applicability 1 Category 11 Relaxation of Surveillance Frequency l

Category 111 Relaxation of Completion Time Category IV Relaxation of Required Actions Category V Relaxation of Surveillance Requirement Category VI Relaxation of LCOs and Administrative Controls Category Vil Deletion of Surveillance Requirements Category Vlil Deleti n of Requirements Redundant to Regulation j The following discussions address why various Specifications within each of these eight categories of information or specific requirements are not required to be included in ITS.

Relaxation of Applicability (Category l}

CNS and MNS CTS typically specify the Applicability of the requirements associated with a limiting condition for operation (LCO) in terms of reactor operational conditions, using the CTS-defined term Operational Mode, or Mode. This definition includes Mode 1 - Power Operation, Mode 2 - Startup, Mode 3 - Hot Standby, Mode 4 - Hot Shutdown, Mode 5 - Cold Shutdown, and Mode 6 - Refueling. These six Modes are defined by inclusive combinations of reactor core reactivity, power level, and average coolant temperature. CTS Applicability statements typically specify meeting the LCO requirements during one or more of these Modes; some specify all six Modes; others specify "at all times." CTS Applicabilities may also specify other plant conditions or operations such as whenever irradiated fuelis in the storage pool, during storage of fuel in the spent fuel pool, during Core Alterations, and during movement of irradiated fuel assemblies. In some cases, the CTS contain footnotes to limit the scope of a Mode of Applicability to more closely match the conditions during which the LCO is needed to

! support the plant safety analysis. Consistent with the STS, the ITS retain the intent of this approach which is to specify Applicabilities that are consistent with the application of the plant safety analysis assumptions for operability of the required features. For a Catawba and McGuire Draf t Safety Evaluation I

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1 experience, industry practice, industry standards, or manuf acturers' recommendations have shown that components usually pass the SR when performed at the specified  !

interval. In such cases, therefore, relaxed SR Frequencies are acceptable because they l do not reduce, but can increase system reliability.

l The ITS relax some CTS SR Frequencies by eliminating the requirement to perform the I surveillance "on a Staggered Test Basis." Consistent with the STS, the ITS omits CTS staggered (alternating) test requirements that have been shown by operating experience to con:ribute little to safety. This is beneficial because staggered testing imposes  !

additional constraints on plant operation, scheduling, and manpower, and may also increase the time safety systems are unavailable from testing. Typically, the ITS, l consistent with the STS, only specifies staggered testing for certain systems or components where this method is mJst practical or where it contributes to safety.

Therefore, the elimination of stagerettesting requirements, consistent with the guidance of the STS, is acceptable.

onh; The ITS also relax CTS SR Frequencies by adding specific exceptions, consistent with the STS, in the form of a SR note or an addition to the Frequency itself to allow performing the surveillance at an optimum time or plant condition. Such an exception might allow entry into a specified Mode or condition in the Applicability of the associated LCO prior to performing the surveillance. Exceptions are also specified to allow delay in the performance of certain SRs for ac and de sources during shutdown conditons when such performance would result in less than the minimum Operable LCO-required electrical power sources. Such exceptions are acceptable because the affected features ,

usually pass the surveillance and the delay in pedormance is expected to be of short l duration. These exceptions ensure the surveillances are performed at the correct time or plant condition to provide the desired verification of system Operability or protective limit. Therefore, the addition of these exceptions, consistent with the guidance of the STS, is acceptable.

The ITS may also base CTS SR Frequency relaxations on staff-approved topical )

reports. The NRC staff has accepted topical report analyses that bound the plant- i specific design and component reliability assumptions.

SR Frequency relaxations in the ITS typically remove unnecessary burdens on plant operation from testing but ensure adequate verification that the associated LCO requirements are being met. Therefore,less restrictive changes falling within Category 11 are acceptable.

Relaxation of Comoletion Time (Category lil) i l

Upon discovery of a condition in which an LCO is not met, the CTS require performing l the applicable specified action requirements. These specified action requirements, or Required Actions as they are called in the ITS and STS, are remedial measures that must be completed within specified time limits. In the ITS and STS, these time limits are formally called Completion Times. Completion Times define limits during which  ;

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CTS contain requirements that are redundant to regulations in 10 CFR. For example, l

many CTS reporting requirements are also required by 10 CFR 50.72 and 10 CFR 50.73. The CTS include requirements to submit Special Reports when specified limits, LCOs, or action requirements are not met. However, the ITS, consistent with the STS, omits many of the CTS reporting requirements because the reporting requirements in the regulations cited are acceptable and do not need repeating in the TS to ensure timely submission to the NRC. In addition, these redundant CTS reporting requirements are administrative in nature and do not affect plant safety. Therefore, this type of change has no impact on the safe operation of the plant. Deletion of these requirements is beneficial because it reduces the administrative burden on the plant and fosters a better focus on operational matters important to safety. Therefore, less restrictive changes falling under Category Vlli are acceptable.

Table L - Less Ree rictive Changes lists the less restrictive changes to the CTS in converting to the ITS. Table s organized in ITS order by each L-type DOC to the CTS, and provides a j summary descrip ion of each less restrictive change that was made, the CTS and ITS references, and a reference to the applicable change categories as discussed above (if applicable). For ease of reference, the eight less restrictive change categories are listed at the bottom of each page of Table L.

Additionally, in electing to adopt the specifications of the STS, the licensee also proposed a number of less restrictive changes to the CTS which do not apply to the above categories of changes, deletions, and relaxations of CTS requirements. These changes are characterized as unique in Table L and are evaluated below. The evaluations for each section are preceded by the ITS section and each evaluation is labeled with the DOC identifier (e.g., L.1) associated with the change. Most of these changes to the CTS were consistent with the STS and/or the current licensing basis and, therefore, were not beyond the scope of the ITS conversion. Those unique changes that were beyon.d the scopa of the conversion are addressed in Section Ill.G of this safety evaluation.

ITS Section 3.2, Power Distribution Limits L.5 CTS 4.2.1.1.a.2 requires monitoring AFD once per hour for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after restoring the AFD alarm to operable status. CTS 4.2.1.1.b requires monitoring once per hour for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 30 minutes thereafter when the alarm is inoperable. These requirements are a carryover from the previous methodology (constant axial offset) and are not necessW for the current methodology (relaxed axial offset control) for AFD and are thus deleted. Logging of AFD was previously required to establish penalty minutes for being outside of constant target bands. Target bands are not associated with the relaxed axial offset control schemes. ITS SR 3.2.3.1 requires monitoring once within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per hour thereafter when the alarm is inoperable. There is no basis for providing increased monitoring after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of alarm inoperability and the requirement adds an unnecessary administrative burden to the operating staff. A failure of the alarm to function does not affect the ability of the operator to routinely monitor control board i

indication of AFD as part of the normal operating practice, nor does the alarm failure

! itself cause AFD to not be within limits. For these reasons, these changes are acceptable.

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For a system to be considered Operable, the definition of Operability as it pertains to the l system must be satisfied. In addition,it'e specified SRs associated with the LCO l governing the system must be met. Some CTS LCOs contain information concerning design and configuration implying that they rela'e to meeting the Operability requirements of the LCO. Such information is usually incomplete and is actually redundant to the definition of Operability and the associated SRs. Because the l

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retained in the improved TS, and adequate TS or regulatory controls exist for any changes to the removed information, moving such information to licensee-controlled documents has no impact on the effectiveness of the ITS to ensure safe operation of the plant.

Limits such as the cycle-specific core design limits, are moved from the CTS to other documents. The cycle-specific core design limits are moved to the Core Operating Limits Report (COLR) in accordance with Generic Letter (GL) 88-16. Removal of these limits is acceptable because ITS administrative controls include adequate programmatic requirements to control limits removed from the CTS to such documents as the COLR.

Relocation of details of system design from the CTS is consistent with the content, j format, and presentation of information in the STS. In addition, existing regulations and  !

TS administrt ' :ontrols will ensure an effective level of regulatory control of this information ano ..,1 provide a more appropriate change control process. Therefore, changes falling within Type 1 are acceptable.

Descriptions of System Operation (Type 2)

The plans for the normal and emergency operation of the facility are required to be described in the UFSAR by 10 CFR 50.34. ITS 5.4.1.a requires written procedures to be established, implemented, and maintained for plant operating procedures including procedures recommended in RG 1.33, Revision 2, Appendix A, February 1978.

Controls specified in 10 CFR 50.59 apply to changes in procedures as described in the UFSAR. The ITS Bases also contain descriptions of system operation. ITS 5.5.14, sases Contro(Twgram, speafies contwlsfor cha 'ng the FTS Bases. It is autytable to remoze details and ~1 descriptions ofsystem operati~from ecause this type ofinformation utK6e adequately controlTelin z ~/

the ilFSMR plant operatingprocedures, nd . es, as appropriate. 9fierefore, changesfamng within

' Type 2 are acceptable. g TroceduralDetai&for Meetina'n s ucments(Type 3)

Detailsforperforming CTS action andsurvei8ance requirements, maintaining andcontrolTing CTS administratize requirements, andstatements providing clanfication ofCTS requirements are more appropriately /

speafielin the tlFs9x qq plan, SelectedLicensee Commitments Manual (SLC), or 175 Bases as appropriate. \

Changes to the informationgoverned6y one of these documents requires an evaluation in accordance utth 10 CFR50.54,10 CFR50.59, or PTS 5.5.14, Tases Contro(Trogram.

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% controlof thepfant conditions appropriate toperfonn a surveinana test is typicaEy an issueforprocedures ,

andschduling (e.xcept u6ere a Mde or condition speafiedin the ApplicabiGty of the Lc0 mustfirst be j enteredin order to perform the suntiEance). % indusion ofroutine proudurafguidana fias previously 6an detenninedto be unnecessary as a TS restriction. As indicatedin Generic Letter 91-04, aEcuing t!xisprocedural  ;

controfis consistent with the tust inajority ofotherSRs that do not dictate speaficplant conditionsfor su.itidances. In addition, Gsts or tables containing 73 relatedinfonnation or data hatt also picViously been \

detenninedto be unnecessary as a TS restriction. Gerwric Letter 93-OSspeaficady approttdthe removalfrom l the 73 of the surttilance acceptance criteria in the instrutnent response time tables. The m extends the a80uunce providelin Generic Letter 93-08 to include the remottilofmost tables and[ists ofinfortnation pertaining to sunei8ances or LCOsfrom tfw 73. Similarly, prescriptite procedura(information in action requirements are unnecessary as a TS restriction. The inclusion ofspeaficprocdurafdetailin action requirernents is unlikc[y to contain aEtheprocedura[ considerations necessaryfor theplant operators to complete the actions required andreferralto plant procedures is therefore requiredin any ettnt. 7he 013 also contain inanygenera[ statements intenddto eqfain or danfy the in tent of requirements in LCOs, action statements, andsavei8ances. 7he m Wases documentprovides a more appropriate locationfor these types of ,/

infonnationa[ statements. \ SD '

CTS also contain proceduraldetailsfor meeting CTS administrative controls such as requirementsfor the Nudear Safety Retiew scard(NJRP). % CTS speafy such details as thefunction, composition, afternatives, consultants, meetingfrequency, quorum, retnew, audits, andrecords of the NSKR %se details of tfie NSRB activities can be adequately addressedin the QA T(an documentation a.ufdo not nedio be indudedin the M.

Changes to the QA Tlan must be erufuatedin accordance with theguidance in 10 CSR50.54; thus adequate regulatory controlis ensured. In addition to the QA T[an, othersimilarprocduraldetailsfor meeting CTS administratist centrols are mattito the tlFSnorSLc uhich are dequately controEedby the provisions of 10CFR50.59.

other changes inw(ving tfie remozulofprocduraldetails include ifiose details remostdfrom the CTS u4ich are associatedwith limits retaindin the ITS. For exampfe, the iTS requirement maysimply refer to programmatic requirements such as the Ventilation FilterTesting Trogram (VTIT), induddin m 5.5.11, unich speafics the limits andtest requirements containedin the VTIT. % 1TS VT1Tpr rides &cquateprogrammatic controlof ,

the associatdprocdura[ details remottsfrom the CTS. Changes to ..

ust 6e appro edby the NRC.

/TS 5.S. q//

%se changes are consistent with the content,fonnat, arufpresentation ofinfonn existing regulations and73 dministratire controfs udensure an effectize (ete(of regulatory controlof this infonnation adudprovide a more appropriate change controlprocess. Grefore, changesfa((ing within Type 3 are auertable.

Table LA lists the requirements and detailed information in the CTS that are relocated to licensee-controlled documents and not retained in the ITS. Table LA is organized in ITS order by each LA-type DOC to the CTS. It includes: the ITS section designation followed by the DOC identifier; e.g.,3.3 followed by LA.1 means ITS Section 3.3, DOC LA.1; CTS reference; a summary description of the relocated details (summary of change); the name of the document to contain the relocated details or requirements (destination document); the method for controlling future changes to relocated requirements (control process); and a reference to the l specific change type, as discussed above, for not including the information or specific requhements in the ITS, l

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The licensee, in electing to implement the specifications of the STS, also proposed, in i accordance with the criteria in the Final Policy Statement and 10 CFR S0.36, to entirely remove l certain spec.'fications from the CTS and place them in licensee-controlled documents noted in Table R of relocated current technical specifications. Table R lists all specifications that are relocated from the CTS based on the Final Policy Statement and 10 CFR 50.36, to licensee-controlled documents. Table R is organized by each R-type DOC to the CTS, in a manner consistent with the organization of requirements in the ITS, followed by a reference to the associated relocated CTS specification; a summary description of the relocated CTS specification; the name of the document that will contain the relocated specification (destination document); and the method for controlling future changes to the relocated specification (control process). The NRC staff's evaluation of each relocated specification presented in Table R is provided below with the corresponding DOC identifier given in parenthesis after the title of each relocated specification.

1. 3/4.1.2.1 Minimum Boron iniection Flow Paths. Modes 5 and 6 (3.1 - R.1) 3/4.1.2.2 Minimum Boron Injection Flow Paths. Modes 1. 2. 3. and 4 (3.1 - R.2) 3/4.1.2.3 Charaina Pump in Boron Injection Flow Path. Modes 5 and 6 (3.1 - R.3) 3/4.1.2.4 Charaina Pumps. Modes 1. 2. 3. and 4 (3.1 - R.4) 3/4.1.2.5 Borated Water Cources. Modes 5 and 6 (3.1 - R.5) 3/4.1.2.6 Borated Water Sources. Modes 1. 2. 3. and 4 (3.1 - R.6)

CTS 3/4.1.2 snecifies requirements for boration flow paths borated water sources JAetyeS 34rtd3tCis,1.2.e speos,or reouirements for ooraiejsater sources) The i

. boration subsystem of the chemical and volume control system (Uvus) provides the F##Y m de honf//En l chemical means to meetabsorber neutron one of the functional (boron) requirements concentration of the in the reactor CVCS, coolant i.e.,

system to control the (RCS)

'/4Y4 fb and to help maintain the shutdown margin. To accomplish this functional requirement, the CTS require a source of borated water, one or more flow paths to inject this borated water into the RCS, and appropriate charging pumps to provide the necessary charging head. -

'broutCMY/h response)

The boration subsystem is not assumed to be operable to mitigate t consequencesvi j a design basis accident (DBA) or transient. In the case of a malfunction of theSCVCj that causes a boron dilution event, the operator must take actiorFclose tne l appropriate valves in the reactor makeup system before the shutdown margin is lost. -

Operation of the t, oration subsystem is not assumed to mitigate this event. In addition, the boration subsystern is not used for, nor is capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA. It also is not used to monitor a process variable, or the status of any design feature, or operating restriction that is an initial condition of a DBA or transient. The boration subsystem is not part of a primary success path in the mitigation of a DBA or transient. Therefore, CTS 3/4.1.2.1 through 3/4.1.2.6 do not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the Selected Licensee Commitments (SLC) Manual (UFSAR Chapter 16).

Note that CTS 4.1.2.4.2 is retained as ITS LCO 3.4.12 for low temperature over

! pressure protection requirements. Any changes to these former requirements regarding Catawba 9rd ?/,cGuire Draf t Safety Evaluation

l QQ , JCS 3.7.loW NC&M/

Irradiated fuel assembli s within the fuel building so that an automatic actuation is not l necessary. ITS 3.7.13 also requires a suspension of fuel handling activities, should the f i system become inoperable. Based on this, the fuel storage pool high gaseous radioactivity monitor does not provide an actuation function that is credited to mitigate a fuel handling accident.

The fuel storage pool criticality radiation monitor (EMF-15) for Catawba monitors  ;

1 radioactivity in the fuel storage pool area. This monitor does not provide any mitigation of a DBA. The monitor does, however, prevent the new fuel elevator from raising spent fuel assemblies. It may also function as a criticality monitor upon detection of high  !

radiation. These functions do not contribute to DBA analysis assumptions.

The criticality radiation monitor (EMF-17 for Unit 1 and EMF-4 for Unit 2) for McGuire monitors radioactivity in the fuel storage pool area. This monitor does not provide any l

mitigation of a DBA. It is provided as a criticality monitor, and it does sound the

@merg.e6ppef@ alarm upon detection of high radiation. f i ON

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ceMS) proviaed to The control room air inta gawvus radiation monitors (EMF-43A,43B) identify increasing level of radioactivity in the control room intakes. The control room area ventilation syste perates continuously in a filtered mode.Qdoes not rely on these monitors to perform any actuation function to mitigate T he C &9t the efteds of a The auxiliary building ventilation gaseoun radioactivity monitor (EMF-41) for Catawba is provided to monitor the auxiliary building ventilation system for increasing levels of radiation. These monitors will realign the ventilation system to filtered operation on high  !

levels of radioactivity. Although these monitors perform an automatic actuation function, this is a design feature of the system and is not credited in the licensing basis of the plant forfinyA7BA) The safety function for the ventilation system is to filter the ECCS j LO pu ms following a loss of coolant accident (LOCA) Filtered operation is automatically accomplished by the safety injection signal. But no credit is taken for radiation monitor operation during a LOCA. This raonitor only provides indication of effluent releases.

The component cooling water system radiation monitors (EMF-46A,46B) for Catawba are provided to identify leaks of contaminated water into the component cooling system.

These monitors provide no control or actuation function and serve only to alert operators to isolate a leaking heat exchanger. No credit is taken for radiation monitcr operation to mitigate or identify a DBA.

Therefore, CTS 3/4.3.3.1 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding these radiation monitors, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

4. 3/4.3.3.2 Movable incore Detection System (3.3 - R.1)

Draf t Safety Evaluation Catawba and Mc.2uire

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in a ready state for mitigative action, this requirement is directed more toward prevention I of degradation and continued long term maintenance of acceptable structural conditions.

l The inservice inspection (ISI) program is also required by 10 CFR 50.55(a). These controls ensure that any changes to these requirements are appropriately reviewed.

Hence, it is not necessary to retain a separate requirement to ensure immediate Operability of safety systems. Furthermore, this CTS requirement prescribes inspections to be conducted during plant shutdown, and is not directly important for responding to a DBA. Therefore, CTS 3/4.4.10 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual, with the exception of the RCP flywheelins ction surveillance. The RCP flywheelinspection requirement has been retained as IT Any changes to these former requirements f regarding the structuralintegrity of ASM de class 1,2, and 3 components, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59.

Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

11. 3/4.4.11 RCS Vent Paths Operable and Closed for Reactor Vessel Head and Pressurizer Steam Space (CNS) 3/4.4.11 Reactor Vessel Head Vent Paths Operable and Closed (MNS)

(3.4 - R.5) l The reactor vessel head vents are provided to exhaust noncondensible gases and steam from the RCS which could inhibit natural circulation core cooling following any event involving a loss of offsite power and requiring long term cooling, such as a LOCA.

The function, capabilities, and testing requirements are consistent with the requirements )

of item II.B.1 of NUREG-0737," Clarification of TMl Action Plan Requirements,"

however, the operation of these vents is an operator action af ter the event has occurred and is only required when there is indication that natural circulation is not occurring. l Therefore, CTS 3/4.4.11 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former rcquirements regarding the reactor coolant system vents, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR l 50.59, sufficient regulatory controls exist to ensure continued protection of the public  !

health and safety.

12. 3/4.6.5.2 Ice Bed Temperature Monitorino System (3.6 - R.1)

The ice bed temperature monitoring system monitors the temperature of the ice bed to ensure that the ice bed temperature does not increase above the required limits undetected. However, it is not required in the ITS to ensure the ice bed temperature is maintained within limits. ITS 3.6.12, " Ice Bed," will continue to ensure that temperature is maintained within the required limits. Therefore, CTS 3/4.6.5.2 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the ice bed temperature monitoring system, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

Catawba and McGuire Draft Safety Evaluation

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13. 3/4.6.5.4 Ice Condenser Inlet Door Position Monitorino System (3.6 - R.2) k s st$in The inlet door position monitoring system monitors the position of the ice bed inte oors during normal operation to ensure that the ice bed inlet doors do not open (which could allow the ice bed temperature to increase above the required limits). However s not required in the ITS to ensure the inlet doors remain closed and ice bed temperature is

}

maintained within limits. ITS 3.6.12, " Ice Bed," will continue to ensure that the inlet doors remain closed and temperature is maintained within the required limits.

Therefore, CTS 3/4.6.5.4 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the Inlet door position monitoring system, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

14. 3/4.7.2 Steam Generator Pressure / Temperature Limitations (3.7 - R.1)

CTS 3/4.7.2, " Steam Generator Pressure / Temperature Limitations,' specifies limits on steam generator (SG) pressures and temperatures to ensure that pressure induced stresses on the SG do not exceed the maximum allowable fracture toughness limits.

These pressure and temperature limits are based on maintaining a SG reference transition nil ductility temperature (RTNDT) sufficient to prevent brittle fracture. These limits, however, are not initial condition assumptions of a DBA or transient, but represent operating restrictions which are not included in 10 CFR 50.36. Therefore, CTS 3/4.7.2 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the SG pressures and temperatures, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficiert regulatory controls exist to ensure continued protection of the public health and safety.

15. 3/4.7.8 Snubbers (3.7 - R.5)

Snubbers support the operability of primary components whose operation or function may be an assumption of a safety analysis. However, snubbers are not considered to be part of the primary success path. Their purpose is to prevent unrestrained pipe motion under dynamic loads while also allowing normal thermal expansion of piping and nozzles to eliminate excessive thermal stresses during heatup and cooldown. The requirements for snubber inspection are also contained in 10 CFR 50.55a and do not need to be repeated in the ITS. Snubber details are defined in ISI program. Changes to the ISI program are adequately controlled by 10 CFR 50.55a. Therefore, CTS 3/4.7.8 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the snubbers and associated surveillances, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

16. 3/4.7.9 Scaled Source Contamination Limits (3.7 - R.3)

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29-CTS 3/4.7.9, " Sealed Source Contamination," pros ides limitations on sealed source l contamination to ensure the total body and individ Jal organ irradiation doses do not j exceed allowable limits in the event of ingestion os inhalation. This requirement is not '

necessary to ensure safe reactor operation. Therefore, CTS 3/4.7.9 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the sealed source  !

I contamination and surveillances, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety. l l

17, 3/4.7.12 Ground Water Level near Reactor and Auxiliary Buildinas (CNS) l 3/4.7.13 Ground Water Level near Auxiliary Buildina (MNS) '

(3.7 - R.4) )

Groundwater level limits are required to be maintained at or below the top of the )

87.Q4 .

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• adjacent floor slabs of the reactor containment building and the auxiliary building to preclude movement of the building from the floating effect of groundwater. These limits, i

however, are not necessary to ensure safe reactor operation;bec555QTicejectT@

sb ag Qu jpegsy Therefore, the ground water level requirements in CTS 3/4.7.12 for CNS t -

I I FNb tnd C1 s 3/4.7.13 for MNS do not meet any of the criteria in 10 CFR 50.36 and may be l M4f A45 no removed from the CTS and relocated to the SLC Manual. Any changes to these former

/5unc/'s/c requirements regarding thyroundwater levellimits, as relocated to the SLC Manual, I d Nect o/; will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health Nb . and safety.

}fftl/On 18. 3/4.7.12 Area Temperature Monitorina (MNS) (3.7 - R.2) j l

CTS 3/4.7.12 requires area temperature monitoring to indicate that safety-related equipment in various areas of the plant is not being subjected to conditions beyond the i defined environmental qualification envelope. This information, however, does not serve '

any primary safety function. Therefore, CTS 3/4.7.12 does not meet any of the criteria  !

in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. I Any changes to these former requirements regarding the area temperature monitoring and surveillances, as relocated to the SLCWlanual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

19. 3/4.7.13 Standby Shutdown System (CNS) (3.7 - R.6)

CI53/4.7.13 identifies dieselgenerators, ma&uppumps, andbatteries as standby shutdown system \

g equipment which is used to ensure that a fire requiring evacuation of the control room J will not preclude achieving safe shutdown. This equipment is independent of areas y/

where fire could damage those systems normally used to shutdown the reactor. 'Ihis system is creditedin certain beyonddesyn basis [oss offunction sanarios (eg, foss ofsertice unter or component cooling unter) to minimize core damagefrequency andoffsite releases. Andthis system is subject to \

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. 50 the regulations associatedwith the snaintenance rule andfireprotection. 'lhese regulations ensure adequate regulatorycontro[ozertheazuifabilityofthisequipnentforstandbyshutdown. However, this system is not used to detect a degradation of the reactor coolant pressure boundary, nor is it asst ned to mitigate a DBA or transient event. Thus, the standby shutdown requirements for this equipment are not necessary to ensure safe reactor operation.

Therefore, CTS 3/4.7.13 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to those former requirements regarding the standby shutdown system equipment, as relocated to the SLC Manual will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59 and the other regulatory requirements cited, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

20. 3/4.8.4 Containment Penetration Conductor Overcurrent Protection Devices fdh*/' Se ffo/YS lrc f The primary function of th containment penetration conductor overcurren rotection devices is to open appropriate control and power circuits whenever the oad conditions f exceed the present(cyrset1t depdhES) Doing so will protect the circuit conductors in the j containment penetrations from overcurrent heating effects that could cause damage or failure of the conductors and the penetration. The continuous monitoring of the operating status of the overcurrent protection devices, however, is not practicable and is not a part of normal control room monitoring, except after breaker trip condition indications, in the event an overcurrent protective device fails to trip the circuit, the design includes an upstream protective device that will operate to isolate the faulty ,

circuit. Thus, the protective devices that provide coordination against losing the '

redundant power source are at a much higher level in the power system. This backup device ensures, that in the event of a single failure loss of the primary device, there is still a device to protect the penetration. In the worst case fault condition, a single division of protective functions can be lost, withouts 5EisEI3gitRicapability to adequately <

f respond to a DBA event. Therefore, CTS 3/4.8.4 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the containment penetration conductor overcurrent protective devices, as relocated to the SLC Manual, will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59, sufficient regulatory controls exist to ensure continued protection of the public health and safety.

21. 3/4.9.5 Communications Between Control Room and Refuelino Station (3.9 - R.1)

CTS 3/4.9.5, " Communications" ensures that refueling station personnel can be promptly informed of significant changes in facility status or core reactivity conditions during Core Alterations. Communications allow for coordination of activities that require interaction between the control room and containment personnel. However, the refueling system design accident or transient response does not take credit for communications. Therefore, CTS 3/4.9.5 does not meet any of the criteria in 10 CFR 50.36 and may be removed from the CTS and relocated to the SLC Manual. Any changes to these former requirements regarding the requirements for communications Catawba and McGuire Draf t Safety Evaluation

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removed provisions to ensure that an appropriate level of control has been achieved. The NRC staff has concluded that, in accordance with the Commission's Final Policy Statement, sufficient regulatory controls exist under the regulations, particularly 10 CFR 50.59. Accordingly, these specifications, information, and requirements, as described in detail in this SE, may be relocated from the CTS and placed in the identi 'ed. license ~nntroHed domnants nn nn n the licensee's letter dated May 27,19 v=., sag /erM/hd // /c//US dM i Mef% 9JetcA Mo Rfd%wuc sJun .2f hfy 7,4/yaf,4pjn&ag Sepfgfy&}q

t. control of specifications, HequireTTientST8Md1nformmion HelocaleG from Ine UId '

j in the ITS conversion, the licensee will be relocating specifications, requirements, and detailed information from the CTS to licensee-controlled documents outside the CTS. This is discussed L

in Section Ill.D and Ill.E above. The facility and procedures described in the UFSAR and SLC l Manual, incorporated into the UFSAR by reference, can only be revised in accordance with the l provisions of 10 CFR 50.59, which ensures records are maintained and establishes appropriate control over requirements removed from the CTS and over future changes to the requirements.

Other licensee-controlled documents contain provisions for king changcs consistent w other applicable regulatory requirements; for example, th OOA c.n t,e changed in c' C [

accordance with ITS 5.5.1, the emergency plan implementing procedures (EPIPs) can be changed in accordance with 10 CFR 50.54(q); and the administrative instructions that I l implemert the QA plan can be changed in accordance with 10 CFR 50.54(a) and 10 CFR Part l

l 50, Appendix B. Temporary procedure changes are also controlled by 10 CFR 50.54(a). The i documentation of these changes will be maintained by the licensee in accordance with the l l record retention requirements specified in the licensee's OA plans for CNS and MNS and such 1 applicable regulations as 10 CFR 50.59. l

, The license condition for the relocation of requirements from the CTS in Section V of this SE will address the implementation of the ITS conversion, and when the licensee stated that the relocation of the CTS requirements into licensee-controlled documents will be completed. The relocations to the UFSAR and SLC Manual may be included in the next required update of these documents in accordance with 10 CFR 50.71(e).

! G. Evaluation of Other TS Changes included in the Application for Conversion to ITS l

l This section addresses the beyond scope issues in which the licensee proposed changes to the CTS that differ from the corresponding requirements in the STS. The staff has provided -

, notices of consideration for these beyond scope issues in the Federal Register; however, some l of the notices issued for the proposed amendments were provided for changes to the CTS that are now not considered beyond scope issues in that they are now not considered both a change to the CTS and a deviation from the STS. The changes discussed below are listed in the order of the applicable ITS Sections and requirements. Each evaluation is annotated with the associated discussion of change (DOC) number as appropriate.

~~ 1. Steam Generator Water fnefImLew '1 efetion of' lime Constant Teauirement from Channe[ Calibration CNS Unit 1 C53/43.1, ' Table 43-1 Functionaf Unit 12, ' Table Notation 13 Ol' f CNS Unit 1 1533.1, 'Ta6(e 33.1-1, Function 13, R33.1.10

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l CMS 33-AfA '1he CS Channe[CcG6 ration surtti8ance requirementfor the CNS Unit 1 steamgenerator unter fett((ow-fow instrumentationfunction sp=tfies setting thefi[ter time constant to a sulue s'1.5 seconds.

'1his criterion uus introducedby CNS Unit 1 Operating hcense Amendment S(9 13 on September 30,1986.

'1he associatedsafety etufuation statedthat thefilter time constant uus to reduce spurious reactor trips aruf angi [iaryfeeduuter initiations. Despite this a8ouunce, in its M su6mittal the licensee statedthat CNS Unit 1 currently has nofifter time constant associatedunh this circuitry, andthat thefilter time constant uns neter implernented. '1hus the [icenset proposedto emit the requirernentfor tfik time constantfrom the M Channel Calibrationfor this instrumentfunction, TISSR33.1.10. 'Ihis change is adminhtratist fecause it deletes a rneaningless requirementfrom the CTS anddoes not afterhow CNS Unit 1 is operated In addition, it brings the Unit 1 Channe[ Calibration requirementsfor thisfunction into conformity with Unit 2. '1herefore, this change is acceptable.

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[ 2. Turbine '1rio and Treducter Isolation instrumentation - Addition oft -? fan Coincident with TeactorTriv 1

Actuation Tunction S[NS C53/43.2; Ta6(es 33-3,3.4-4, and43-2; Functiona[ Unit 5 S[NS M33.2,'Ta6le33.2-1 Function 5.d S{AfS33-3{.24 '1he CIS3/43.2 requirementsfor the turbine trip andfeeduuterisolation instrumentation function are increased to also require an initiation stynalfromg'T -[cw coincident utth reactor trip (T-4). 'This stynalrelationship [imits an egessist reactor coolant system (RCS)cooflownfollowing a reactor trip 6y tenninatly inainfeeduuterf[cw to tfte steantgenerators. '1he inclusion of this initiation stynalin TTS 33.2.5. dis acceptable because it enhancesplant safety andis consistent unft theplant desyn andsafety analysis.

3. Containment Tressure Contro(Sustem - TethedAction Teauirements CNS CTS 3/43.2, Table 3.3J, Functiona[ Unit 7, Action 166.a CNS M33.2 Action T, Ta6le 33.2-1 Function 9 S[NS CTS 3/43.2, Ta6[e33-3, Functiona[ Unit 6, Action 26 S{NS M33.2 '4 tion R Table 33.2-1 Function 9

.Rackaround '1he Containment Tressure Centro [ System (CTCS)is describedin CNS UFSARSection 7.6.4 and l

S[NS UFSRRSection 7.6.16. It consists of tum redundant trains witfifourdiferentialpressure f transmitters l

or channefsper train, each channelsupponing a redundant independent component orsystem. '1hese systems are j the containment spray system andthe air returnfan system. In addition, the CTCSfor S[NS suppons the l fiydvgen skimmersystem. In the ezent one of the etyht channe[s is inoperable, CTS spectfy action requirements. '

l

'Ihese action requirernents hate 6cen rethedso that the M action requirementsfor CNS ands [NS are the same.

'Each CTCS instrument channefperfonns a start pennissitt/tenninatefunctionfor its associatedsystems. '1he purpose of the start pennissitt/tenninatefunction is to pretent egessive depressurization of the containment t[irough inaltertent or e.tressist operation ofcenain engineeredsafetyfeatures such as the containment spray system.11%en containment pressure is below the tenninate setpoint, the stan/tenninatefunction wi8 automatica8 9 stop orprevent actuation of the associatelfeatures to protect against inadttrient actuation and the resultiy negatistpressure transient in the containment. '1he start /tenninatefunction blocks actuation of the associatedfratures unti(containment pressure has increased to the start pennissive setpoint.11%cn Catawba and McGuire Draft Safety Evaluation 1

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/1 f containment pressure is aboze the start permissize setpoint, thefeatures are enabled to perfonn their l

containment protectistfunctions; eg, to prezent ozerpressurication of the containment in the ezent of a DM  :

%se instrumentation centrofs to blockandpennit actuation of the associatedfcatures are automatic, 6ut each channelmayindiziduaEy 6e vnanuaEy ostfridden byplacing t[1e channelin the test inode andsetting the l selpoint to eitherpermit orprestnt (or terminate) system operation. Selecting oneprecludes the other. 1 I

CMS 33-M.25:'Discussionfor CHS in the ezent erw channefis inoperable, the CW cI5 requheplacing that channelin trip unfxin one(wur. For emmple, shouMthe stan permissist/tenninatefunctionfor the channelbe j inoperable, manuany placing the channelin the start pennissize mode uvuWrender the terminatefunctionfor that channelunazuifable. %proposedm action requirement s{oes not requireplacing the channelin trip, an action unich uvuMdisable the othersafety mode of that channel Rather, it requires immediately declaring the associatedsupportedfeature inoperable. 1his is a more restrictize action because the c15 uvuMaEow operation to continue indefinitelyprovidedthe channelis in trip, uncreas the supponeffeature's action l requirements, in most cases, uvuMplace a (imit on unit operation. 'Ihis change is acceptable because the  !

speafiedaction requirements associatedwith the Lcofor the supporteffeature are adequate to ensure l protection of the pubGc health andsafety.

In the ezent more than one CTG channelis inoperable, the c$ c15prozide no action requirements; thus a unit shutdown in accort{ance unth c53D3 uvuM6e required. In some cases this may be overly restrictize.

%proposedm action requirement to immediately enter the Lcos of the supportedfeatures appGes ezen tf more than one c10channelis inoperable. %th tuo or more channels inoperable, the m may require a unit shutdown, uhich is consistent with the CIS. In other cases, houtzer, the supporteffeatures' action requhements may anowoperation to continue temporarily to cEow time to restore the inoperable c1U channel < to operable status. In these cases, the m action regubement uvuMbe less restrictize. % m action requhement prozales adequate assurance tfiat operation with any number ofinoperable cia instrument channels is Gmitedconsistent uith the Require / Action completion %es associatedunth the Lcosfor the supportelfeatures. 'Inis change is acceptable 6ecause the specifiedaction requirements associatet{unh the Lco for the supporteffeature are adequate to ensureprotection of thepubGc health andsafety.

MMS 33-L28:'Ducussion forMWS In the eitnt one OIGchannelis inoperable n ;d$ c5 require placing that channelin the'startpermissize mode unthin one fwur. Ifotherchannas 6ccome concunently inoperable, the same action reguhement appGes; a shutt{own in accordana with c53D3 uvuMnot i necessarily 6e requhef, ufich ovum 6e the case under the CW c13. In addition, the MW c15 require applying the appGcable action statement of thefeatures supportedby the inoperable channel % m action requirement retains this action requhement but omits the CIS requirement toplace the inoperable channelin the start pennissize mode. 'Inis is less restrictize because it pennitsgreater operationalflegbinty; in some plant condstions, it may be adsuntageous toplace the channelin the tenninate moi {e. % m actions are acceptable because they addappropriatefle46inty ufile maintaining the (czelofsafety affortfed6 9 the cI5 action requirements.

4. 9(udroaen Monitors ' Deletion ofAnaloa channeloverationa(Test. Refaration ofchannelchect 'Treauencu,

' ' ~ '

anifirmozufofStanaeredTest krauhNnentfrom ciiannefcalibration c$c54E4.1 c$ MSR333.1 andSR333.2 Catawba and McGuire Draf t Safety Evaiuation

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l 71 r ,

i CHS33-L11 CIS 4.6,4.1for trie hydrogen monitors requires a channdcheckonceper12 hours, an Analog ChanndOperational' Test (ACOIl COTin the FIS) once per31 days, anda channdCalibration etery 92 days ,

on a Stagered' Test Basis. % m relaxedthe test intenulof tfie CAanndcheckto 31 days in ITS SR333.1.  !

% is acteptable because it is consistent wit & the m SKFrequencies esta6Gsheffor aEotherpost-accident i monitoring fPAM) instrumentation. % 175 also omittedthe stageredtesting requirementfrom tfie Cluusnd l CaG6 ration in FISSR333.2. '11 tis is acceptable because tfue hydrogen monitors do notperform a mitige at function. In addition, ddeting the stageredtesting requirement simpfsfies scfieluang andwi8 preclude ,

missing a ChannelCalibration simply because ofa missedstageredtest intenul FinaEy, the 175 omits the l l

COT % u acceptable because the hydrogen monitors arepassist detrices, do not initiate any automatic actuations, andare uselon[y duringpost accident conditions. % staffagrees that the retrisedS4 are commensurate uith the rnonitoringfunction of the hydng> en monitors. %refore, thue changu uftidi are consistent with the SIS, are acceptable.

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5. Tost-Accident Monitoring System Instrumentation - TetisedAction Requirements l CNSCI53/433.6 Actions CNS0153/4.6.4.1 Actions CNS ETS333 Actions CHS33-L8 CNS CTS 3/433.6 Action a ande allow 7 days to restore an inoperable citannefofpost-accident monitoring fPMf) instrumentation. Corresponding 115333 Actions A,9, andC relaxedthis to 30 days 'Ihis diange is acceptable baselon operatiry e.yerience andbecause these channds are passite andperform no actuationfunction. In addition, tfie remaining operable channels, the remaining operable diverse 1 ariable, or ,

afternate rnonitoring methodunflensure adequate monitoring ofplant conditionsfo8owing an accident.

CHS33-L9 CNS CIS3/433.6 Action a and3/4.6.4.1 Action a require a unit shutdown uften one required TAMchanndis inopera6(c andthe actions cannot be completeduithin the aEcuedtime. rTS333 Action D replaces the shutdown requirement uith a requirement to immediately initiate action in accordance with !TS 5.6.7, 9AMReport. ' 'Ihis change undallow continuedoperation in tfils conditionforfunctions with tzio l requiredchannds andfor tfwse unth one requiredchannelif the associatedliterse cfianneforafternate monitoring metfwdis operable, protideda specialreport is written to tfte NRC witfiin 14 days detailingplanned correctist actions. '1his change is acitytable 6ecause untfi eithera remaining operable channe4 or a distrse operable channel the monitoringfunction is not fost.

~ In the etent one channefof the containment area radiation snonitor or reactor coolant radiation lett[ monitor is irwperable and the afternate monitoring metfwdis also inoperable, the CI5 uvuld require a unit shutdown in accordance uitft CNS CIS3.03 6ecause CNS OTS3/433.6 does not specify an action requirementfor this specific condition. % FIS addresses tfils situationforTAMradiation rnonitoring instrumentation by l

requiring, in 115333 Action D, tfiat sfone of the inoperable channels cantwt be restoredto operable status within 7 days a specialreport uvuld6epreparedandsufnnittedto the NRC witfiin 14 days. 'Ihis is consistent unth the STS andis accepta6fefor tfie reasonsgiten a6ott.

l l CHS33-L1D CNS C153/433.6 Action 6 requires a unit shutdown if the ininimum number ofoperable TM[

channels cannot be restoredwitfiin 48(wurs. % FI5 relaxes this Completion 'Iime to 7 days in FIS333 \

Actions 'E andF. Gs cfiange is acceptable basedon tfie [owprobability ofan etent requiring TM[ instrument operation andthe asuifability ofafternate means to obtain the requiredinformation.

l Catawba and McGuire Draft Safety Evaluation 1

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6. Reactor Coofan t System (RCs) LourTemperature Otervrusure Trotection (L90T) System - Addition of Alfouunce to Ope' rate Tuv Charainn Tuhtps Ceneurrent(y }

Sf6 CB3/4.433 Action a andFootnote

• SO(S 153.4.12 &quiredAction A4 Sl%fS 3.4-L26 In the etent tuo or more centnfuga[chargingpumps or tuo or more safety injection pumps are capa6(e ofinjecting into the reactor coolant system (RG) ufien L70T is required, CB 3/4.433 Action a requires immdiately reducing the num6erofcapablepumps to the num6er alTourdby CB3.433. 9(outrer, Footnote

• to CS Action a specifies an egeption to this actionfor the condition of tuo centnfuga[ charging pumps being capable. 7&is egeptionperm*ts tue capa6(e centnfuga[chargingpumps unen tuoyoutr-operatedreliefsultes fivRVs)are securdopen unth blocksulzes open unth theirpouer ranozed. 153.4.12 Action A alsopennits this alTouencefor tue capable chargingpumpsfor the additionalafternatize condition in NguirdAction At that the RG is depressurizedandan RG vent ofgreater t[wn or equalto 4.5 square inches is established. 7his change is acceptable because the sent size uns erufuatelin the S(7(S (aus-temperature oterpressur: protection analysis andis approximatedby the tuo open TORVs. 7 hat is, uith tuo capable chargingpumps, the [ezelofozerpressure protection affordedby a sentedanddepressurizedRG is ,

equitufent to that prozoided6y tum TORVs unth open de-energized 6(ockzultts.

7. Teactor Coolant Suitem fraRaae ' Detection Instnimenta.* ion - TettsedArtion Trauirements

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l CS(Sands (A(SC53/4.4.6.1 Actions CNS and MNS ITS 3.4.15 Actions The staff reviewed CNS and MNS's proposed ITS 3.4.15 which is based on STS 3.4.15

" Reactor Coolant System Leakage Detection Instrumentation," for changes to CNS and MNS CTS 3/4.4.6.1 that are also deviations from the STS. A change to the LCO and action requirements for an inoperable containment atmosphere radioactivity monitor (gaseous or particulate for CNS; gaseous for MNS) satisfied this description.

Backaround (CNS and MNS 3.4-A.1 and CNS 3.4-A.41) ITS 3.4.15 differs from the STS to reflect plant-specific system names, which include changing the STS's

" containment sump level monitor" to the ITS's " containment floor and equipment sump level monitor," and changing the STS's " containment air cooler condensate flow rate monitor" to the ITS's " containment ventilation condensate drain tank (CVCDT) level monitor." Also, the CNS CTS 3.4.6.1 requirement for the Operability of containment sump discharge flow monitor was not retained because the actual system monitors level changes, not flow rate. The staff found that these deviations from the STS terminology were acceptable because they are consistent with existing CNS and MNS terminology and leak detection system design.

CNS and MNS 3.4-L17 in the event a containment atmcsphere radioactivity monitor (gaseous or particulate for CNS; gaseous for MNS) is inoperable, CTS 3/4.4.6.1 Action allows continued plant operation for 30 days provided grab samples of the containment atmosphere are taken and analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For this condition, CNS and MNS ITS 3.4.15, in Required Action B.1, retain the requirement for daily grab samples of the containment atmosphere, but add the option in Required Action B.2, consistent with the STS, to instead perform an RCS inventory balance every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This added Catawba and McGuire Draft Safety Evaluation

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I flexibility is acceptable because both methods provide an effective mechanism to detect RCS leakage. This part of the change to the CTS action requirements, however, is within the scope of the ITS conversion.

i CNS and MNS ITS 3.4.15 Action B differs from the STS and the CTS because it does I not require restoring the inoperable monitor within 30 days. In addition, the ITS does l not adopt the STS's option to verify the Operabilny of the CVCDT level monitor within 30 days. Omitting these two STS action requirements is beyond the scope of the ITS conversion. The ITS omit these action requirements because they provide no additional limitation beyond that imposed by the other Actions of ITS 3.4.15, all of which are consistent with the STS action requirements.

Discussion for CNS in the STS, if the CVCDT level monitor is Operable, then the second optional action requirement would be taken, and operation of the unit could ,

continue indefinitely. If the CVCDT level monitor is not operable, however, then this I action requirement to verify the Operability of the CVCDT level monitor within 30 days is l unnecessary, in addition, CNS ITS 3.4.15 Action D already addresses the condition of both the containment atmosphere radioactivity monitor (gaseous or particulate) and the CVCDT level monitor being inoperable. This Action requires restoring one of these monitors within 30 days. Thus the 30-day requirement, when it would apply, is contained in the ITS action requirements without including it in CNS ITS 3.4.15 Action B.

Discussion for MNS In theSI5, if the CibDTlew1rnonitoris Opera 6fe, then thesecondoptionalaction requirement uvuff 6e taken, andoperation of the unit couldcontinue indefinitely. If the CtL9T[ewlrnonitor is not operable, houtwr, then this action requirernent to tienfy the Opera 6i[ity of the CltDT[ewfinonitor within30 days is unnecessary 6ecause the containment floor and equipment sump monitor and the containtnent atmosphereparticulate rnonitorwould be availab!e to monitor leakage. in addition, if the containment atmosphere particulate monitor is also inoperable, MNS ITS 3.4.15 Action C would require restoring one of these monitors within 30 days. Thus the 30-day requirement, when it would apply, is contained in the ITS action requirements without including it in MNS ITS 3.4.15 Action B.

Therefore, as long as the CVCDT level monitor is Operable and either a containment grab sample is obtained and analyzed or an RCS inventory balance is performed daily, ITS 3.4.15 Action B will allow plant operation to continue indefinitely with an inoperable containment atmosphere radioactivity monitor (gaseous orparticulateforc#S;gaseousfora(#59 This is acceptable because diverse indication of RCS leakage is maintained by the CVCDT level monitor and the containment floor and equipment sump monitor, and for MNS, the containment atmosphere particulate monitor. Based on the above, the staff finds that ITS 3.4.15 Action B for CNS and MNS is acceptable.

8. Accumulator Isolation Valves - Revised Pressure Limit for Removina Power CNS and MNS CTS 4.5.1.1.c CNS and MNS ITS SR 3.5.1.5 Catawba and McGuire Draft Safety Evaluation

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1 CNS and MNS 3.5-M.2 CTS 4.5.1.1.c requires that the power be removed from the accumulator isolation valves when reactor coolant system pressure is greater than 2000 psig. Removal of power will ensure that the accumulators are not isolated from the RCS, and can inject coolant into the RCS when the conditions exist. Corresponding ITS SR 3.5.1.5 specifies a more restrictive pressure threshold of 1000 psig. The licensee l cited Westinghouse Nuclear Safety Advisory Letter (NSAL)97-003 to support this I change. NNL 97-003 addresses operating bypasses and compliance with IEEE 279- l 1971. The revised pressure setpoint is consistent with the operability assumptions i described in the NSAL for a loss of coolant accident while shutdown, and is also consistent with existing practice. Therefore, the staff finds this change acceptable.

9. Refuelina Water Storaae Tank (RWST)- Deletion of Outside Air Temperature Condition j for Performina RWST Temperature Verification Surveillance '

CW ands {NS CI54.5.4.6

, CNS antfS{NS P13SR3.5.4.1 \

CNs and%{Ws3.5-sf.3 'Etery 24 (wurs, CIS 4.5.4.6 requires zenfying that the refueling unterstorage tank ,

(mt'ST) temperature is within the range 70 *7to 100 *F "wfien the outside air temperature is less than 70 *7or greater tIsan 100 *F.* % SRis retainedas rTSSR3.5.4.1. % ambient temperaeure condition is deletedso j that the daily requirement to monitor the ms'STtemperature apphes without regardto the ambient temperature. 'under the current Section 4.5.4.6, licensee personnelhate to venfy the outside temperature ezery 24 (wurs, anddetennine if there is any needto senfy m t'STwater temperature; under the proposedSR3.5.4.1, j personnelsimply senfy the Mt'STtemperature ezery 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> regard [ess ofoutside ambient temperature. % l proposeilchange is acceptable because it increases the monitoring ofm1'STtemperature to u(senezer the mt'ST is requiredto be Operable.

10. 9(ydrocen %{itiaation System - Tevised%{inimum Humber ofTeauired9(ydroaen faniters jg yyygg S{NS CI54.6.43.a y, I S{NS FTSSR3.63.1 g S{MS 3.6-A37 CTS 4.6.433 requires that 32 of33 hydrogen yniters be operable on e train. Corresponding 113SR3.63.1 requires 34 @nitersper train to 6e operable. % actualdesyn contai

• nitersper train. l

'Ihis change is administratite because it corrects an inadtertent error in the CI5 andis consistent with current operation of the system. % corre t numSer ofyniters uus increasal as discussedin S{NSSERSupplement 7, Attaclunent C, after thefirst refueling outage ofeach unit. 'This change corrects the'I5 uitft the approzed l

[icensing Basis as describedin the SERsupplement. 'Iherefore this change is acuptable. j l

11. lee Bed- Tela. ration ofST 'Treauencu to ' Verify Baron Concentration andv3(

CNS ands {NS CTS 4.6.5.1.6.1 CNS ands {NS ETSSR3.6.123 l l

'Bacfaround % boron in the ia of the ia 6cdis usedto reduce the tulatility of radiciodines andto ensure that the ozera(( boron concentration in the sump is not dilutedduring the ia meltfo((owing a desyn basis foss of l coolant accident. % pHof the iafacilitates remozulof radiciodines andminimizes corrosion uithin l centainment during the recirculation phase of a iles@n basis foss ofcoofant accident. l Catawba and McGuire Draf t Safety Evaluation I

1 CMS 3.6-f,.25 CIS 4.6.5.1.6.1 requires tenfying the boron concentration andpS{of the ice 6edis witfan limits onceper9 months, ufiich h the test intenufgittn in the STS. Corresponang MSSR3.6.12.3 increases the sunti8ance intenulto 18 months. SampGng of the ice baskets &pefonnedat random fy sampGng the topfew feet after removing afewinches oficefrom the top of the fasket. Datafrom past sampling of the ice beds indicates that there hatt 6eenfewfaifuresfor tfils sunti8ance. 7he boron in the ice is in tf,eform ofsodium tetra 6 orate (a salt), andU not telatile eten though the ice itselfmay sublimate. As a result, not only uvuldthe boron concentration not decrease, it un8 increase in interseproportion to the quantity ofice remaining. 7his was demonstratedbypast sunti8ance t{ata, sfwuing that the 6oron concent ation associatedpS{ routinely met the acceptance criteria (specu f iedin CTS 3.6.5.1.a andretainedin iTSSR3.6.12J). Accorengly, the SK Frequency may be refandto onceper18 months, consistent witft thefrequency ofrefuefing outages. A 6enefit of tftis relaxation is that it wi8 reduce the number of routine containment entries duringpouer operation. 7his refaxation is accepta6ft 6ecause of thefaturable survei8ance recordandthe tendency of the ice Ecdboron concentration to increase oter time.

, !k(MS3.6-[e.2E CIS 4.6.5.1.61 req tires tenfying the boron concentratlen arufp9{of the ice 6edis uithin limits onceper 9 rnonths, afiich & the test intervafgiten in the S1S. Corresponding PTSSR3.6.123 increases the survei8ance intenulto18 rnontfis. Sampling of the ice baskets isperfonnelat randorn by sampling the topfew feet after removing afewinches oficefrom the top of the basket. Data rom boron sampling in tfue ice 6 tis indicates that there fwst beenfewfailures for this sunti8ance in - S6 r{yfailur torl'o N84) RWeD sin >daman,attnbuted a the smiialice loadry orice makeup techniques in use at j t time. During the initia[ years of operation, ice sublimation rates uere higher than eqcctedandsettral rnetTwifs utre uselto increase the ice basket utiglit. '1hese includedreloading witlifresfiflake ice, reloading with ice blocsc onnedfrom a foraxsolution in molds, aruf the direct addition ofborax to the baskets. As a result, effective samplingfor these 6askets duriry 's timeframe uns difficult because the sample may not hatt been representatite. 7he data revicuelfo nt arperioi((1986 to1996) indicate that of the oter5m faskets samplet{ 26 hadconcentrations less than 1800 ppm, andthat 7 of these 266askets utre reloaded, and the remaining 6askets utre azeragelunth the other 6askets.

7he 6oron in the ice is in thefann ofsodium tetra borate (a salt), andis not tefatile eign tfwugft the ice itself may sublimate. As a result, not only uvuld the boron concentration twt decrease, it ui8 increase in instise proportion to the quantity ofice remaining. 7hu uns ifemonstratelbypast sunti8ance data, s(wwing that tfe boron concentration andassociated79{ routine [y met the acceptance criteria (speafiedin CTS 3.6.5.1.a and retainedin FTSSR3.6.12.3), except as twtelabove. Accor&ngly, the SRFrequency may be relaxelto onceper 18 months, consistent uith thefrequency of refue[ing os.tages. A benefit of this refaxation is that it wi(( reduce the number of routine containment entries duringpouer operation. 7his relaxation is acceptable because of the fazerable sunti((ance recerifofrecentyears and the tendency of the ice belboron concentration to increase over tirne.

12. Containment 'I'afre Iniection WaterSystem Deletion ofSurge' Tank WaterSupplu Tequirement and

' Reduction ofTequiredSealInfection 'Ifow Tate CW CTS 4.6.6.1 and4 6.6.2 CW lTS SR3.6.17.1 andSR3.6.17.2 Catawba and McGuire Draft Safety Evaluation

I Tackstround '1he containtnent tufve injection untersystem prettnis (eakage ofcontainment atmospftere past certaingate vahes useffer containment hofationfo8owing a foss-of-coolant accident (LOC 9)by injecting sea [uuter at a pressure qceeding containmentpressure betuten tuo seatingsurfaces of theflgelge tuhts as

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describedin CNS tlFSARSection 6.2.4.2.2.

C%fS3.6-L.23 CTS 4.6.6.1 requires tenfication etery31 days that the surge tanks of the system hatt a 30-day supply ofuntea Corresponding f1SSR3.6.17.1 omits this requirement because the nuclearsenice uuter system (Q1S) U the assuredautomaticsource ofunteraftera LOCt '1he Qtt;b desynedforlong term (30 day)cooGng. before, it is not necessary to specifica89require this to 6e tenfiedon a montIdy basis. 7hus the supply ofunter is assureduith or uitfaut the sunti8ance requirement. kefore, deletion of the surge tankuuter supply requirementfrom thu sunti8ance u acceptable.

CIS 4.6.6.2 requires tenfying onceper18 months that system pressure u 2 45psy, andthat the systemflow rate & less than 1.7ppmfor Train A and1.4gymfor Wain $ with a tankpressure 2 45psy. he criteria are baselon tuu QtSpumps in operation. '1he FIS criteria are 6asedon a single Qt'Spump in operation.

Specifica8y, corresponding f1SSR3.6.17.2 requires aflow rate to be less than 1.29ppmfor Train A andless than 1.16gymforWain B with a surge tankyrusure 2 36.4psy. In its submittal the licensee statedthat at this (outrsurge tankpressure, thepressure at the va[tt with thegreatest system head [ossfrom the surge tankis 216.2 ps@, ultich is 110 percent ofpeakcontainment pressurefo8ouiry a LOct 'Ifius spenfying the required system pressure with a surge tankpressure of 2 36.4psy is equitulent to speafying a system pnssure of 216.2 psy. he changes in sunti8ance requirement acceptance criteria are acctytable because they are adequate to ensure that the containment tuht injection watersystem wi8 perform its containment isolationfunction fo8owinga des @n basis LOC 9.

13. Sfain Steam Sa,fett!'Vahts (%fSS1's)- TevisedAction Teauirements CNS CTS 3/4.7.1.1 Action a andTable3.7-1 CNS 1T53.7.1 Action A and'Ta6(e3.7.1-1 Bacfaround '1he rnain steam safety vahts are code safety valves ((itt associatedunth each of thefour steam generators)andensure that the secondary system pressure wiE6e [imitedto unthin 110 percent (1304 ps@)ofits desyn pressure of1185psy during the most settre anticipatedsystem operationaliransient. 'Each vaht provides 20 percent of tfu re[ieving capacity. CNS CTS 3/4.7.11 afowsplant operation during the operational conditions of9(ot Standby, Startup, andToutr Operation (%fodes 3,2, and1) with some of these tuhes inoperableprovided the steamflow and thermalpouer are limited. '1he staff transmittedWestingftouse's Nuclear Safety Advisory Letter (NSRL)94D01 to licensees by Infonnation Notice 94-60, da tedAugust 22, 1994. NSAL 94-001 recommended reducing the existing limits on thermal power.

CNS 3.7-M21 CNS CTS 3/4.7.1.1 Action a references Table 3.7-1, to specify the maximum allowable power range neutron flux high setpoints (percent of reactor rated thermal power) as 87, 65,43 for 4,3,2 code safety valves operable, respectively, on a steam generator. In response to a recommendation received from the nuclear steam supply system (NSSS) vendor Westinghouse in NSAL 94-001, the licensee proposed to reduce the setpoints to 58,41,24 for 4,3,2 code safety valves operable, respectively.

These new setpoints were calculated using the formula orovided in NSAL 94-001, and will replace the old setpoints in corresponding CNS ITS Table 3.7.1-1. This change is Catawba and McGuire Draft Safety Evaluation

. For SRs that existed prior to this amendment whose intervals of performance are being l extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

The staff has reviewed the above schedule for the licensee to begin performing the new and revised SRs and concludes that it is an acceptable schedule.

-9' lnorrt AHk:A tht VI. STATE CONSULTATION in accordance with the Commission's regulations, the North Carolina and South Carolina State officials were notified of the proposed issuance of the ITS conversion amendments for the CNS Units 1 and 2 and MNS Units 1 and 2. The State officials had no comments.

Vll. ENVIRONMENTAL CONSIDERATION m, ~

Pursuant to 10 CFR 51.21,51.32, and 51.35, an environmental assessment and findi g of no significant impact was published in the Federal Reaister'pn for e proposed conversion from the CTS to the ITS for the CN&and#NR_ Anm% , ased upon the environmental assessment, the Commission has determined that issuance of this amendment will not i nificant effect on the quality of the human environment.

r Af/J' included in il se amenaments are changes that were beyond the scope of th9 ITS conversion for the CNS. These changes are discussed in Section Ill.G of this safety evaluation and were l either included in the Federal Reaister notice of July 14,1997 for Catawba (32 FR 37628), and July 15,1997 for McGuire (62 FR 37940) or in separate notices in the Federal Reaister. These changes altered requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that these changes involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occtpational radiation exposure. The Commission has previously issued proposed findings that the amendment involves no significant hazards consideration, and there has been no public comment on such findings (for Catawba: 63 FR 25106,63 FR 27760,63 FR 40553; for McGuire: 63 FR 25107,63 FR 25108,63 FR 27761,63 FR 20554).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no er.vironmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Vill. CONCLUSION The CNS and MNS ITS provide clearer, more readily understandable requirements to ensure safer operation of the stations. The NRC staff concludes that the !TS satisfy the guidance in the Commission's Final Policy Statement with regard to the content of TS, and conform to the STS provided in NUREG-1431 with appropriate modifications for plant-specific considerations.

The NRC staff further concludes that the ITS satisfy Section 182a of the Atomic Energy Act,10 Catawba and McGuire Draft Safety Evaluation

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Insert for Section V l i

"In its letter of September 8,1998, the licensee also proposed a license condition that will  ;

enforce the relocation of requirements from the CTS to licensee-controlled documents.  !

The relocations are provided in Table LA of Removal of Information from the Current l Technical Specifications and Table R of Relocated Current Technical Specifications. {

The license condition states that the relocations would be completed, during the  ;

implementation of the ITS, within 90 days of the issuance of this amendment (McGuire)  !

by January 31,1999 (Catawba). This schedule is acceptable." (

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l Catawba and McGuire - Draft Safety Evaluation

TABLE A- ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION

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Edi$ddisid$2 MIT%

MIN.

' i # '

OM@Qf:SW ** W@ 7" WNS%ND j$PMN%y TOR 414AMGtV -.. whWojsem fff*Q 1 QM. , 7 ii 1.0 A.12 The CTS electrical power requirement in the CTS definition of OPERABILITY was clarified 1.1 1.19 to explicitly state " normal or emergency electrical power." The intent of the CTS language "necessary... electrical power"is to only require one source of power for a feature to be OPERABLE. Similarly, the CTS language "specified function" was replaced with "specified safety function (s)" to clarify that OPERABILITY does not encompass any non-safety functions a system may also perform. >

1.0 A.13 The CTS definition of MODE was clarified to include "with fuelin the reactor vessel." This 1.1 1.20

• is editorial in nature since the statement was already included in CTS Table 1.2 which  ;

defined Operational Modes. Therefore, the ITS definition of MODE is equivalent to CTS t

requirements. i 1.0 A.14 Not used. gpbM[/O 1.0 A.15 In the o excore detector is inoperable, the CTS definition of OUADRANT POWER SR 3.2.4.1 Note 1.25  ;

TILT RATIO (OPTR) requires computing OPTR using the three remaining excore l [

detectors to compute the average detector output. This requirement is retained as a note in ITS SR 3.2.4.1 to determine the OPTR.

1.0 A.16 in the determination of SHUTDOWN MARGIN (SDM), CTS 4.1.1.1 and 4.1.1.2 require 1.1 1.30 accounting for the reactivity worth of any rod cluster control assemblies (RCCAs) which 4.1.1.1 -

are not capable of being fully inserted. This requirement is retained in the ITS definiton of 4.1.1.2 SDM, consistent with the STS. In addition, the CTS definition of SDM is clarified consistent with the STS and current practice to specify using nominal zero power level values for fuel and moderator temperatures to calculate SDM during operation in MODES 1 and 2.

• 1.0 A.17 The CTS definition of STAGGERED TEST BASIS is modified to be consistent with its 1.1 1.35 usage throughout the ITS. The intent of the frequency of testing components on a STAGGERED TEST BASIS is not changed. The ITS 1.1 definition allows specifying staggered test intervals for applicable ITS SRs in the SR Frequency column, independent

• of the number of subsystems.;The modification of the definition does not involve any technical changes to the staggered intervals specified in the CTS and only affects the presentation of thisinformation.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 3

t TABLE A- ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION 5 r (el .

1.0 A.18 The CTS definition of FREQUENCY NOTATION and associated CTS Table have been 1.1 1.14. Table 1.1 deleted since the abbreviations in the CTS Table are no longer used within the ITS. The ,

CTS FREQUENCY NOTATIONS are replaced in the ITS by the direct specification of all frequencies without the use of " Notations".

1.0 A.19 The note in CTS Table 1.2 that helps define MODE 6, Refueling, is revised to delete the Table 1.1-1 Note c Table 1.2 Note * !

phrase "with the head removed." This change is administrative because this note also j describes Mode 6 with the bounding phrase "with the head closure bolts less than fully

[

tensioned." The vessel head can only be removed if the head closure bolts are less than '

fully tensioned. Thus MODE 6 may be defined without the phrase "or with the head removed." i 1.0 A.20 The ITS contains three new sections,1.2 - Logical Connectors,1.3 - Completion Times, 1.2,1.3, and 1.4 1.0 ,

te ego C requency, to ensure consistent understanding and use of the ITS format and g presentation style. These new sections do not eange any CTS operational restrictions or limits. Their addition is, therefore, an ed$nistrative change.

1.0 A.21 The average reactor coolant temperature threshold for MODES 1 and 2 specified in CTS Table 1.1-1 Table 1.2 Table 1.2 was changed to NA (not applicable) in corresponding ITS Table 1.1-1. In the ITS, individual specification appilcability statements specify the applicable average reactor coolant temperature limits in MODES 1 and 2. In particular, the 350*F MODE 1 and 2 temperature specified in the CTS tab *e is unnecessary because ;he minimum required '

reactor coolant temperature for MODES 1 and 2 is specified in the appropriate ITS '

Section 3.4 specifications. The ITS definitions for MODES 1 and 2 retain the CTS i theshold values of reactMty (K,) and thermal power level. These thresholds are the  !

principal basis for the applicability of CTS requirements in MODES 1 and 2. Therefore, specifying reactor coolant temperature boundaries in the applicability statements of only those ITS specifications that require it, and omiting it from the ITS definitions for MODES 1 and 2 is an administrative change.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 4

l TABLE A- ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION n 7 V d > 4 Li M : --nVT%$W

%is6065i6M < w n M W MV 3 Di Vm s.,iL ^%

70!rCMAfTOM ffW@h

@# h s g 9 W 4 ;<.s f . i 4j9$fCEM.+ SMdd5Miidacsgr - . . ' .

t 1.0 A.22 The definitions o Hot Shutdown (MODE 4) and Cold Shutdown (MODE 5) in CTS Table Table 1.1-1 Note b Table 1.2 1.2 are clarit er completeness to preclude misinterpretation. Specifically, a note was i addedt s eci i hat these Modes require "all reactor vessel head closure bolts fully I tensioned. he addition of this note is an administrative change because it eliminates a potential overlap in defined operational modes and reflects actual industry practice.

I 1.0 A.23 The definition of REFUELING (MODE 6) in CTS Table 1.2 was changed to remove the Table 1.1-1 Table 1.2 140'F uppe, limit on average reactor coolant temperature. When the average coolant temperature exceeded 140'F, the CTS could be misinterpreted as not requiring the application of TS requirements that are needed when the reactor vessel head bolts are not fully tensioned. Removing the temperature reference will ensure observance of the MODE 6 TS requirements should the average coolant temperature exceed 140*F. This change is administrative because it makes clear the intent of the CTS and is consistent with current practice.

1.0 A.24 The CTS definition of CHANNEL CALIBRATION was revised to include calibration of 1.1 1.5 required displays The majority of CTS channels which require a calibration are those that perform trip or actuation functions and do not have a " required" display function. However, CTS 4.3.3.6 requires a calibration of the post accident monitoring channels. The safety function performed by these channels is a display function only. Therefore, the inclusion of required displays within the ITS definition of CHANNEL CALIBRATION is an administrative change because it is consistent with the CTS calibration requirements for the post accident monitoring syste n instrumentation channels and with current practice.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 5 i

. - - - + - -- -.__._m-._m_____--*-____-2 '--- -_m- - -- - -- +v.e*+1=-~re=_- aw-"_2-M

t TABLE A- ADMINISTRATIVE CHANGES SECTION 3.2 POWER DISTRIBUTION LIMITS ,

G i g l A Note was added to the CTS Actions to clarify that a power reduction is not required to 3.2.2 Actions 3.2.3 Actions 3.2 A.7 meet the required actions if, prior to reducing power below 75% (or 50%), F,s(X,Y) is restored within limit. No technical requirements are added or deleted by this change.

3 3.2 A.8 The CTS Action that allows operation to proceed and THERMAL POWER to be increased provided Fas(X,Y) is demonstrated within limit prior to increasing THERMAL POWER whenever power is reduced because F1w(X,Y) is not within limit has been reformatted as a 3%d y g ggD 3.2.idctions y,3 gfM g l!  ;

Note to the required actions in ITS Actions.

The CTS allowance for an exemption to the provisions of Speci%ation 4.0.4 that allowed SR 3.2.2.1 4.2.3.1

, 3.2 A.S

> the plant to change MODES (enter MODE 1) without requiring toe Surveillance .

Requirement to be performed is retained in the Frequency requirements of the

. corresponding ITS Surveillance Requirement.

The CTS Surveillance Requirements for verification of hot channel factors after the OPTR 3.2.4 Actions 4.2.2.2.b and l 3.2 A.10 indicated by the excore detectors is normalized using incore detectors was converted to an 4.2.3.2.b action in the ITS OPTR LCO. The CTS requirements are retained intact in the form of Actions. l i 3.2 A.11 Not used.

i 4.2.3.2.c.1 and The CTS SRs for a determination that Fas is within the sumeillance limit and for an SR 3.2.2.2 3.2 A.12 4.2.3.2.d extrapolation of recent Fas measurements to determine if the surveillance limit would be exceeded in the next 31 EFFD were reformatted and retained in the corresponding ITS Surveillance Requirement. No technical changes were introduced when reformatting the CTS requirements.

The CTS Surveillance contains Actions if the Fan surveillance margin has not been met. 3.2.2 Actions 4.2.3.2.c.2 3.2 A.13 3

The Action requirements in the Surveillance are redundant to the Actions provided in the 4

associated LCO. Since,if the Surveillance was not met the LCO Actions would be applicable, the Actions contained in the CTS Surveillance are not required and have been deleted.

(C) Catawba specific (M) McGuire specific 2

Catawba and McGuire Nuclear Stations

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION

• DISCUSSION TWWEDT "OWCHANGEU

1. +6dM$7PE N9%$ %h MD25@@FSiEMS$W*MNNM i $h ihidshDN$$NifMhd IlkNsblii$idhNN IMd$N5%ME9$s j h 3.3 A.22 (M) A clarification has been added to the single channel Source Range Neutron Flux function Table 3.3.1-1 Table 3.3-1 in MODES 3,4, and 5. The ITS Note clarifies that this function is required when the reactor trip breakers are open. A note already exists for the two channel function in these modes that states two channels are required Operable when the reactor trip breakers are closed and the rod control system is capable of rod withdrawal. Therefore, this addition only provides clarifying information.

3.3 A.23 (M) The applicability of the CTS Turbine Trip function was modified by a Note consistent with Table 3.3.1-1 Table 3.3-1 the design for this function. The note specifies that the function is required operable above the P-8 interlock which conforms with the normal operation of the P-8 interlock. Below the interlock, a turbine trip does not cause an automatic reactor trip.

3.3 A.24 A Note was added to the CTS Actions that allows separate condition entry for each ESFAS 3.3.2 Actions 3.3.2 Actions Function. The Note provides bxplicit instructions for proper application of the Actions for TS compliance. In conjunction with the ITS 1.3, " Completion Times," this Note provides direction consistent with the intent of the existing actions for the ESFAS Instrumentation.

3.3 A.25 The CTS reference to Table 4.3-2 for the required Surveillance Requirements applicable to SR Note 4.3.2.1 each Function was converted into an ITS SR Note which references ITS Table 3.3.2-1 for the Surveillance Requirements applicable to each Function.

3.3 A.26 The CTS ESFAS Table which lists the, " Total No. of Channels," Viannets to Trip," and (C) Tables 3.3.2-1, 'Tabte 3.3-3

" Minimum Channels Operable" was replaced with one ITS colui.m that lists the, " Required 3.3.6-1, 3.3.7-1, and Channels." The ITS actions classify inoperabilities based on the required channets, 3.3.8-1 whereas the CTS actions were constructed based on total channels and minimum number of channels. A clarification was also made to the APPLICABLE MODES column. The (M)Tabit. .3.2-1 l phrase "or other specified conditions" was added to the APPLICABLE MODES column title. This change is intended to cover the Notes used to modify the modes listed in this ) M' b column. The Notes modify the modes in the Tabte or identify conditions beyond the defined modes. Therefore, this change provides a more appropriate column title. In addition, the CTS ACTION column was renamed to the CONDITION column and all CTS actions are replaced with ITS Conditions. The above changes only affect the presentation of the information on the Tables.

(C) Catawta specific (M) McGuire specific Catawba and McGuire Nuclear SMtions 6

TABLE A- ADMINISTRATIVE CHANGES  ;

SECTION 3.3 INSTRUMENTATION j NGIE $ h -

ai=t g i .

F The CTS ESFAS Control Area Ventilation Operation function which includes requirements 3.3.7 - 3.3.2 3.3 A.60 (C) for a loss of power initiation with specific channel requirements, actions, and surveillance  :

i requirements was moved to the ITS LCO specifically for this instrumentation (3.3.7). The requirements for the loss of power initiation feature of this system are redundant to other TS requirements and were eliminated from the new ITS instrumentation LCO for this system.yihe loss of power DG start function is addressed by ITS LCO 3.3.5 and the l verification that required loads are auto connected through the sequencer on a loss of  ;

power is contained in CTS 3.8.1.1 and is maintained in ITS SR 3.8.1.11. ,

A note was added to the CTS to require the CRAVS train be placed in the chlorine gas 3.3.7 3.3.2 Action 24 3.3 A.61(C) j protection mode if automatic transfer to the chlorine gas protection mode is inoperable.

This addition is consistent with the requirements of CTS 3.3.3.7 which has been relocated  ?

4 from the TS. ,

r The CTS requirements for the Auxiliary Building Filtered Ventilation Exhaust System 3.3.8 3.3.2 )

3.3 A.62 (C) l (ABFVES) actuation instrumentation were moved to a new LCO in the ITS. t A Note was added to the CTS that allows separate condition entry for each ABFVES 3.3.8 3.3.2 Actions i 3.3 A.63 (C)

Actuation Instrumentation. This Note in the ITS provides explicit instructions for proper  ;

application of the actions for Technical Specification compliance. In conjunction with ITS  ;

1.3," Completion Times," this Note provides direction consistent with the intent of the existing actions for the ESFAS Instrumentation. l The CTS requirements for surveltlance testing of the Source Range Neutron Flux Monitors SR 3.3.9.6 4.3.3.11.2.a  !

3.3 A.64 (C) Table 4.3-1 i consistent with CTS Table 4.3-1 when relying on these monitors to meet the requirements SR 3.3.9.4 for the BDMS were made into specific SRs in the ITS LCO for the BDMS (3.3.9). No  !

reference is used in the ITS to another LCO. In addition, the CTS error in referencing a monthly test in Table 4.3-1 was corrected. The referenced test on table 4.3-1 is a quarterly test and the new ITS surveillance is consistent with the frequency specified in Table 4.3-1. [

i The CTS requirement for a TADOT on the manual initiation function for Containment SR 3.3.6.4 Table 4.3-2 3.3 A.65  !

Purge and Exhaust was revised to clarify that verification of the setpoint is not required for the surveillance. The TADOT definition includes setpoint verification, however, this is a 4 manual actuation with no associated setpoints. l

)

(C) Catawba specific ,

(M) McGuire specific Catawba and McGuire Nuclear Stations 12

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION GE N. .

3.3 A.66 CTS requirement for a TADOT on the manual initiation function for Si, Containment Spray, (C) SR 3.3.2.8 Table 4.3-2 Phase A, Phase B, and Steam Line Isolation was revised to clari'y that the verification of (M) SR 3.3.2.7 setpoint is not required for thk illance. The TADOT definition includes setpoint verification, however, these ; Aual actuations with no associated setpoints.

3.3 A.67 The CTS requirement for a TADOT on the manual initiation function for reactor trip, reactor SR 3.3.1.14 Table 4.3-1 trip bypass breakers, and Si input to reactor trip was revised to clarify that the verification of setpoint is not required for this surveillance. The TADOT definition includes setpoint verification, however, these are manual actuations with no associated setpoints.

3.3 A.68 (C) (Unit 1 only) conceming the filter time constant in the Unit 1 steam generator low-low level 3.3.1 Note 13 on Tabte 4.3-reactor trip circuitry was deleted. Unit 1 presently has no filter time constant associated 1 with this circuitry. This note was added to the Unit 1 Technical Specifications on . i September 30,1986, via license amendments 13 and 5 for Units 1 and 2, respectively.

1 The purpose of the time constant was to assist in reducing the number of spurious low-low ,

steam generator level reactor trips that occurred early in the plant operating history. The f subject filter time constant was never actually implemented.

3.3 A.69 The portion of the CTS note in the RTS Specification regarding the exception to the SR 3.3.1.11 Note 2 Note 5 on Table 4.3-1 provisions of Specification 4.0.4 for entry into Modes 1 or 2 for the detector plateau curve verification was moved to the applicable ITS SR.

3.3 A.70 (C) The CTS Channel Calibration mquirement for the overtemperature and overpower delta T SR 3.3.1.10 Table 4.3-1 functions was revised by the addition of a clarifying note which states that the surveillance shall include verification that the time constants are adjusted to thed5roscribe alues. The (

overpower and overtemperature delta T functions have several time constants speci i -60/

their setpoints. As these constants are part of the CTS (and ITS) setpoint they are -

routinely verified in Channel Calibrations (which are required to verify the specified [IESOU setpoints). Therefore the addition of this ITS surveillance note serves as a clarification or reminder that the Channel Calibration should include the time constants.

9 l

(C) Catawba specific (M) McGuire specific  ;

Catawba and McGuire Nuclear Stations 13 l

i TABLE A- ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION '!

E .

[ n  :- nt:aggyu!

3.3 A.71 A new ITS Note has been included in the ESFAS Channel Calibration surveillance (M) SR 3.3.2.8 Table 4.3-2 ,

requirement to require that the channel calibration include verification of time constants. (C) SR 3.3.2.9 l Time constants are specified in the ESFAS as part of the setpoint. In CTS Tab!e 3.3-4 the setpoints for McGuire Function 4.d and Catawba Function 4.e contain time constants for which the ITS note is applicable. As the time constants are specified as part of the function setpoint and the fact that a channel calibration must verify each function's

i. setpoint, the addition of the ITS note provides a clarification and does not introduce a technical change in the calibration of any ESFAS function.

3.3 A.72 A new ITS Note has been added to the CTS requirement for ESFAS Response Time (C) SR 3.3.2.10 4.3.2.2  ;

Testing that provides an exception for the performance of Response Time Testing of the (M) SR 3.3.2.9

Turbine Driven AFW pump. The addition of this ITS note is consistent with an existing CTS l allowance for testing the turbine-driven AFW pump contained in the Plant Systems Technical Specifications for the AFW system. As this allowance already exists in the CTS pump testing requirements, the addition of the ITS Response Time Surveillance Note  ;

! serves only as a clarification of the existing CTS requirements.

. 3.3 A.73 The CTS surveillance requirement for the P-6 and P-10 interlocks is revised to more - SR 3.3.1.8 Table 4.3-1 Note 9

clearly identify the Nuclear Instrumentation channels associated with each interlock. The  !

identification of the Intermediate Range Instrumentation in association with the P-6  ;

interlock and the Power Range Instrumentation in association with the P-10 interlock is -

l consistent with the design of those interlocks.

3.3 A.74 (M) The Plant specific Doghouse Water Level High-High Function Actions are based on the loss of one entire train (less than the minimum required number of channels operable or Table 3.3.2-1 Function 5.e '

Action #25 g

k!

l more than one channelinoperable). Therefore, the typical conversion to the ITS of the p pp 3,p.y CTS Total number of channe's with an Action for one channelinoperable does not appfy. Conditions L and M L .

Instead of the total number of channels being used in the ITS " Required Channets" column, the CTS specified minimum number of channels per train is used in the ITS. The ITS Required Channels and Action Conditions preserve the CTS requirements in the ITS format.

t (C) Catawba specific (M) McGuire specific  ;

Catawba and McGuire Nuclear Stations 14 .

t

. . . _ _ _ _ _ __ _ . . _ _ . _ . - _ _ _ _ . . __ __ __ ___ . - . - . . ,,. -  %- w.- ,_.,e - - _ -

I L

TABLE A- ADMINISTRATIVE CHANGES f

. SECTION 3.3 INSTRUMENTATION GE 6 3.3 A.75 (C) The CTS table notation which states that the ' Trip function is automatically blocked above Table 3.3.2-1, item Tabled.3-3, Table ) i P-11 interlock and may be blocked below P-11 when Safety injection on low steam line 4.d.(2) Notation ##

pressure is not b!ocked' was revised in the ITS Applicability to state the signal may be  ;

blocked below P-11 when Steam Line Isolation Steam Line Pressure-Low is not blocked.

The reference to SI has been deleted. Amendment No.158/150 was issued by the NRC on April 3.1997 to delete the steam line pressure-low safety injection signal. The CTS inadvertently included an additional reference to this Si signal which should have been deleted.

2 l

i w

b l

i I

r i (C) Catawta specific  !

, (M) McGuire specific Catawta and McGuire Nuclear Stations 15  :

. ___-.___._.___._m._.________mm______.___.. ,

_ _ _ _ _ _ _ . ___ _ . _ _ ________.___ _ _ _ _ _ . _ _ _ . _ _ _ - . - - - ---x -e . _ _ , . - - . . ., n v -

l TAh.E A - ADMINISTRATIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM for CNS aM s)#uary /2 1945~ ,

g g. g '

'~

y

~

3.4 A.7 The CTS requirement for determining the RCS total flow rate by measurem nt on an 18 3.4.1 4.2.5.3 l month interval was left over from a previously deleted requirement to perf m a precision  !

heat balance to determic "OS total flow. This requirement was delete ylicense amendment dated Febuary 17,1995 (TAC Nos. M88480 and M88658). The deletion of this requirement shnfd have included 4.2.5.3. As the resulting CTS 4.2.5.3 is effectively the same as the re quirements in CTS 4.2.5.1 to determine total flow using the indicators every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />,4.2.5.3 is redundant and should have been deleted.

I 3.4 A.8 The CTS applicability requirement for monitoring pressure and temperature limits in the SR 3.4.3.1 4.4.9.1.1 CTS SR has been reformatted from text in the body of the surveillance requirement to an SR note.

3.4 A.9 The CTS requirements for RCS Loops in MODE 4 have been reformatted consistent with 3.4.6 3.4.1.3 Action a the STS and split into two separate Actions. This enange effectively keeps the same i

Actions in a different format.

3.4 A.10 The presentation of the CTS pressurizer safety valves setpoint limits of 2485 psig +3% and 3.4.10 3.4.2.2  !

-2% was revised to apply the tolerances to the setpoint and state the limits as 22435 psig and s 2559 psig.

3.4 A.11 The CTS Actions were revised by the addition of a note to indicate that separate Conditior. 3.4.11 3.4.4 i entry is permitted for each PORV. This Note provides a clarification of the ITS format fm permitting mult!ple entry into the Conditions, as described in ITS Section 1.3, Comp'etion '

Times and is consistent with the intent of the CTS requirements. ,

3.4 A.12 The explicit CTS Action for RCS PORVs to either restore an inoperable component, or 3.4.11 3.4.4  ;

comply with the required action was not retained in ITS. The allowance to restore ~

inoperable components is an inherent feature of any action, as described in LCO 3.0.2.

l 33 A.13 The CTS cross reference to CTS 4.0.5 for the Pressurizer Relief Valves was not retained 3.4.11 4.4.4.1 ,

in the corresponding ITS requirement. Requirements for Inservice testing (4.0.5) are provided in ITS 5.5.8 and need not be referenced in individual specifications. These types

[

of cross references are not used in the ITS. '

k (C) Catawba specific (M) McGuire specific [

r Catawba and McGuire Nuclear Stations 2 I I

_ . _ _ _ _ _ __. __ - --...w ~-r _ e = =+-- -~ - - ~ ' - * * " '

R i

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM - *

' \ k, ' " '

~ --'

/,,, .(

'-- 'l e h@_

b I:i(b E .' @MW40/ddkt;ELc2 hhh 1.J.

~

Meglid3cL:W C &L;L:QEu1=,it; 3.4 A.14 (M) A note has been added to the applicability of the CTS to clarify the restrictions for 3.4.12 3.4.9.3 accumulator isolation. The ITS Note is consistent with the CTS action b for an unisolated accumulator, l.G., the actions place the unit outside the mode of applicability. The CTS Action has also been clarified to include this statement.  ;

3.4 A.15 (M) The CTS Action a and the associated footnotes were reformatted to incorporate the 3.4.12 3.4.9.3 footnotes into the required actions. .

I I 3.4 A.16 Not used.

3.4 A.17 The CTS Action requirements for two inoperable PORVs, failure to meet the requirements 3.4.12 3.4.9.3 of an Action, or for an inoperable LTOP System for any other reason, were reformatted i and co!!ected into a single Acilon in the ITS.

3.4 A.18 The CTS requirement for an ANALOG CHANNEL OPERAT10NAL TEST o.- \ COT was (C) SR 3.4.12.5 4.9.3.1.a revised consistent with the new ITS Section 1.1, definition of the corresponding ITS (M) SR 3.4.12.6 i surveillance the CHANNEL OPERATIONAL TEST or COT which incorporates the key aspects of the ANALOG CHANNEL OPERATIONAL TEST. Any changes to the definition ction 1.1, are described in the Discussion of l which Changes for are thatthe result of the changes in[(ef;)

section.

3.4 A.19 Several CTS surveillance requirements have been combined into one ITS survelliance SR 3.4.12.1 4.1.2.3.2, 4.1.2.4.2, requirement. 4.5.3.2 (M) 4.4.9.3.3 3.4 A.20 The CTS interval for verification that the RCS vent is property maintained has been (C) SR 3.4.12.3 4.4.9.3.2 reformatted from an SR and footnote, to a SR with two Frequencies. The intervals (M) SR 3.4.12.4 ,

retained in ITS remain the same.

3.4 A.21 The CTS requirements regarding the RCS Controlled Leakage have been moved to a 3.5.5 3.4.6.2.e and separate ITS specification for Seal injection Flow. 4.4.6.2.1.c - t 3.4 A.22 The CTS requirements regarding the RCS Pressure Isolation Valves and RHR interlock 3.4.14 3.4.6.2.f 3.4.6.2 have been moved to a separate ITS specification for RCS Pressure Isolation Valve (PlV) section c 4.4.6.2.2, Leakage. and 4.5.2  ;

(C) Catawba specific  ;

(M) McGuire specific Catawba and McGuire Nuclear Stations 3

,,1-- .--evs: * *e m ---a m-- war--+i--vT +- e '- - -

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM

1. W '

< M4, . .

(DISCUSSIONk 4OKCl4ANGES Yg* #pWM3

[ g{k M [ N k [ [ [A[ [+ 2

SUMMARY

,OF.CHANGEP 1 , W[GF[g kAf . 2Q

>ITS REQUIREMENTO

,t

> CTS REQUIREMENT!

3.4 A.38 The CTS requirements for a radiochemical analysis of the reactor coolant to determine SR 3.4.16.3 Table 4.4-4 E-bar has been reformatted to match the ITS presentation of this information. The change re-organizes the requirements but does not include any technical revisions.

3.4 A.39 The detailed information in the CTS table describing the analysis for E-bar has been 3.4.16 Table 4.4-4 deleted. This information is redundant to the Definition for E-bar in ITS Section 1.0.

3.4 A.40 The LCO requirement in CTS to maintain all RCS loops in operation has been explicitly 3.4.4 3.4.1.1 clarified to read "Four RCS loops shall be OPERABLE and in operation." The addition of the word OPERABLE is consistent with the existing plant interpretation of this requirement, i.e. the RCS loops including the steam generators must be OPERABLE.

3.4 A.41 (C) The name of the sump monitor in the CTS has been changed to delete reference to " flow." 3.4.15 3.4.6.1 This chartge clarifies that this monitor is a level monitor in the containment floor and equipment sump. Leakage rate or flow is actually calculated by a rate of change in level using the plant computer.

3.4 A.42 The CTS requirement that the reactor coolant DOSE EQUIVALENT l-131 s 1.0 pCi/gm be SR 3.4.16.2 Table 4.4-4 verified following power changes > 15% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when in MODES 1,2, and 3 was revised to only require this verification in MODE 1. This change is based on the intent of the surveillance to ensure lodina remains within limit during normal operation and following fast power level changes when fuel failure is more likely to occur. Power level changes

>15% cannot occur in MODES 2 and 3.

3.4 A.43 (M) The CTS Actions that take exception to declaring the PORVs in_ operable due to inoperable 3.4.11 Required 3.4.4 Actions e, f, and block valve actions which require disabling the PORV were (etain_ edin]he ITS Actions for Actions B.I and B.2 g l one block valve inoperable. This exception is not necessary for two o three block valves inoperable since the actions do not require disabling the PORV for th se subsequent inoperabilities, k

ru)o ww/s (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 6

_ - - _ - - . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - - _ - _ - _ - _ . _ _ _ _ . _ . _ _ _ _ _ _ _ - _ _ . .-_ ~

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.7 PLANT SYSTEMS , 7%e i gg&@@Q t eJL .' .f '.;i.? m' A:rg i. W ' ..( % J b n _ . l-n '%

gg@h(: ' ~ 'Sh dMb hbbdh 14 5,hh[c V4%idddEE . . JIJF.Jtid@!%El46PW CthidicdtiiWAlf 3.7 A.34 (C) The CTS surveillance requirement for the control room and nearby area temperature was 3.7.11 3.7.6,4.7.6 a.

revised into a separate LCO for" Control Room Area Chilled Water Systems (CRACWS "

The creation of a new LCO for this requirement is a change in format and presentatio, the l.

limits and intent of the CTS SR were retained.

3.7 A.35 (C) The CTS Action requirements for inoperable ventilation system heaters were reformatted 3.7.12 Action C 3.7.7 Action b consistent with the ITS method of referencing a special report contained in Section 5.0 instead of stating the reporting requirements in the Action. The technical requirements of ,

the Action were retained.

3.7 A.36 The CTS Actions and Surveillance Requirements for the testing of ventilation filters in (C) SR 3.7.12.2 3.7.7 ,

accordance with Regulatory Positions and ASTM codes have been moved to the (M) SR 3.7.11.2  :

Programs section of the ITS Chapter 5.0," Administrative Controls". The applicable ITS r SR is constructed to require the testing in accordance with the Ventilation Filter Testing Program as described in Chapter 5.0. No technical changes to the requirements were made. '

3.7 A.37 The CTS SR requirement for pn actuation test signal to be used during testing was revised (C) SR 3.7.12.3 4.7.7 d.2 to a!Iow an actual, as well as a simulated test signal, to meet the Surve3ance Requirement (M) SR 3.7.11.3  ;

in ITS. The acceptance criteria of the survei!!ance remains unchanged and unaffected by i this revision.

3.7 A.38 The CTS Action requirements for the Control Room Area Ventilation in Modes 1,2,3, and Action E 3.7.6 4 were revised by the addition of an Action to enter LCO 3.0.3 with the loss of 2 (C) 3.7.12 CGACWS trains. This addition does not change the CTS which implicitly required the (M) 3.7.11

' ame Action. ,

3.7 A.39 The CTS requirement for the Operable Fuel Handling Ventilation Exhaust System (C) 3.7.12 4.9.11.1 .

(HVES) to be operating has been reformatted in the ITS LCO and stated as one train of (M) 3.7.11  !

FHvES shall be Operable and in operation. The change maintains the technical requirements of the CTS.

I (C) Catawba specific (M) McGuire specific s Catawba and McGuire Nuclear Stations 6 ,

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS p } $

F f' -

3.8 A.1 The CTS have been reformatted and renumbered in accordance with the STS. As a 3.8 3/4.8 result, the TS are easier to read and understand by plant operators as well as other users.

The reformatting, renumbering, and rewording process serves only to clarify the CTS requirements and involves no technical changes to the CTS.

3.8 A.2 The requirement for the automatic load sequencers for Trains A and B is added to the CTS LCO. The OPERABILITY of the sequenc .s is required by the SRs in CTS 4.8.1.1.2 LCO 3.8.1 @ l to demonstrate OPERABILITY of the diesel generators. Therefore, this change only yfgg clarifies the CTS operability requirements. M /*SM*8 N 3.8 A.3 The CTS action requirement to periodically (within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter) 3.8.1 Required 3.8.1.1 Action b.1 demonstrate the OPERABILITY of the remaining AC efectrical power sources when one Actions A.1 and B.1:

offsite circuit and one diesel generator (DG) are inoperable is retained in the individual ITS and Action D Actions for an inoperable offsite circuit and for an inoperable DG. In accordance with ITS Section 1.3," Completion Times,"the ITS would require entering both these Actions and thus require perfoming the verification at the specified frequency, if the condition of an inoperable offsite circuit and DG existed. Thus the specific Action for this conditon, Action D, need not explicitly contain this CTS action requirement.

3.8 A.4 Not used.

3.8 A.5 A Note was added to CTS Actions to clarify that entry in the applicable Conditions and 3.8.1 Action D Note 3.0.1 Required Actions of ITS LCO 3.8.9," Distribution Systems - Operating" is required for any 3.8.1.1 Action b train that becomes de-energized with the loss of an offsite circuit and a DG. This change is administrative because the note reflects the CTS 3.0.1 requirement to meet the associated action requirements fo LCOs that are not met -in this case the action requirements for any denergiz'e a istribution bus. This note is needed because the ITS /

contains a new provision, LCO 3. .ti, which would only require entering the Actions of ITS 3.8.1. The ITS 3.8.1 Note to Action D which requires entering ITS LCO 3.8.9 is an exception to ITS 3.0.6 See Table f[, DOC 3.0-M.3 regarding ITS LCO 3.0.6.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 1

i i

TABLE A- ADMINISTRATIVE CHANGES i

. SECTION 3.8 ELECTRICAL POWER SYSTEMS G$k -

.. 41 m1R

' ~

"h- aja '

sth 6 3.8 A.11 Three ITS SR Notes were added to the CTS SR. The Notes maintain the iechnical SR 3.8.1.2 4.8.1.1.2.a,4 [

requirements of the CTS and only represent a change in presentation and format to A conform with the ITS style. /

]

3.8 A.12 The CTS SR clarification for an engine prelube prior to a DG start was reformatted into an 3.8.1 SRs involving 4.8.1.1.2.a.4 r ITS note used in each applicable ITS SR consistent with manufacturer recornmendations. diesel generator starts 3.8 A.13 The information contained in the CTS SR footnote was reformatted into two ITS style notes SR 3.8.1.3 4.8.1.1.2.a.5 footnote and applied to the corresponding ITS SR. The ITS SR Notes represent a change in presentation to conform to the STS and maintain the technical requirements of the CTS. I .

Therefore, this change is administrative.

3.8 A.14 The CTS requirement to perform certain SRs "during shutdown" (Modes 5 and 6) has been (C) SRs 3.8.1.11, - (C) 4.8.1.1.2.g.4, 6,7,  ;

reformatted into an ITS note which prohibits testing with the reactor at power (Modes 1-4). 3.8.1.13,3.8.1.14, 9,10 and 4.8.1.1.4 d

, The ITS language is equivalent, thus this change is administrative. 3.8.1.16,3.8.1.17,  !

3.8.1.19 and 3.8.4.8 (M)SR 3.8.1.11, (M) 4.8.1.1.2.e.4, 6, 3.8.1.16,3.8.1.17, 10, and 11 ,

and 3.8.1.19 t 3.8 A.15 The CTS surveillance requirements for DG operation were revised to include an ITS note (C) SR 3.8.1.14 and (C) 4.8.1.1.2.g.7 and which indicates that momentary transients outside the load and power factor ranges do not 3.8.1.15 4.8.1.1.2.g.15 [

i invalidate the test. This change is considered a clarification of the existing requirements I since it is not considered to alter the overall technical requirement to operate the DG (M) SR 3.8.1.14 (M) 4.8.1.1.2.e.8  !

loaded for the specified period. Therefore, this change is administrative. footnote i 3.8 A.16 Not used. .

! I i

I (C) Catawba specific  !

(M) McGuire specific  ;

Catawba and McGuire Nuclear Stations 3

. - . . - . - , ~ ~ . . . - _ . . - _ _ - . - - . - _ . _ _ _ . . - . - - . __ _ _ - -_- _ ___-__-___- - - ___

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS H Ni . [ . p tirm. .L [ ,

i m ;g! , i l 3.8 A.25 (M) The CTS action requirement that the RCS must be depressurized and vented within 8 3.8.10 Required 3.8.1.2 Action hours through?a 4.5 square inch vent was revised to require a vent size of 2.75 square . Action A.2.6 inches. This change corrects an error in the CTS. As a part of a license amendment dated March 29,1995 and approved by the NRC as Amendment 162/144 on January 11, 1996, the correct RCS vent size for overpressure protection is 2.75 square inches. This requirement with the correct vent size is sjso reformatted to conform with the STS.

3.8 A.26 The CTS requirement for the Fuel Storage System was used as the basis for new separate 3.8.3 3.8.1.1 b. 2) specification, ITS3.8.3," Diesel Fuel Oil, Lube Oil and Starting Air" Currently, the fuel oil and the starting air subsystems are evaluated for DG OPERABILITY, but are not explicitly specified in the CTS sources LCO. The addition of the new requirements for these 1ti5 systems maintain @s the current interpretations for required DG subsystems. Thus, this change is administrative.

3.8 A.27 A Note was added to the DG support system requirements to allow separate Action 3.8.3 Actions 3.8.1.1 Actions -

Condition entry for each DG. The addition of the ITS Note does not modify current requirements and is therefore an administrative change.

3.8 A.28 An Action was added to the CTS DG support system requirements that requires the DG to 3.8.3 Action F(C) 3.8.1.1 l be immediately declared inoperable if Required Actions and associated Comp!etion Times of the support system Actions Conditions are not met. The addition of the ITS Action does g,g,g4Q gg not modify any technical requirement and is therefore an administrative change.

3.8 A.29 The CTS requirements for sampling of new and stored DG fuel oil have been moved to SR 3.8.3.3(c) (C) 4.8.1.1.2.e and l Section 5.0, Administrative Controis. The corresponding ITS SR refers to the 5.5.13 4.8.1.1.2.f.

requirements in Section 5.5.13 but does not modify any technical requirement. sg 3,g,3,pg (M) 4.8.1.1.2.c and 4.8.1.1.2.d.

3.8 A.30 Not used. l 3.8 A.31 (C) The CTS battery requirements were combined with the CTS diesel generator's battery 3.8.4 3/4.8.2.1 and charger requirements and reformatted into the ITS LCO for the DC sources required 3/4.8.1.1 for Modes 1 through 4. This change in presentation is administrative.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 5

L TABLE A- ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS '

I ...-. _ .. _. _._ . _ _ ..._. _ _ _ _ _ __ _ _. _ _ _ _ _ __._ _ _.. _ _ _ _i_ _ _._ _ i _ _ {

In the event either battery EBA or EBD inoperable, CTS 3/4.8.2.1 Action d allows to days  ! 3.8.4 Action A l 3.8.2.1 Action d 3.8 A.47 (C) to restore the battery to operable status provided the associated DG (DGBA or DGBB) DC subsystem powers the associated DC train subsystem (EDE or EDF bus). This action requirement was reformatted, consistent with the STS as ITS 3.8.4 Action A. It maintains the requirement to supply DC power from either the DC channel or the DG DC subsystem.

In the event the DG DC subsystem is also inoperable, ITS 3.8.4 Action D requires 3.8.4 Action D 3.8.2.1 Action a j

immediately entering the applicable Condition (s) and Required Action (s) of ITS LCO 3.8.9,

" Distribution Systems-Operating'. ITS 3.8.9 Action D would allow 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the DG DC subsystem. This is the same time allowed by CTS 3/4.8.2.1 Action a for an inoperable DG DC subsystem. Therefore, the ITS action requirements represent an administrative reformatting of the CTS action rerquirements.

The CTS SRs have been combined and reformatted to form a single ITS SR. The ITS SR SR 3.8.9.1 (C) SR 4.8.2.1.2 and 3.8 A.48 1.8.3.1 maintains the technical requirements of the CTS.

(M) 4.8.2.1.1 and 4.8.3.1 I [ 3/4.8.3.1 k Portions of two(CTSshkicationhere reformatted and used in the new ITS specification 3.8.9 3.8 A.49 3/4.8.2.1 for " Distribution Systems - vperaung". No technical changes were made to the CTS requirements.

i The CTS specification is reformatted into the iTS specification for Distribution Systems l 3.8.10 l3/4.8.3.2 3.8 A.50 during shutdown. The technical requirements of the CTS are maintained. l l t 3.8 A.51 Not used. l l Two CTS SRs are combined and reformatted to form a single ITS SR. The technical l SR 3.8.10.1 l 4.8.2.2.1 and 4.8.3.2 i' 3.8 A.52 requirements of the CTS are maintained. l l i

i t I

(C) Catawba specific  ;

(M) McGuire specific {

8 Catawba and McGuire Nuclear Stations

.. - _ _ , . -.,._,-.,.,._m. .__...x - _~ ., m. - _ , , .-_mm.. _ . . -

I TABLE A- ADMINISTRATIVE CHANGES  ;

SECTION 3.8 ELECTRICAL POWER SYSTEMS i FNiiiNisisA51T 9MWus FuiP 3.8 A.53 (C) The CTS cctions requirements in the event one or more required electrical distribution l 3.8.10 Required l 3.0.3.2 Actions l subsystems are inoperable were revised by the addition of new ITS action requirements. Action A.1

'This' hf s ITS 3.8.10 Required Action A.1 requires immediately declaring inoperable associated 5till' nder talf - supported featuresfLii4ii5 w.av_wmanuwwauisas wusisianiWitMithBfcidrenI7 l rsVI .

Icterci-vu.oune:vidf #>5ert aWacAct/

Attematively, the operators may follow ITS 3.8.10 Required Action A.2. Required Actions 3.8.10 Required

• j A.2.1 through A.2.4 specifically retain the remedial measures speciifed in CTS 3/4.8.3.2 Actions A.2.1 - A.2.4 Actions.

fi5 addition equired Action A.2. quires immedjately declari f3.8 R  !

e associlsetIRH ir su inoperable and n operation. nsed JiBEthMCOMBIsten '

'on .5 hj.bs sWlfiihflutmppmuu, a gd rese/ 47 uvised af.f 7)

Finally, Required Action A.2.6 requires immediately declaring affected LTOP features 3.8.10 Required inoperable. See DOC 3.8 - A.60 to see why this is consistent with the CTS action Action A.2.6 ,

requirements. .

)

The"chshges'c66tilded InlTS 3.800ActT6PilAi!Iri[fdminis?It!NFd6sDiiistfis"ne*Telf6ti l

~

techhi6alftfahbehRth@)tfijEll5df]KnCUigrequirem'ents'afe'c6hsistehtWittfthT8tifftmfifftBfpfl!!!Att6ffMlfR gfis 3.8 A.54 (M) The CTS note which allows, during period of station modifications, a one time exception 3.8.4, 3.8.7 3.8.3.1 and 3.8.2.1 I for up to 112 hours0.0013 days <br />0.0311 hours <br />1.851852e-4 weeks <br />4.2616e-5 months <br /> for CTS 3.8.3.1 and 30 d for batteries reolacement was deleted. The applicable modifications for CTS plet $3.8.2.1, pem ire acomWhlM J QpergDsxflicense arDimument tssgs6g Lie ITJ;)thus e ex %n provided by the note is f

i no longer required. ,y Qr6 i 3.8 A.55 (C) Two CTS Actions for an inoperablehurce were reformatted and combined into one 3.8.4 Action A 3.8.2.1 Actions e and l  !

ITS Action. The technical requirements of the CTS are maintained. b  ;

3.8 A.56 (M) The portion of the CTS table for High Specific Gravity cells was deleted. This type of cel! Table 3.8.6-1 Table 4.8-3 was replaced and that part of the CTS Table is no longer applicable to the plant design. '

k (C) Catawba specific (M) McGuire specific Catawta and McGuire Nuclear Stations 9

L i

i 1.

1 Insert 3.8 A.53 (C)

The CTS definition of OPERABILITY requires the normal or emergency power source, therefore, if the bus were deenergized, the supported equipment would be considered inoperable. The addition ofITS 3.0.6 would not specifically require the actions of supported equipment be taken, therefore this action maintained this option.

4 l

l l

t Catawba and McGuire Table A 3.8 DRAFT SER l.

l' e

i l

TABLE A- ADMINISTRATIVE CHANGES (MDYO 64 SECTION 3.8 ELECTRICAL POWER SY (6j56b55idNi SMf3Wf% %i-  : W 1 J$i VlS W $E id5CHAf(GIN EDhIk h[MCf B+ & - ':ld -sdMgMWepckfAdgL:

J l -- J % .c f d % [C M W 'i gNcerhyWi;lyi M;1: cat;w j 3.8 A.57 (M) Th TS LCO note which provides conditions when an inverter mp[Je disconnected from 3.8.4 Required . 3.8.3.1 Note f g/ its c ource for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,if CTS 3.8.2.1 Action b is satisfiedWas deleted. The CTS Action A.2 7 note is redundant to the Actions contained in the corresponding ITS specification.

3.8 A.58 (M) ' The CTS Action which allows continued operation with an inoperable de source for 72 3.8.4 Action A 3.8.2.1 Action b.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided the associated bus tie breakers are closed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was reformatted consistent with the corresponding ITS Action but maintains the technical content of the CTS.

3.8 A.59 Not used.

3.8 A.60 (C) The CTS Action requirements for the condition of less than the minimum required sources 3.8.10 Action A.2.6 3.8.1.2, 3.8.2.2, and Operable that require the RCS to be depressurized and vented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> through a - 3.4.12 Actions 3.8.3.2 Actions 4.5 square inch vent was retained and reformatted consistent with the ITS. 5B5Ei!IedN9) io ble $ 1i i u M OVC ,

change maintains the technical requirements of the CTS, and is administrative. Sfiadfog 3.8 A.61 Not used.

3.8 A.62 Not used.

3.8 A.63 Not used.

3.8 A.64 Not used.

3.8 A.65 Not used.

3.8 A.66 (M) The CTS footnote which states," Required for both Units 1 and 2" and the CTS action 3.8.10 3.8.3.2.c footnote

• which also states that it applies to both units are clarifications that were deleted. The deleted clarifications were applicable to shared systemsend necesyary wnen botpung (15 wer3,e6mbined. UcepseEfd;tt4ise cofHisptwiiG Cyrunipt wTor Detnyffits! /

~ , - , ,

)

@ 4 00 3,0,2 and S q S.0,5 sfah Maf LCOs asW (C) Catawba specific (M) McGuire specific Sks aylf b LAC ll UMl lnll'Yl Wd j NM >

yfsp .fooff,ofg ,5 ,gggg}gg( ,,,) ,,p ,ygggg$p ,

Catawba and McGuire Nuclear Stations 10

TABLE A- ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS -

wsa a w:2x1 Bra w wnmv etw 3.8 A.67 ' The CTS Actions were clarified to require ITS LCO 3.0.3 to be entered immediately if two 3.8.9 l 3.8.3.1 and 3.8.2.1 or more of the required buses or channels are inopera and a loss of safety function 3.0.3 exists, consistent with the rules of usage of the ITS. us s an administrative change }

because in this condition the CTS would require a unit s down consistent with CTS 3.0.3. TAI 5 3.8 A.68 The CTS inverter requirements for Modes 5 and 6 are reformatted into the ITS 3.8.8 3.8.3.2 specification for the inverters during shutdown. The CTS LCO statement was clarified to LCO 3.8.8 indicate that whenever a second AC vital bus distribution system is required operable by ITS LCO 3.8.10, the distribution system need only be energized (inverter or regulated voltage transformer) consistent with current requirements and the definition of operability.

1 .

i (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 11

i TABLE A- ADMINISTRATIVE CHANGES SECTION 5.0 ADMINISTRATIVE CONTROLS '

5.0 A.10 Not used.  !

5.0 A.11 The CTS reactor coolant pump flywheel surveillance requirements were moved to the ITS 5.5.7 4.4.10 Administrative Controls as the " Reactor Coolant Pump Flywheel Inspection Program."

5.0 A.12 The annual report submittal date in the CTS as a separate requirement is omitted from the 5.6.1 through 5.6.7, 6.9.1.4 i ITS because the individual reports described in the CTS and retained as ITS have been except 5.6.4 i modified to include the required submittal dates.

! 5  :

The submittal date for the Occupational Radiation Exposure Report is revised from March 5.6.1 6.9.1 1 to April 30. This change in submittal date is administrative because it does not change l any CTS restrictions on plant operation.

5.0 A.13 The CTS Surveillance Requirements for inspecting the Steam Generator Tubes were 5.5.9 4.4.5.1 through moved to the ITS Administrative Controls section as the ' Steam Generator Tube 4.4.5.5. t Surveillance Program."

l 5.0 A.14 The CTS Surveillance Requirements for the following ventilation systems were moved to 5.5.11 McGuire - 4.6.1.8.b.1, .i the Administrative Controls section as the,' Ventilation Filter Testing Program (VFTP)." b.2, c, d.1, d.5; ,

. 4.7.6.c.1, c.2, d, e.1, t i Annulus Ventilation System; e.4; 4.7.7.1.a.1, a.2, ,

Control Room Area Ventilation System; b, c; 4.9.4.2.a.1, a.2, Auxiliary Building Filtered Exhaust System; b, c; and 4.9.11.2.a.1, i Reactor Building Containment Purge System; and a.2, b, c.1.

Fuel Handling Ventilation Exhaust System i Catawba - 4.6.1.8.b.1, t b.2, c, d.1, d.5; 4.7.6.c.1, c.2, d, e.1, e.4; 4.7.7.b.1, b.2, c, j d.1, d.5; 4.9.4.2.b.1, l b.2, c, d.1, d.2; and  !

4.9.11.2.b.1, b.2, c, d.1, d.4 i

I (C) Catawba specific (M) McGuire specific  !

Catawba and McGuire Nuclear Stations 2 i

. _ _ _ . . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ ____ _ _ _ . _ _ _ _ _ _ _ . . . _ . . . _ . . _ - . _ . . _ _ _ . . _ . . . . _ _ _ . . . . ~ . . . _

TABLE M -MORE RESTRICTIVE CHANGES SECTION 3.3 INSTRUMENTATION ,

i h  ;

3.3 M.6 The CTS ActionTo-r Turbine Trip-Low Emergency Trip Fluid Pressure (Interlocked with P-9) 3.3.1 S 3.3.1 Action 6.a" m/

and 11 for Turbine Trip-Turbine Stop Valve Closure requires an LCO 3.0.3 entry if an

[ M /045 O u // f' inoperable channel cannot be placed in trip in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. LCO 3.0.3 requires THERMAL [

POWER to be reduced to < P-9 within the following 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The time allowed by this CTS  !

i Action was reduced by three hours in the corresponding ITS Action. j 3.3 M.7 The CTS Action for Reactor Trip System Interlocks requires entry into LCO 3.0.3 if one 3.3.1 3.3.1 Action 8 channel is inoperable and the interlock cannot be verified in the required state for the -l existing unit conditions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This CTS Action was revised consistent with the ITS  !

to require either the plant be placed in mode 2 or 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, depending on the i applicability of the interlock. This change is slightly more restrictive because it reduces the time limit to get outside the mode of applicability by one hour.

3.3 M.8 The CTS Actions that allow an RTB to be bypassed for maintenance on the undervoltage (C) 3.3.1, Action O 3.3.1 Action or shunt trip mechanisms were revised by the addition of a two hour RTB bypass time limit (M) 3.3.1, Action R statement 12 l 4

for maintenance on the undervoltage and shunt trip mechanisms.

3.3 M.9 (M) The CTS Action requires shutdown margin to be verified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 12 3.3.1 Action L' 3.3.1 Action 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> thereafter when the only required source rcnge neutron flux monitor becomes  ;

inoperable. This CTS Action was revised by the addition of requirements to suspend all I operations which involve positive reactivity additions immediately and to close all unborated water source isolation valves within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.  !

3.3 M.10 (M) The CTS RTS surveillance requirements were revised by the addition of a requirement to SR 3.3.1.13 CTS Table 4.3-1 perform a channel operational test for the Reactor Trip System Interlocks.

3.3 M.11 If the CTS ESFAS Action requirements are not met an LCO 3.0.3 entry is required. This 3.3.2 ' Tab!e 3.3-3 Actions  ;

CTS convention is revised by the addition of a specific ITS Action to require the unit to be 15,15a (C).15b (M),  !

in mode 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and, if applicable, mode 4 within the following 12 16,19, and 20 i hours if the Actions are not met. This change is slightly more restrictive, because with the  !

CTS LCO 3.0.3 requirement, one additional hour is allowed prior to beginning the  !

shutdown. .

i (C) Catawba specific i

- (M) McGuire specific f Catawba and McGuire Nuclear Stations 2

_ _ - - _ _ - __-___- _ _ _ - _ _ -- _ _ _ _ _- . ~. .. ___ .._ __ _ - _ _ - .. _ _ - _ _ _ __ ___

TABLE M- MORE RESTRICTIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM (RCS) i %f6fkN _3G WIT!BVtFil W4 IF 4%5 L.WWE 3.4 M.15 Not used.

3.4 M.16 Not used. l 1

l l l 3.4 M.17 The Frequency of the CTS SR to verify all but one charging pump is inoperab!e was SR 3.4.12.1 4.1.2.3.2 and ,

changed from 31 days to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; the language of the CTS SR was also replaced with 4.1.2.4.2  ;

equivalent language. ITS SR 3.4.12.1 states " Verify a maximum of one charging pump is ,

capable of injecting into the RCS."

3.4 M.18 CTS Action a allows up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one, two, or three Inoperable coolant loops 3.4.5 Action A and 3.4.1.2 Action a and to Operable status. Corresponding ITS 3.4.5 Action A only allows the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the Required Action D.3 Action c condition of one or two required RCS loops inoperable. If three loops are inoperable, ITS 3.4.5 Required Action D.3 requires immediately taking action to restore one RCS loop to Operable status, which is more restrictive for a third concurrently inoperable RCS loop. [

3.4 M.19 Not used. l l l  ;

3.4 M.20 in the event the containment floor and equipment sump monitoring system is inoperable, 3.4.15 Action A the CTS allows continued operation for up to 30 days. The ITS retains this allowance but l 3.4.6.1 Action l

adds the conditional action to perform a precision water balance of the RCS once per 24 l hours in accordance with ITS SR 3.4.13.1 during this 30-day period. ~

l i

h.4M.21 The restri range of operation region in CTS . .5 Figure 3.2-1 has been ted. !3 .4.18 igure 3.4.1-1 3/4.2.5 Figure 3.2-1 Theref , plant operation in Mode 1 is no lo r allowed with reactor co ystem flow I be 382,000 gpm, regardless of the owerlevel. This change w ade because

. e restricted range of operation is n nger supported by the existi safety analysis i described in LER 97-10 for M , e Nuclear Station and LER 97 for Catawba N ar  !

Station. gotemnigyuauveppu.vgu Otem.Psuuin9hana=JmSUnelevisealipigure 3 M 01 / /

/ -

W8/}SC,g)ffgpfffQf

~

'IO b [A #f/Y  ;

(C) Catawba specific (M) McGuire specific t

Catawta and McGuire Nuclear Stations 3

TABLE M- MORE RESTRICTIVC CHANGES SECTION 3.7 PLANT SYSTEMS i

3.7 M.1 Not used.

3.7 M.2 (M) The CTS Action to place the plant in Cold Shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> was revised to require 3.7.1 3.7.1.1 the plant to be brought to MODE 4 (outside the Applicability) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3.7 M.3 The exception in the CTS MStV Applicability in Modes 2 and 3 wa3 rcvised by the addition 3.7.2 3.7.1.4 of a restriction requiring that inoperable MSIVs be de-activated as well as closed.

3.7 M.4 The CTS Actions to close an inoperable MSIV in MODE 2 and 3 were revised by the 3.7.2 Action C 3.7.1.4 addition of an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit to close the valve and a requirement to verify the MSIV closed once per 7 days.

3.7 M.5 The CTS Plant Systems Section was revised by the adi'Mn of a new LCO containing 3.7.3 3.7 requirements for the Main Feedwater Control Vaives (MFCVs), Main Feedwater Isolation l

Valves (MFIVs), their bypass valves and the(temperindalves The new ITS requirements add an LCO, as well as the associated Actions, ana Smveii an Re fl valves. &quirement for theTQp) m, ]

p gg , g g 7 7 /g B y, 4_SS V4fycS[g) )

3.7 M.6 (M) The CTS Plant Systems section was revised to include specific hirems5ts for the 3.7.4 3.7 Steam Generator Power Operated Relief Valves (SG PORVs). The new requirements include a new LCO, Actions, and Surveillance Requirements for these valves.

3.7 M.7 The CTS requirements for AFW were revised to include requirements to ac' dress the 3.7.5 3.7.1.2 condition where a steam generator is being required for heat removalin Mode 4. In this condition, an Operable AFW train must be available to supply a source of makeup water to the required steam generator. This change represents new operability requirements for the AFW.

3.7 M.8 The CTS Action were revised by the addition of a new Actions Condition which requires 3.7.5 3.7.1.2 the restoration of the affected trains within 10 days from discovery of failure to meet the requirements of the LCO. This addition represents a new restriction on plant operation.

(C awba specific (M) f,cGuire specific Catawba and McGuire Nuclear Stations 1

TABLE M- MORE RESTRICTIVE CHANGES SECTION 3.7 PLANT SYSTEMS u *

.LE -

3.7 M.9 (C) (Unit 1 only) The CTS Plant System Section was revised by the addition of a new 3.7.6 3.7 specification for the Condensate Storage System. The new ITS LCO includes a survelliance to periodicaffy verify required inventory and action requirements to restore the inventory to within the limit within 7 days or commence a plant shutdown .

3.7 M.10 Not used.

3.7 M.11 The CTS Applicability was revised by the addition of "during movement of irradiated fuel (C) 3.7.10 3.7.6 assemblies" Other related changes involve actions to alieviate these potential hazards (M) 3.7.9 with various levels of Control Room ventilation degradation. This change imposes new restrictions on plant operation.

3.7 M.12 (C) The CTS CRAVS LCO is revised by the addition of a new Surveillance Requirement that SR 3.7.10.3 3.7.E requires the CRAVS trains to be started on a simulated or actual actuation signal once per 18 months.

3.7 M.13 Not used.

3.7 M.14 Not used.

3.7 M.15 The CTS CRAVS Applicability is revised by the addition of "during movement of irradiated (C) 3.7.11 3.7.6 fuel assemblies". This change imposes new restrictions on plant operation. (M) 3.7.10 3.7 M.16 Not used.

3.7 M.17 Not used.

3.7 M.18 The CTS requirement for the determination of DOSE EQUIVALENT l-131 to be performed (C) 3.7.17 4.7.1.3 once per 31 days whenever the gross radioactivity determination indicates concentrations (M) 3.7.16 greater than or equal to 10% of the allowable limit for radiolodines and once per 6 months whenever the gross radioactMty determination indicates concentrations less than or equal to 10% of the allowable limit for radiciodines was revised to simp equire the DOSE EQUIVALENT I-131 to be determined once per 31 days, regardiess of the gross radioactMty.

(C) Catawba specific (M) McGuire specific Cotawba and McGuire Nuclear Stations 2

i TABLE M- MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS i

. h 3.8 M.1 The CTS Actions were revised by the addition of a second Completion Time requirement 3.8.1 Required 3.8.1.1 Action a and for the retum of an inoperable AC source, either an offsite circuit or a DG, to OPERABLE Actions A.3 and B.4 status. In addition to the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirement, a 6 day limit from discovery of failure to Action c (C') d @t) {;

meet the LCO is added to limit the total time that the LCO is not met.

3.8 M.2 The CTS Actions were revised by the addition of an Action that requires declaring a 3.8.1 Required 3.8.1.1 Action e required feature inoperable in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when both offsite circuits and a required redundant Action C.1 feature are inoperable.

3.8 M.3 The CTS was revised by the addition of a new ITS Action. The new Action requires that a 3.8.1 Required 3.8.1.1 Action a redundant required feature must be declared inoperable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when one offsite Action A.2 circuit and a required feature are inoperable.

i

' 3.8 M.4 Not used.

• 3.8 M.5 The CTS surveillance requirement to perform a load rejection test on the DG and the CTS (C) SRs 3.8.1.9 and (C) 4.8.1.1.2.g.2, surveillance requirement for a DG be loaded and operated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were revised to 3.8.1.14 4.8.1.1.2.g.7 require that when the DG is paralleled with offsite power these tests must be performed at (M) 4.8.1.1.2.e.2,  !

a DG power factor of s 0.9. 4.8.1.1.2.e.8 3.8 M.6 The CTS surveillance for the DG was revised by the addition of a new requirement that the SR 3.8.1.12 (C) 4.8.1.1.2g 5) emergency bus be verified to remain energized from the (M) 4.8.1.1.2e.5 offsite source after the DG statt. \  !

3.8 M.7 The CTS requirement for testing both DGs with a simultaneous start once every 10 years SR 3.8.1.20 (C) 4.8.1.1.2.h '

was revised to include acceptance criteria for both p~ ANN $siovoitage and (M) 4.8.1.1.2.f frequency requirements.

~

3.8 M.8 Not used.

3.8 M.9 The CTS action requirements were revised by the addition of an ITS Action to declare 3.8.2 Required 3.8.1.2 i required features inoperable when no offsite power is available. This new Action Action A.1 establishes requirements on plant operation that did not previously exist.

3.8 M.10 Not used.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 1 t

i

'f I

TABLE M - MORE RESTRICTIVE CHANGES  ;

SECTION 3.8 ELECTRICAL POWER SYSTEMS t 4

~

3.8 M.11 Not used. ,

t

- 3.8 M.12 Not used. i 3.8 M.13 (C) Deleted the CTS action requirement which allowed continued operation temporarily in the 3.8.4 Actions 3.8.2.1 Action e .

event two 125 VDC batteries and/or their full-capacity chargers are inoperable. ITS 3.8.4 - LCO 3.0.3 does not include an Action for the condiiton of two or more channels of DC inoperable; thus ITS would requires immediately entering LCO 3.0.3 which requires a plant shutdown.

j 3.8 M.14 The CTS requirements for the batteries were revised by the addition of an ITS Action to 3.8.6 Required Table 4.8-3 I

! verify that the battery cell parhmeters are within the Category C limits every 7 days after Action A.2 the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verification.

3.8 M.15 The CTS oattery cell parameter requirements were revised by the deletion of the 3.8.6 Table 4.8-3, footnote /

tempers.urs compensation allowance from the float voltage limit of Category B parameter requirernents. This change also deletes an allowance to adjust the float voltage range.

Table 3.8.6-1 (6) (c), foo/ note (c7 N) t 3.8 M.16 The ClS Actions were revised by the addition of a second Completion Time requirement 3.8.9 Actions 3.8.2.1 Actions )

to lirr;t the time the LCO is not met. This additional requirement limits the time from 3.8.3.1 Actions  !

di'.covery of failure to meet the LCO to a total time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

f or. [

3.8 M i7 The CTS Applicability requirements for the AC or DC sources or inv rters in MODES S or 6 3.8.2 (C) (C) 3.8.1.2,3.8.2.2, I was revised to include "during movement of irradiated fuel assem ies." 3.8.5 and 3.8.3.2 t (M) The CTS Actions were also revised by the addition of the fo wing requirements to 3.8.8 (M) 3.8.2.2 or 3.8.3.2 - [

immediately: declare the affected required features inoperable, uspend Core Alterations, 3.8.10  ;

}

suspend movement of irradiated fuel assemblies, initiate action to suspend operations i involving positive reactivity additions, and initiate action to restore required equipment to ,

OPERABLE status. I For inoperable distribution systems, the ITS also added requirements for cascading to the  ;

applicable RHR LCO and declaring the affected LTOP features inoperable. (g)  !

3.8 M.18 Not used. -1 3.8 M.19 (C) The CTS DG requirements were revised by the addition of specific surveillance SR 3.8.3.2 and 4.8.1.1 requirements for the lubricating oil inventory and the starting air receiver pressure. 3.8.3.4

• I (C) Catawba specific (M) McGuire specific Catawba and McGuire Nu-lect Stations 2

i l

TABLE M- MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWCR SYSTEMS fu>p r20/($

, s

• 3.8 M.20 The CTS DG surveillance requirements were revised by the addition of d The Notes (C) SR 3.8.1.8 Notes 4.8.1.1.2 a.5 f require the performing the surveillance on only one diesel at a time and immediately (LQ SR 3.8.1.3 Notes

! following the performance of either ITS SR 3.8.1.2 or 3.8.1.7, without a shutdown of the diesel.

3.8 M.21 Not used.

3.8 M.22 (M) The CTS Applicability was revised by the addition the condition of " movement of irradiated 3.8.2 Applicability 3.8.1.2 Qlied6ftit]y f fuel assemblies." This change requires the necessary electrical equipment to be Operable whenever irradiated fuel assemblies are being moved.

3.8 M.23 (M) The CTS requirements that the DG fuel oil system contain 28,000 gallons of fuel in Modes SR 3.8.3.1 3.8.1.1.b.2 5 and 6 and 39,500 ga!!ons of fuel in Modes 1-4 were revised to require that the DG fuel oil 3.8.1.2.b.2 system contain 39,500 gallons of fuel whenever the associated DG is required operable, including during Modes 5 and 6.

3.8 M.24 The CTS surveillance requirement to start the DG within 5 minutes after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - SR 3.8.1.15 (C) 4.8.1.1.",g.15 was revised by the addition of a requirement to verify steady state voltage and fregt <~f (M) 4.8.1.1.2.e.8 during the restart test.

3.8 M.25 (C) The CTS requirements for the DG were revised by the addition of specific DG lube oit 3.8.3 3.8.1.1 requirements (SR and Action). This change represents an additional restriction for plant operation.

3.8 M.26 (C) The CTS requirements for the DG were revised by the addition of specific OG air start 3.8.3 3.8.1.1 pressure requirements (SR and Action). This change represents an additional restriction for plant operation.

3.8 M.27 The CTS notes which provided allowances regarding disconnecting a vital bus from its DC 3.8.7 3.8.2.1 source for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and for disconnecting an inverter during a battery equalizing charge 3.8.9 3.8.3.1 were deleted.

3.8 M.28 (M) Deleted the CTS allowance for testing of the battery capacity via a dummy load at a 440 3.8.4 4.8.2.1.2 d.2 amps for 60 minutes while maintaining the battery terminal voltage a 105 VDC.

(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 3

^

TABLE M- MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS

, en ;~, - .

e 3.8 M.29 If the requi a ources are inope le when the plant is in Mode 5 with the RCS loops not filled orin Mode 6 with waterlev less than 23 feet, the CTS requires immediately 3.8.2 Required Actions A2.4 and 3.8.1.2 Action  !)

initiating action to restore the requi a sources to operable status. This action B.4 I; requirement was revised to require these actions in Mode 5 or Mode 6 or during movement of irradiated fuel regardless of whether loops are not filled or water level is  ;

below 23 feet. The expansion of the applicability of the Actions is more restrictive.

3.8 M.30 The CTS limits for battery ceII specific gravity which specify that battery charging current Table 3.8.6-1 Table 4.3-8

• be less than 2 amps when on float charge were revised to limit the use of the float charge Note (c) footnote (b) ,

current for meeting specific gravity requirements to 7 days and to require that specific ,

gravity be measured prior to expiration of the 7 days.

I t

L

?

i (C) Catawba specific (M) McGuire specific j Catawba and McGuire Nuclear Stations 4 l

T

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.1 REACTIVITY CONTROL SYSTEMS

- - w - yn ww am m . - - n = ~ ~ - -

v: n-y fi i _em;g 14 iip'1MJ, * , afz DISCUSS!ON) ' ,x, . ; JITS? . . , c m; PCTS;b _.; f. . _ < 1

.OECHANGEn ^ c W ' E

SUMMARY

OECHANGEC.  % C~ .: REQUIREMENTS? 2 REQUIREMENTS? (CATEGORYi 3.1 L.1 The CTS LCO for " Shutdown Margin - T, greater than 200 'F' was revised by the addition of appropriate actions consistent with the associated surveillance 3.1.2 @

4.1.1.1.2 IV l requirement for performing an overall core reactivity balance. The new Actions to be taken in the event the overall core reactivity balance did not meet the survei!!ance requirement allow a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for re-evaluation of core design, safety analysis and a determination if the core is acceptable for continued operation. In addition, appropriate operating restrictions and surveillance requirements must be established or the plant is required to be placed in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.1 L.2 The CTS 4.1.1.3.b requirement that specifies a measurement of MTC at 300 ppm, SR 3.1.3.2 4.1.1.3.b 11 and if not within the limit, to continue the surveillance and measure MTC every 14 effective full power days (EFPDs) was revised by the addition of a note that allows the performance of the surveillance to be suspended if the measured MTC at the 60 ppm surveillance is less than the COLR limit.

3.1 L.3 Deleted the CTS action requirement to reduce the High Neutron Flux Trip 3.1.4 Action B 3.1.3.1 Action IV Setpoints to s 85% of RTP when a rod is not restored within alignment limits. c.3.d 3.1 L.4 Not used.

3.1 L.5 The CTS Surveillance requirement to verify shutdown rod insertion limits within 15 SR 3.1.5.1 4.1.3.5.a VII minutes prior to withdrawal of any control rods during an approach to criticality was deleted.

3.1 L6 The CTS Actions which address one shutdown rod not within insertion limits were 3.1.5 Actions 3.1.3.5 Actions IV revised to address one or more shutdown banks out of limit.

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Sunreillance Requirement (M) McGuire specific 11. Relation of Survei!!ance Frequency VI. Relaxation of LCO and Administrative Controls 111. Relaxation of Completion Time Vii. De!etion of Surveillance Requirement IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 1

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.3 INSTRUMENTATION k

3.3 L1 The requirement to reduce the power range neutron flux high trip setpoints is 3.3.1 Condition D 3.3.1, Action 2c IV deleted.

3.3 L.2 The CTS Action requirement for the Intermediate Range monitors between P-6 3.3.1, Condition F 3.3.1, Action 3.b IV and P-10 which specifies that an inoperable channel must be restored to OPERABLE status prior to increasing power above 10% was revised to require power to be adjusted to either below P-6 or above P-10 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

3.3 L3 The CTS requirements for the Intermediate Range Neutron Flux instrumentation 3.3.1, Condition H 3.3.1 Action 3.a . IV (when below P-6) to be restored to operable status prior to increasing THERMAL POWER above P-6 with one channel inoperable were revised to provide the same action when two channels are inoperable. CTS requires entry into 3.0.3.

3.3 L.4 The CTS requirements for the RTBs were revised by the addition of a one hour (C) 3.3.1, Actiot 3.3.1 Action Ill Completion Time to restore the RTBs to operable status. This one hour is in O. statement 9 addition to the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> currently allowed to be in mode 3. (W 3.3.1, Actior R

3.3 L 5 The CTS 3.3.1 S/U (startup) frequencies for the Power Range Neutron Flux Low, SR 3.2.t7 an:J Table 4.3-1 h.7C '[

Source Range Neutron Flux, and Intermediate Range Neutron Flux Channel SR 3.3.1.8 Operational Test requirements were revised from 31 days prior to startup to 92 days prior to startup.

3.3 L6 The requirement in the CTS for the AFW Pump Manual Initiation Function has Table 3.3.2-1 Tables 3.3-3,3.3- Vi been deleted. 4, and 4.3-2 3.3 L7 (C) The requirement in the CTS for the Turbine Trip Manual Initiation Function has Table 3.3.2-1 Tables 3.3-3,3.3- Vi been deleted. 4, and 4.3-2 3.3 L8 The CTS Completion Time of 7 days for an inoperable channel of post accident 3.3.3, Condition 3.3.3.6 Action a[M)til monitoring (PAM) instrumentation was revised to 30 days. B ,@

v k I (C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement 3.3.M Actoon a.0/c (C)  !

(M) McGuire specific 11. Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls

• lit. Relaxation of Completion Time Vll. Deletion of Surveillance Requirements i IV. Refaution of Required Actions Vllt. Deletion of Requirements Redundant to Regulations }

Catawba and McGuire Nuclear Stations 1 t

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.3 INSTRUMENTATION ,

DISCUSSION:

~

• 7_ @gggh 3 3fMj[ _ jMhhMNSEM[

1c#he ((50MMARY,OECHANGEW tJ+

^_~ A M ITS$ [ U [$CiS2c [J i' $

.OE CHANGE - -

. a :REQUIREMENTSE !REdOIREMEN(TS3 lCATEGORYj 3.3 L.9 The CTS requirements for inoperable PAM channels that specify a unit shutdown 3.3.3 Conditions 3.3.3.6 Action a IV when one required channelis inoperable and the actions cannot be completed C and H and 3.6.4.1 Action were revised to a!!ow continued operation in this condition for functions with two a required channels and to those with one required channel if the associated diverse channel or attemate monitoring method is operable provided a special reportis written to the NRC detailing the planned corrective actions. [FNh 3.3 L10 The CTS Completion Times (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) for inoperableh channels 3.3.3 Conditions 3.3.3.6 Action b Ill were extended to 7 days fc! all channels, except hydrogen monitors which were D, E, and F (M) 3.7.4.a extended from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

3.3 L11 The CTS requirements for the Hydrogen Monitors that specify a channel check SR 3.3.3.1 and 4.6.4.1 11 once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monthly analog channel operational test, and a channel SR 3.3.3.2 calibration 92 days on a staggered test basis were revised to require a channel check once per 31 days and a channel calibration once per 92 days. The channel operational test was eliminated.

3.3 L.12 The CTS requirement for the inoperable remote shutdown system instrument 3.3.4 Condition A 3.3.3.5 Action a Ill channels to be restored to operable status within 7 days was increased from 7 days to 30 days.

3.3 L.13 The CTS requirement for both the auxiliary feedwater flow and the steam Table 3.3.4-1 Table 3.3-9 Vi generator level as separate indication of Decay Heat Removal via the SGs was revised to allow the use of either one or the other indicators rather than both.

3.3 L14 (M) CTS PAM requirement for a CHANNEL CAllBRATION to be performed every SR 3.3.3.3 Table 4.3-7 V refueling was revised by 1 " addition of a Note allowing the neutron detectors to be excluded from the CHANNEL CAllBRATION.

(C) Catawba specific Categories: I. Relaxation of Applicability V. Relaxation of Surveinance Requirement (M) McGuire specific it. Relation of Surveifiance Frequency VI. Relaxation of LCO and Administrative Controls 111. Relaxation of Completion Time Vll. Deletion of Surveillance Requirements IV. Relaxation of Required Actions Vi!L Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 2

TABLE L-LESS RESTRICTIVE CHANGES SECTION 3.3 INSTRUMENTATION i

3.3 L20 (C) CTS Action requirement that the unit be in mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and mode 4 in the 3.3.8 Condition A 3.3.2, Action 21a Ill following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if one channel of the automatic actuation logic is inoperable was revised to increase the Completion Time for the ABFVES actuation instrumentation function to 7 daysh /

3.3 L21 Not used.

3.3 L22 (M) The CTS Actions that allow operation to proceed with one inoperable channel 3.3.2 Conditions Table 3.3-3 IV (placed in trip) until the next performance of the COT were revised by the addition D,J and P Actions 15 and of a note that allows the channel to be placed in bypass for surveillance testing on 15b other channels.

3.3 L23 (C) The CTS requirements for Diesel Building Ventilation support system operability 3.3.2 Table 3.3-3,3.3- Vi have been deleted in the ITS. 6 4, and 4.3-2 3.3 L24 The RTS CTS Action for an inoperable power range channel that requires power 3.3.1 Action D.1.2 Table 3.3-1 Action  !!!

to be reduced to less than or equal to 75% within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or OPTR to be 2c monitored using the movable incore detectors every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was revised to require that either OPTR be verified or power be reduced to less than or equal to 75% within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3.3 L.25 The CTS Actions which allow operation to proceed with one inoperable channel 3.3.5 Condition A 3.3.2 Action 15(C) IV (placed in trip) until the performance of the next operational test were resised to 15a (M) allow operation to continue indefinitely once the channel is placed in trip.

3.3 L26 (C) The CTS requirements for the " Auxiliary Building Filtered Exhaust Operation 3.3.2 and 3.3.8 3.3.2 Function VI  ;

(ABFVES) Manual Initiation were deleted from the ESFAS LCO. The deletion 16a includes the Fenetion and all associated Actions and Surveillances. 3 F

3.3 L27 (C) The CTS surveillance requirement which verifies the automatic actuations of the SR 3.3.9.3 4.3.3.11.1.c V i BDMS upon receipt of a trip signalis revised to allow an actual or simulated signal i to be used for the testing.  !

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveiitance Requirement )

(M) McGuire specific 11. Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls f lit. Relaxation of Completion Time Vll. Deletion of Surveillance Requirements  !

IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations [

Catawba and McGuire Nuclear Stations 4 l l

l

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM GgGM- f-; W f ^ . *'

[b W+ _, y [ ; '

t . - . x .

sues oaose w}y:yj Qt- -

a=wm.nL.es 3.4 L9 (C) The CTS requirement to place the controls for a PORV with an inoperable 3.4.11 Action C 3.4.4 Action d IV associated block valve in the closed position was revised to require the valve to be and Action F placed in manual control.

3.4 L10 The CTS requirement for the performance of an ACOT within 31 days prior to SR 3.4.12.5 4.4.9.3.1.a 11 entry into the LTOP mode of applicability, ar.d at least once per 31 days thereafter was revised by a Note which allows up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the LTOP mode of applicab!!ity to complete the required surveillance test.

3.4 L11 Deleted the CTS requirements to verify that RCS leakages are within limits by use SR 3.4.13.1 4.4.6.2.1.d Unique of the containment atmosphere radioactivity and sump level monitarn nnea ner 12 N/A 4.4.6.2.1.a  ;

hours, and by use of the reactor head flange leakoff systenf6ncedir2MTounC) N/A 4.4.6.2.1.b i N/A 4.4.6.2.1.e -L SR 3.4.15.1 4.4.6.1 SR 3.4.15.2 4.4.6.1 SR 3.4.15.4 4.4.6.1 3.4 L12 in the event of one or more floe paths with leakage from one or more PlVs greater 3.4.14 Action A 3.4.6.2 Action c fil, IV than the limit, the CTS requires isolation of the system via two valves within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before requiring a unit shutdown. These action requirements are relaxed to permit isolation with just one valve within the first 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and restoration of ,

leakage to within the limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, before requiring a unit shutdown.

3.4 L13 The CTS requirement for the isolation of RCS PlV flow paths with a closed manual 3.4.14 Required 3.4.6.2 Action c IV or deactivated automatic valve was revised to include the provision for use of a Action A.1 check valve.

i (C) Catawba specific Categories: I. Relaxation of Applicability V. Relaxation of Surveillance Requirement (M) McGuire specific L Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls  !

Ill. Relaxation of Completion Time VII. Deletion of Survei!!ance Requirement '

IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawta and McGuire Nuclear Stations 2

. _ _ - _ _ - _ - _ - - - - - - - _ _ _ - - _ _ _ _ _ _ _ - _ _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ . _ _ - - _ _ .- _ a

TABLE L- LESS RESTRICTIVE CHANGES 4o SECTION 3.4 REACTOR COOLANT SYSTEM 3.4 L19 (C) The CTS requirement for a shutdownh initiated within 30 days if the containment 3.4.15 Action C ' 3.4.6.1 Action Unique ' }

ventilation unit condensate drain tank (CVCDT) level monitoring system is inoperable was revised to permit continued operation provided either a channel check of the required containment atmosphere radioactivity monitor is performed once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or an RCS water inventory balance is performed once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with ITS SR 3.4.13.1.

3.4 L20 The CTS App'icability requirement for limits on RCS specific activity in MODES 1 - 3.4.16 3.4.8 Applicability I 5 was revised to only require limits in MODES 1,2, and in MODE 3 with RCS Tavg App!!cability 2 500*F.

3.4 L21 The CTS requirement to verify RCS gross activity s 1 pCl/gm every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was SR 3.4.16.1 4.4.8.1 11 revised to require this verification every 7 days. Table 4.4-4 3.4 L22 In the event gross specific activity of the RCS exceeds its limit of 100/E pCi/ gram, 3.4.16 Action B 4.4.8.4.a IV CTS requires verifying DOSE EQUIVALENT l-131 activity within limits within 4 Table 4.4-4 hours and placing the unit outside the mode of applicability in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This requirement was revised by deletion of the requirement to perform the verification within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3.4 L23 (M) With less than the four required reactor coolant loops in operation, the CTS 3.4.4 Action A 3.4.1.1 Action  !!I requires placing the plant in Mode 3 (Hot Standby) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; this Completion Time has been relaxed to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.4 L24 The CTS requirement for each Intermediate, Power Range, and P-7 interlock SR 3.4.17.2 4.10.4.2 Il instrument to be subjected to an Analog Channel Operational Test within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to the start of PHYSICS TESTS was revised to only require testing prior to PHYSICS TESTS without specifying a preset time.

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement (M) McGuire specific II. Relation of Survel!!ance Frequency VI. Relaxation of LCO ad Administrative Controts 111. Relaxation of Completion Time VII. Deletion of Surveillance Requirement IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regutations Catawba and McGuire Nuclear Stations 4

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.5 EMERGENCY CORE COOLING SYSTEM

. GE .

3.5 L9 The CTS Actions that allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore an inoperable RWST were revised to 3.5.4 3.5.4 Ill allow up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the RWST to OPERABLE due to the boron concentration or temperature not within limits.

3.5 L10 The CTS Action for an accumulator inoperable due to a closed isolation valve 3.5.1 3.5.1.1 Action b Ill which requires that the valve be opened immediately or a shutdown be initiated was revised to allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to correct the inoperability prior to requiring a unit shutdown.

3.5 L11 (C) A Note was added to the CTS to allow in Mode 3, both safety injection pumps flow 3.5.2 3.5.2 Vi paths to be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform valve testing.

3.5 L12 The CTS requirement that the RCS controlled leakage be within limits during 3.5.5 3.4.6% 2.d I (

operation in MODES 1-4 was revised to only require that the limits be maintained in MODES 1-3.

3.5 L13 The CTS requirement to provide a special report for ECCS actuation was deleted 3.5.2 3.5.2 Action b Vill as being redundant to regulatory requirements in 10 CFR 50.73. 3.5.3 3.5.3 Action c r

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement ,

(M) McGuire specific II. Relation of Surveitiance Frequency VI. Relaxation of LCO and Administrative Controls  ;

111. Relaxation of Completion Time Vll. Deletion of Surveillance Requirement '

IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulation Catawba and McGuire Nuclear Stations 2

TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.6 CONTAINMENT SYSTEMS 3.6 L28 The CTS requires that the specified testing be performed using a " test" signal. SRs 3.6.3.7, 4.6.3.2, 4.6.2.c, V.

The ITS permits the use of an actual or simulated actuation signal for testing 3.6.6.3, 3.6.6.4, 4.6.5.6.1.a.

purposes. 3.6.8.4,3.6.10.3, 4.6.5.6.1.d, 3.6.11.1,3.6.11.3, 4.6.1.8.d.2, and and 3.6.17.3 (C) 4.6.6.2 (C) '

3.6 L29 The CTS requirement for continuously monitoring inlet door positions was revised SR 3.6.13.1 4.6.5.3.1.a 11 to require the door position to be monitored every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

3.6 L30 The CTS requirement to verify that each containment purge valve is sealed closed SR 3.6.3.1 4.6.1.9.1 IV, V was revised by the addition of an exception to open one purge valve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs.

3.6 L31 The CTS allowance for certain containment isolation valves to be opened under 3.6.3, Actions 4.6.1.1.a and IV administrative control was revised by the addition of an ITS note to the ACTIONS Note footnote (M) which provides an allowance to open any containment isolation valve required to 7g/g g (c) be closed (except for the large containment purge / exhaust valves) under administrative controls.

3.6 L32 The CTS requirement for restoring inoperable valves to OPERABLE status was 3.6.2, Required 3.6.1.9, Action c IV replaced by the ITS Action which specifies isolating the affected penetration flow Action E.1 path by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange.

3.6 L.33 The CTS Surveillance Requirement that specifies requirements for Type B leak SR 3.6.1.2 4.6.1.1.c Vill raic testing for penetrations which have been opened after testing was deleted.

The ITS does not contain this specific SR but contains the broader requirement that all applicable Type B testing specified by 10 CFR 50, Appendix J, Option A must be met. The CTS requirement duplicates the requirements of 10 CFR 50, Appendix J, Option A section Ill.D.2 which requires that Type B penetrations be j retested following opening.

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Survelunce Requirement (M) McGuire specific 11. Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls III. Relaxation of COnvletion Time Vll. Deletion of Surveillance Requirement

, IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant te Regulations Catawba and McGuire Nuclear Stations 5

_ - - _ . . - - _ - _ _ - - _ _ _ _ _ _ _ _ _ - . -___ - _ _ _ _ . . ~ . - - . _ - . _ _ . . _ _ . - . _ _ - - _ - _ - _ - - _ _ - _ _ _ _ _ _ _ - _ . _ - _ _ _ - - _ _ .

i 6[ TABLE L- LESS RESTRICTIVE CHANGES q //p cd SECTION 3.7 PLANT SYSTEMS CHAPTER g g ;;;;ig gwy= gggy phGM .i>Ute.9%;c-Ma ji c MQhf

.;1.

3.7 L26 CTS requirement hat each automatic valve be demonstrated Operable by SR 3.7.2.1 4.7.1.4 V verifying full clos re when tested pursuant to Specification was revised to allow  !

the use of an a ual or simulated actuation signal for testing purposes.

3.7 L27 The CTS requi ment that the AFW automatic valves be verified to actuate to the SRs 3.7.5.3 and V .

correct positi and that the AFW pumps start on the specified test signals was 3.7.5.4 '

revised t oow he use of an " actual or simulated" test signal. I 4.7.1.2.c.1 an 3.7 L28 The CTS requirement that each automatic valve be verified to actuate to the (C) SRs 3.7.7.2 4.7.3.b.1 and 2 V correct position and that the CCW pumps start on the specified test signals was and 3.7.7.3 revised to allow the use of an " actual or simulated" test signal. (M) SRs 3.7.6.2 and 3.7.6.3  !

3.7 L.29 The CTS requirements that each automatic valve in the flow pathhetuate to its (C) SRs 3.7.5.3, 4.7.1.2.1.c.1, V 3.7.7.2, and 4.7.3.b.1, and

[

I correct position upon receipt of an actuation test signal were revisedpxclude automatic valves that are locked, sealed or otherwise secured in position from this 3.7.8.2 4.7.4.b.1 verification. (M) SRs 3.7.5.3, ,

TO 3.7.6.2, and 3.7.7.2 3.7 L30 The CTS requirement that each automatic valve be verified to actuate to the (C) SRs 3.7.8.2 4.7.4.b.1 and 2 V correct position and that the NSWS pumps start on the specified test signals was and 3.7.8.3 revised to allow the use of an " actual or simulated

• test signal. (M) SRs 3.7.7.2 and 3.7.7.3 3.7 L31 (M) The CTS requirement to use a simulated actuation test signal during testing was SR 3.7.9.3 4.7.6.e.2 V revised to allow the use of an actual, as well as a simulated test signal.

i i

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement (M) McGuire specific 11. Relation of Surveittance Frequency VI. Retaxation of LCO and Administrative Controls .

III. Relaxation of Completion Time Vit. Deletion of Surveillance Requirement f IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 4 l

i

P TABLE L- LESS RESTRICTIVE CHANGES I SECTION 3.8 ELECTR! CAL POWER SYSTEMS ' ,

I 3.8 L1 The CTS requirement for the specified DG testing be performed on a 3.8.1 and 3.8.3 4.8.1.1.2.a 11 1' STAGGERED TEST BASIS was deleted from the corresponding ITS surveillance SRs requirements.

3.8 L.2 The CTS action requirement for the performance of surveillances 4.8.1.1.2.a.4 and 3.8.1 Required 3.8.1.1 Action d IV g 4.8.1.1.2.a.5 for the Operable DG if the other DG is inoperable have been relaxed Action B.3.1  !

by deleting the requirement to perform the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> load test of 4.8.1.1.2.a.5.  !

3.8 L3 The CTS Action requirement to verify redundant equipment OPERABLE within 2 3.8.1 Required 3.8.1.1 Action c til  !

hours after discovery of an inoperable DG was revised to tequire this verification Action B.2  ;

within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

l 3.8 L4 Not used. hjthsdMcaddbhyvaNdf(0tV/40%) f

, 3.8 L.5 The CTS requirement for testing the DG load rejection capability of a load of 576d SR 3.8.1.9 (C) 4.8.1.1.2.g 2) V lf 420 VAC) and frequency at 60 Hz ( 1.2 Hz) was revised to allow a frequency of (M) 4.8.1.1.2.e.2) s 63 Hz. ,,

i nv l, 3.8 L6 An new action requirement is added to the CTShtources specification in the 3.8.3 Action A 3.8.1.1 Actions ill event the quantity of fuel oil for the DG is less than required. By the definition of j Operability, CTS would require immediately declaring the associated DG inoperable. The new ITS Action allows an additional period of time (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) to -

resupply the fuel oil before declaring the associated DG inoperable. I 3.8 L7 I4ct used.  ;

i 3.8 L8 The CTS requirements for the total particulates allowed in the stored fuel oil is 3.8.3 Action B 4.8.1.1.2 Ill ,

revised to allow the fuel oil to exceed the total particulates limit for 7 days before  ;

declaring the associated DG inoperable. By the definition of Operability, CTS l would require immediately declaring the associated DG inoperable.  !

1 3.8 L9 Not used.  ;

(C) Catawba specific Categories: 1. Relaxation of Applicability - V. Relaxation of Surveillance Requirernent ,

(M) McGuire specific II. Relation of Surveillance Frequency VI. Relaxation of I.CO and Administrative Controls i Ill. Relaxation of Completion Time Vll. Deletion of Surveittance Requirement IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations i Catawba and McGuire Nuclear Stations 1 j

I t

TABLE L- LESS RESTRICTIVE CHANGES

- SECTION 3.8 ELECTRICAL POWER SYSTEMS r NG f f '

3.8 L10 The CTS requirement that all diesel fuel oil properties must be within limits for new 3.8.3 Action C (M) (C) 4.8.1.1.2e 2f 111 f, fuel oil is revised to a!Iow oil properties to be outside required limits of the Fuel Oil 3.8.3 Action D (C) (M) 4.8.1.1.2.c.2 [

, Testing Program for 30 days before the DGs must be declared inoperable. By the definition of Operability, CTS would require immediately declaring the associated DG inoperable.

3.8 L11(M) The CTS requirement to verify, every 18 months during shutdown, with all DG air SR 3.8.3.3 4.8.1.1.2.e.15 Unique .

start receivers pressurized to 220 psig or less and the compressors secured that See Safety the DG will start twice from ambient conditions and accelerate to at least 57 Hz in Evaluation >

11 seconds or less. This surveillance was replaced with the ITS requirement to Section j verify that the air start receiver pressure is 2210 psig every 31 days. Ill.G.14 3.8 L12 (M) The CTS survei!!ance requirement which tests the DG capability to reject a load of SR 3.8.1.10 4.8.1.1.2 e.3 V 4000 kW without tripping was revised to require a load of at least 3600 kW but not more than 4000 kW.

3.8 L13 The CTS was revised by the addition of an allowance to perform a modified (C) SR 3.8.4.9 (C) 4.8.2.1.1.e, V performance discharge test instead of the performance discharge test, when 4.8.2.1.1.f and f verifying battery capacity with less than 80% of manufacturer's rating. 4.8.1.1.4.d  ;

(M) SR 3.8.4.8 (M) 4.8.2.1.2.e and 4.8.2.1.2.f .

3.8 L14 Not used.

l 3.8 L.15 (C) The CTS requirement to verify, on a weekly basis, no indication of damage from SR 3.8.6.1 4.8.2.1.1.a.3 Vil electrolyte leakage for the DC channel batteries was deleted. l 3.8 L16 The CTS time allowed to restore Category A and B battery parameters to within 3.8.6 Required Table 4.8-3 Notes ill limits was increased from 7 days to 31 days. Action A.3 (1) and (2) j i

l (C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement f (M) McGuire specific II. Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls  !

111. Relaxation of Comp!etion Time VII. Deletion of Surveillance Requirement {

IV. Relaxation of Required Actions '

VIII. Deletion of Requirements Redundant to Regulations I

Catawba and McGuire Nuclear Stations 2 s

R

_._._z__,-m _..._ .._._ _ _..__.._._._.._...___ _._ _ ___ __ .__.._ _____ _ _ -

__m__.__ _ . . _ _ . _ - + - , ..-,..w , . . _ _ _ - - _ . . . - - - ~ . , - _ . - - . ,m.,

x TABLE L- LESS RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS F AlGE 3.8 L17 (C) Following a battery discharge to a voltage of 110 VDC or an overcharge above SR 3.8.4.1 4.8.1.1.4.b Vil _

150 volts, the CTS require verifying within 7 days that there is no visible corrosion SR 3.8.6.2 at either terminals or connectors and that the average electrolyte temperature of l' six connected cells is within limits. This surveillance is deleted for the DG batteries. j 3.8 L.18 The CTS time allowed to demonstrate the OPERABILITY of the remaining 3.8.1 Actions A, 3.8.1.1 Action b 111 i OPERABLE DG, when one offsite circuit and one DG are inoperable, was B, and D increased from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. .

t 3.8 L19 (M) The CTS requirements were revised by the addition of an action requirement 3.8.3 Action D 4.8.1.1.2.e.15 Unique j which allows the DG starting air supply to decrease below the required capacity of See Safety i 210 psig for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Evaluation  ;

i Section llLG.14

,. t 3.8 L20 The CTS requirement for the simultaneous start of both DGs during shutdown was SR 3.8.1.20 4.8.1.1.2.h [C) 11 [

revised to delete the requirement to perform this surveillance during shutdown. f, f,/,/,p, f (,4f) 4 l

3.8 L21 The CTS shutdown surveillance requirement for the required DG and offsite circuit SR 3.8.2.1 and 4.8.1.2 VII was revised to delete surveillances that demonstrate capabilities that not required in Modes 5 and 6, or that should not be performed in these modes.

A note was also added to exempt performance of certain surveillances for the DG SR 3.82.1 Note V and offsit c ources being used to satisfy the operability requirements of ITS i LCO 3.8.2. /iC 3.8 L22 The CTS surveillance requirement for the DC Sources - Shutdown was revised by SR 3.8.5.1 Note 4.8.2.2.2 Vil '

the addition of an allowance which exempts performing certain surveillances on the DC sources required to be operable to satisfy ITS LCO 3.8.5.

(C) Catawba specific Categories: 1. Relaxation of Applicability V. Relaxation of Surveillance Requirement (M) McGuire specific II. Relation of Surveillance Frequency VI. Relaxation of LCO and Administrative Controls 111. Relaxation of Completion Time Vll. Deletion of Surveillance Requirement IV. Relaxation of Required Actions V;ll Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 3

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t TABLE LA - REMOVAL OF INFORMATION FROM THE CTS 1

SECTION 3.2 POWER DISTRIBUTION UESTINATiON dCONT' rob [ [CHANGEJ

@d6T$$$35 {%m%%jc 965#M M@MMM A

SUMMARY

OEiCHANGEs@b/3$3$[h MB i%p (MDOCUMENTF; .y PROCESS ' 4 TYPE ^ .

((6iSOO5SIO5) 3 O$ CHANGE 3 FREQUIREMEN1% (A wm i I

3.2.1 Bases Bases control 3 3.2.2 The formulas in the CTS for determining the values of Fy(X,Y,Z), P.

3.2 LA.1 program

' Fo"", and K(Z).

The CTS references to trip setpoint constants and instrument scales. 3.2.1 Bases Bases control 1 3.2 LA.2 3.2.2, Action c program and 4.2.2.2.c 3.2.1 Bases Bases control 3  !

3.2 LA.3 4.2.2.2.e The CTS exceptions for various core planes and core regions used program  ;

4.2.2.2.d when determining Fy(X,Y,Z).

5.6.5 3 The CTS requirements for the measured value of Fo(X,Y,Z) to be COLR 3.2 LA.4 4.2.2.3 ,

increased by 3% to account for manufacturing tolerances and 5% for l

measurement uncertainties.

3.2.1 Bases Bases control - 3  :

3.2 LA.5 4.2.2.2 The descriptive information for how the peaking factor sunreillances are

• i program 4.2.3.2 to be performed.

Definitions of FTw(X,Y) an X,Y)tc . t 3.2.2 Bases Bases control 1 },

3.2 LA.6 3.2.3 program l Fa The CTS references to trip setpoint consta and instrument scales. 3.2.2 Bases Bases control 1 3.2 LA.7 3.2.3 program SR 3.2.4.2 Bases Bases control 2 >

4.2.4.2 The CTS information regarding how the incore detectors are used for 3.2 LA.8 program determining OPTR.

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i LA Change Types:. 1. Details of System Design (C) Catawba specific i

2. Descriptions of System Operation (M) McGuire specific Procedural Details for Meeting TS Requirements 3.

1 Catawba and McGuire Nuclear Stations I

___.-__._.___________m______.m. . _ _ _ _ _ _ _ _ __ _ _ _ _ _ - m_.___ _ _ _ , . - , - - , - - . - - - - - + + - - . _ - _ ~ ,- -,-- -

-v_ _ _ - -+,_w_____ e n,_ ,.____._._______._____._-_m'

i TABLE LA - REMOVAL OF INFORMATION FROM THE CTS SECTION 3.3 INSTRUMENTATION I

[dl5UU$dd5! ISindTEjdN '

%$$%$$$$$$M@$fi$M!@[3 #

DE5hNATIO I 2C65 TROL "CHANGEf AOECHANGEO FREQUIREMENTg ,(J chd6

SUMMARY

rOECHANGENW WMG@ TDOCUMENT@ # PROCESS _e 6 TYPET -

3.3 LA.10 (M) Table 4.3-2, Note CTS details for performing the surveillance on the high flux at shutdown SR 3.3.1.7 Bases control . 3 9 alarm are moved to the ITS Bases. Bases program -

3.3 LA.11 Table 2.2-1 The Overtemperature AT and Overpower AT limit equation compensation UFSAR 10 CFR 50.59 1 variable definitions in CTS were moved to the UFSAR. [

3.3 LA.12 Table 3.3-5 The CTS Engineered Safety Features Response Time testing, is moved UFSAR 10 CFR 50.59 3 to the UFSAR. l t

3.3 LA.13 3.3.2 Actioris The descriptive details in the CTS Actions regarding the relationship 3.3.2 Bases Bases control 3 l between Trip Setpoints, Allowable Value, and OPERABILITY have been program incorporated into the ITS Bases.

3.3 LA.14 Tables 3.3-3 The CTS design description of Function 1 Safety injection, including all 3.3.2 Bases Bases control 1 1 3.3-4, and 4.3-2 the functions initiated by a safety injection signal (e.g., Reactor Trip, program l Feedwater Isolation, etc.) was moved to the ITS Bases.

3.3 LA.15 Table 3.3-3 The CTS AFW design description regarding which initiating signal starts 3.3.2 Bases Bases control 1  ;

the motor or stegdriven pumps was moved to the Bases for ITS 3.3.2. program I

3.3 LA.16 Table 3.3-4 The CTS d ighMeriptions of the Feedwater Isolation and Auxiliary 3.3.2 Bases Bases control 1 Feedwate or the SG Level-High High (P-14) and Auxiliary Feedwater for program the SG Level-Low Low functionTtrip setpoints and allowable values as  !

" narrow range instrument span," were moved to the ITS Bases .  ;

3.3 LA.17 Not used. hCy 3.3 LA.18 Not used.

I 3.3 LA.19 4.6.4.1 The specific information located in the CTS SR which requires the 3.3.3 Bases Bases control 3 Channel Calibration to be performed using a sample gas containing program [

hydrogen and the specific calibration points is moved to the ITS Bases. i 3.3 LA.20 Not used.

1 (C) Catawba specific LA Change Types: 1. Details of System Design (H) McGuire Specific 2. Descriptions of System Operation ,

3. Procedural Details for Meeting TS Requirements Catawba and McGuire Nuclear Stations 2 I

'?

r .

TABLE LA - REMOVAL OF INFORMATION FROM THE CTS 1 SECTION 3.8 ELECTRICAL POWER SYSTEMS -[

IIIISClliislOAi g e c4 9 , ]d $MAEN%M$$i![3dk f M SO M bE; CHANGE F/$@

Ej idESTIAATIUA $CONTROlli CHANGEe M GN WEDOCUMENTP

$(Mj((Mi LORCHANGE! 3[$EQUIREMENT#iMM $fPROCESS4 TTYPEP 3.8 LA.29 (C) 4.8.1.1.2.g.2 The CTS specific value for the single load rejection that a DG must be SR 3.8.1.9 Bases control 3 (M) 4.8.1.1.2.e 2 capable of withstanding, while maintaining a specified frequency has Bases program been moved from the TS to the !TS Bases.

3.8 LA.30 (C) 4.8.1.1.2.g.14 Tne CTS requirements to verify diesel lockout features and prevent the SLC 10 CFR 50.59 1 and diesel from starting when the DG is on the tuming gear or the 4.8.1.1.2.g h. maintenance mode switch is activated have been moved to the SLC. This l (M ) 9././.2.e,/p J is a design feature of the DG which is not required within the TS.

3.8 LA.31(M) 4.8.1.1.2 e.6.c The CTS exception to testing the DG when the plant is not in a shutdown - SR 3.8.1.13 Bases control 3 .

i Footnote condition (Modes 1,2,3, and 4) has been moved to the ITS Bases. program 3.8 LA.32 4.8.2.1.2 b.3 The specific number of battery cells listed in the CTS has been moved 3.8.6 Bases - Bases control 3 from the TS to the ITS Bases. program 3.8 LA.33 (C) 4.8.1.1.4.a The CTS footnote describing the procedure to test two different cells on 3.8.6 Bases Bases control 3 the DG batteries each month has been moved to ITS Bases. program i

l (C) Catawba specific LA Change Types: 1. . Details of System Design (M) McGuire Specific 2. Descriptions of System Operation

3. Procedural Details for Meeting TS Requirements ,

I Catawba and McGuire Nuclear Stations 4 I

+

_ _ _ _ _ _ . .. .I

Y 0 q [l ' htfot .tB Qbkb TABLE R- RELOCATED SPECIFICATIONS 1

kMMM 3.4 R.4 3/4.4.10 hhhNU Structuralintegrity of ASME Code Class 1,2, and 3 components hbk$$kh h hMiNNh SLC- 10 CFR 50.59 10 CFR 50.55a i 3.4 R.5 3/4.4.11 RCS vent paths operable and closed for reactor vessel head and SLC 10 CFR 50.59 pressurizer steam space (C) and Reactor vessel head vent paths operable ,

and closed (M) 3.6 R.1 3/4.6.5.2 Ice bed temperature monitoring system SLC 10 CFR 50.59 3.6 R.2 3/4.6.5.4 Ice condenser inlet door position monitoring system SLC 10 CFR 50.59  ;

'l 3.7 R.1 3/4.7.2 Steam generator pressure / temperature limitations SLC 10 CFR 50.59  !

l 3.7 R.5 3/4.7.8 Snubbers SLC 10 CFR 50.59 .

. o 3.7 R.3 3/4.7.9 Sealed source contamination limits SLC 10 CFR 50.59 }

t 3.7 R.4 3/4.7.12 (C) Ground water level near reactor and auxiliary buildings (C) SLC 10 CFR 50.59 i

)

3/4.7.13 (M) Ground water level near auxiliary building (M) -l i

l 3.7 R.2 3/4.7.12 (M) Area temperature monitoring SLC 10 CFR 50.59 'i 3.7 R.6 3/4.7.13 (C) Standby Shutdown System SLC 10 CFR 50.59 i

3.8 R.1 3/4.8.4 Containment penetration conductor overcurrent protection devices SLC 10 CFR 50.59 l

! 3.9 R.1 3/4.9.5 Communications between Control Room and Refueling Station SLC 10 CFR 50.59 ]

i 3.9 R.2 3/4.9.6 Reactor building manipulator crane and auxiliary hoist SLC 10 CFR 50.59  !

3.9 R.3 3/4.9.7 Load handling restrictions over fuel assemblies in storage pool SLC 10 CFR 50.59  !

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! (C) Catawba specific [

[ (M) McGuire Specific .t Catawba and McGuire Nuclear Stations 2 f

L .A l

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4 ENCLOSURE 2 CATAWBA NUCLEAR STATION CHANGES TO ITS SUBMITTAL ]

1 1

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CHANGES TO CATAWBA ITS SUBMITTAL

1. Condition A of ITS LCO 3.2.2 incorrectly includes the words " steady state." This is not consistent with the CTS and results in not having a condition to enter if SR 3.2.2.2 is not met. This error has been conected.

2. The Bases for ITS 3.3.1 indicates that the Trip Setpoints are the limiting safety system settings (LSSS). This is incorrect and should state that the Allowable Values are the LSSS. This change has been conected.

3. Discussion of Change (DOC) R4 for Section 3.7 was revised to provide additional  !

justification for the relocation of the groundwater level speci5 cation to licensee controlled documents. This was identified as an open item in the draft SE. l 1

4. DOC M17 for Section 3.8 was revised to address the additional actions associated with cascading to the Residual Heat Removal specifications after a loss of the distribution systems in MODES 5 and 6 (LCO 3.8.10). This was identified as an open item for DOC A53 in the draft SE.

5. ITS SR 3.8.1.6 incorrectly indicates that the transfer from the fuel oil storage tanks is accomplished automatically. The CTS only requires that th- transfer capability be demonstrated. This is currently done both by an automatic transfer valve or manual '

valve. The Bases for this SR also indicates that the transfer to the day tanks is l accomplished by transfer pumps. The design utilizes gravity feed. This enor has been l corrected consistent with the design and CTS requirements.

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Fm(X,Y) 3.2.2 I

3.2 POWER DISTRIBUTION LIMITS l

3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (Fm(X,Y))

LCO 3.2.2 Fm(X,Y) shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ----- NOTE---- A.1 Reduce THERMAL 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Required Actions A.3.2.2 POWER 2 RRH% from and A.4 must be RTP for each 1% F"6s(X,Y) completed whenever exceeds limit.

Condition A is entered.

AND F"6s not within limit. A.2.1 Restore F"is(X,Y) to within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> limit for RTP.

M A.2.2 Reduce Power Range 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Neutron Flux-High trip setpoints 2 RRH% for each 1% F"as(X,Y) exceeds limit.

AND A.3.1 Restore F"3s @,Y) to WtNn M Mm  ;

limit for RTP.

2 A.3.2.1 Reduce OTAT Trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Setpoint by 2 TRH for each 1% F"as(X,Y) exceeds limit.

AND (continued) l Catawba Units 1 and 2 3.2.2-1 Amendment No.

SPttIfi d - 3, w POWER DISTRIBUTION LIMITS 30.2 NUCLEAR ENTHALPY RISE HOT CPA=EL FACTOR FoHfX.Y1 d!MITING C0dITION FORAPERATIOD

, ItO 3.2 Fw(X,Y) shall_ bj)llaited by i slog the following elationsM Fm"(X,Y) :s; F '(X,Y)Lco '

Where: Fg X,Y) = the me vred radial peak.

' [F (X,Y)]'00 = the simum allowable r tal peak as defin in CORE OPERATING MITS REPORT (COLR ,

APPLICABILITY: MODE y:[dy d2 d /' J' h  !

ACTION:

, s w w c.as n a..ua ..ut*% i 7m

--# A.t l 9 M With Fm(X,Y)exceedingitsAlimit:

l

' "A.Lh Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, red l

POWER from RATED THERMAL POWER at I s eforthe each allowable 1% that FgTq(X,Y) exceeds the limit, and L.I

@ Withi ours e ther:

A. t.t Restore F M(X,Y) to within the limit of Specification 3.2.3 for

' @ RATED TH POWER, or g

A128 Reduce the Power Range Neutron FI -High Trip Setpoint Gn Table 2.2-1 at least RRH% for each 1% that F (X,Y) exceeds that limit, ane

@ Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of initially being outside the limit of Specification 3.2.3, either:

AAL @ Restore F M(X,Y) to within the limit of Specification 3.2.3 for RATEDTHEbLPOWER,or f Pegora thg4o110winq4ctions3 A .S "i- I D 4,g l Q Reduce the OTAT Uable a .z-D by at least TRHt21 for M

each 1% that Fm (X.Y) exceeds the limit, and

[m RRH is the reduction requi to compensa foD each 1% th F ((of THERMALX,Y) exceed the limits ficationof 3.2.

S provided a th COLR per S fication 6.9.1.9.

(23 TRH is , setpoint reducti required to e ensate d3 for he amount ofjTAT ch 1% that F X i exceeds the limi of Specificati 3.2.3, p ded in the CON p(e Specification 6.9. 9. /

CATAWBA - UNIT 1 3/4 2-7 Amendment No. 148 L-67 If 3

bM% 3.Z. Z.

POWER DISTRIBUTION LIMITS 38.2btEAR ENTHALPY RISE HOT CHA' N NEL FACTOR FoH(X.Y',

(LIMITIlMiCONDITION FOR OPERATI0@

LCO 3.2 Fm(X,Y) alted by impo ngthefollowingreationshih M

Fm (X,Y) s F L(X,V] Leo Where: F (X,Y) A .b

= the meas ed radial peak.

[ m L(X,Y)]Lco a the laus allowable radi peak as deff d QnteCOREOP6RATINGLIM SREPORT(C0 .

APPLICABILITY: MODE 1. g 94 Aq ACTION:

,A__ _q NcTE.w., w.m %A38C*

MA M ^3 i, Js11M y,s.,,) ...

A4 p.\ mt.k W Se,c Cot.A Q,dd A With Fy(X,Y) exceedin's itsAa -

li mit:)

'Al

@ Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, red fe'the allowable THERg. POWER fros! RATED THERMAL POWER at I as for each 1% that Fm (X,Y) exceeds the Italt, and

.I

@ Within urs e her: I A2 ! @ Restore F M(X,Y) to within the limit of Specification 3.2.3 for RATEDTHEblPOWER,or T*

A.2'Z @ Reduce the Power Range Neutron Flux-High Trip Setpoint (n TabW2.2-1 at least RAH % for each 1% that Fm"(X,Y)exceedsthatlimit,and

@ Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of initially being outside the limit of Specification 3.2.3, either:

A.S.I Restore F M(X,Y) to within the limit of Specification 3.2.3 for RATED TH L POWER, or (2. _Perfod the folloding actind A. 3. 2.1 (a) Reduce the OTAT@ Tate 2.7-) by at least TRHW for each 1% that Fm"(X,Y)exceedstheIlmit,and

( m RRH is the unt of THERMAL POW reduction require tocompensateford each 1% F M(X,Y) exceeds he limits of Specif cation 3.2.3 provided th COLR per Specif cation 6.9.1.9.

l.,A .4 m TRil' is etpoint reduction r utred to compensate for ea 1%amount that F offTAT X in the CON Sp X ceeds the Ilmit of pecification 3.2.3, p(er,Y),

provi ification 6.9.1.9.

CATAWBA - UNIT 2 3/4 2-7 Amendment No. 142

({ e. 1O b

F((y,y) 3.2.2 3.2 POWER DISTRIBUTION LIMITS (y,y j 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (k)

N '^'

LCO 3.2.2 d s ,Y)lx within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. .1 Rester within )

l

.........N0TE-..h.

R 1 s p limit Q g g y) l eted whenever Co ition A is entered. A.1 hour Reduce THERHAL POWER

<50YR W~s RRH'/. b E g g g.7, not withifflimit.  ;

@ F[(X/y)ewd5 I l [bN .2.2 Reduce Power Range Neutron Flux-High 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> h*

__ ERRH Y. A<- tbcb

[ re.cn.n r -._

p tteds l/m'd j h@ Perform SR 3.2.2.1. hours a

(continued) 43,l Reskt. F$ (Y,y) 4. d,R.-o y%

likW L RTP.

B. 5 Aa.1.1 RtJvts OTAT Tr;pw S 4 72he bN b ecd 1%

F[g b ,y,) w t<<ds lik' f.

k 3.2 9 Rev 1. 04/07/95 cas

RTS Instrum:ntation B 3.3.1 BASES BACKGROUND (continued)

Trio Setooints and Allowable Values The Trip Setpoints are the nominal values at which the bistables are set.

Any bistable is considered to be properly adjusted when the "as left" value is within the band for CHANNEL CALIBRATION tolerance.

The Trip Setpoints used in the bistables are based on the analytical limits (Ref.1,2, and 3). The selection of these Trip Setpoints is such that adequate protection is provided when all sensor and processing time delays, calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those RTS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 5) are taken into account. The actual nominal Trip Setpoint entered into the bistable assures that the actual trip occurs in time to prevent an analytical limit from being exceeded.

The Allowable Value accounts for chanps ic > .noam measurement errors between COTS. One example of -oco a change in measurement error is drift during the surveillance interve, c' une COT demonstrates that the leop trips within the Allowable Value, the loop is OPERABLE. A trip within the Allowable Value ensures that the predictions of equipment performance used to develop the Trip Setpoint are still valid, and that the equipment will initiate a trip in response to an AOO in time to prevent an analytical limit from being exceeded (and that the consequences of DBAs will be acceptable, providing the unit is operated from within the LCOs at the onset of the AOO or DBA and the equipment functions as designed).

Note that in the accompanying LCO 3.3.1, the Allowable Values of Table 3.3.1-1 are the LSSS.

Each channel of the process control equipment can be tested on line to verify that the signal or setpoint accuracy is within the specified allowance requirements. Once a designated channelis taken out of service for testing, a simulated signalis injected in place of the field instrument signal. The process equipment for the channelin test is then tested, verified, and calibrated. SRs for the channels are specified in the SRs section.

The Trip Setpoints and Allowable Values listed in Table 3.3.1-1 incorporate all of the known uncertainties applicable for each channel.

The magnitudes of these uncertainties are factored into the determination of each Trip Setpoint. All field sensors and signal processing equipment Catawba Units 1 and 2 B 3.3.1-4 Revision No.

RTS Instrtmentation B 3.3.1 BASES BACKGROUND Trio Setooints and Allowable Vafds (continued)

/ 5etpoints in a nce with the Allowab Value ensure t SLs are not olated during A00s ( t the s of DBAs 1 be acceptable, provi the unit is ated frem in the LCOs at the on of the Am nr DBA and t eouir-mt functions as desioned).fNote that in the ~

a are g LC0 3.3.1 theorio mpointpof Table 3.3.11 tcs.avau) g Each channel of the process control equipment can be tested on line to verify that the signal or setpointJ.ccuracy is within the specified allowance requirements 6f h_ZL Once a designated channel is taken out of service for @. .

testing, a simulated signal is injected in place of the field instrtment signal. The process equipment for the '

channel in test is then tested, verified, and calibrated.

s SRs for the channels are specified in the SRs section.

ints and Allowable Values listwf in The TableTrip 3 3 1Sep- zare pa>mi un tneJetnooolo(v described irD

' ~

(Refere(e 6ALehfincorporategall of the known uncertainties applicable for each channel. The magnitudes of these uncertainties are factored into the determination of each Trip Setpoint. All field sensors and signal processing equipment for these channels are assumed to operate within the allowances of these uncertainty magnitudes.

Solid State Protection System -- -

The SSPS equipment is used for the decision logic processing of outputs from the signal processing equipment bistables.

To meet the redundancy requirements, two trains of SSPS, each performing the same functions, are provided. If one train is taken out of service for maintenance or test- - - - - - - - - - - -

purposes, the second train will provide reactor trip and/or ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result. Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements. The system has been designed to trip in the event of a loss of power, directing the unit to a sa t.rt h 1 shutdown condition.

(continued)

B 3.3-5 Rev 1, 04/07/95 m

Discussitn cf Chrng:s S cti n 3.7 - Plant Systems RELOCATION movement of the building from floating effect of the groundwater. Thi; requirement i; net nece;;;ry ic cnsurcGroundwater level is slow changing and has no imediate affect on safe reactor operation. It is a non- significant risk contributor to core damage frequency and offsite releases.

Therefore, this item is being relocated out of Technical spect fications. Any changes to this requirement in the UFSAR  !

require a 10 CFR 50.59 evaluation. The 10 CFR 50.59 evaluation I ensures that changes to this requirement will not have any l adverse impact on the safe operation of the plant. This change  !

is consistent with NUREG-1431 and the Application of Selection Criteria. )

R.5 Details of the Snubber inspection requirements located in CTS 3/4.7.8 are being removed to the Selected Licensee Commitments Manual (SLC)(UFSAR Chapter 16). Any changes to UFSAR will require a 10 CFR 50.59 evaluation. Snubbers support the operability of primary components whose operation or function may be an assumption of a safety analysis. However, snubbers are not considered to be part of the primary success path.

Their purpose is to prevent unrestrained pipe motion under dynamic loads while also allowing normal thermal expansion of l piping and nozzles to eliminate excessive thermal stresses during heatup and cooldown. The requirements for Snubber Inspection are also contained in 10 CFR 50.55a and do not need I to be repeated in the technical specifications. Snubber details are defined in Inservice Inspection (ISI) Program. Changes to the ISI program are adequately controlled by 10 CFR 50.55a.

This provides an equivalent level of regulatory control. This change is consistent with NUREG-1431.

R.6 The proposed change relocates CTS 3.7.13, " Standby Shutdown System" to the Selected Licensee Commitments (SLC)(UFSAR Chapter 16). The Standby Shutdown System equipment identified in this Specification (diesel generator, makeup pumps, and batteries) are used to ensure that a fire in the control room will not preclude achieving safe shutdown. This equipment is independent of areas where a fire could damage systems normally used to shutdown the reactor. However, the equipment is not used to detect a degradation of the reactor coolant pressure boundary nor assumed to mitigate a design basis accident (DBA) or transient event. This requirement is not necessary to ensure Catawba Units 1 and 2 Page R - 2 Supplement 69l

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$peeA pe CAD J,s ELECTRICAL POWER SYSTEMS 38 D 18.(e tDNmt em 0lSTRIBUTIQ.

QHUT00W]N G IPiRING CON 01JMN FOR MTIOD TF tco 3.8. @ s a mini e, the following .C. electrical buss #sCand inverterib s all p gb e LE and e rgized:

/ / a. One - 4160-volt essentia bus, i

b. Two - 600-volt essenti busses in a sing e train, and

/.IO . o - 120-volt A.C. i nyerters connected otal busses their energi reenactiv, edchannele n.c. from their re ectiv]e -

j 6PPLICABILITY Mon and y , _ / /,!

& nry _^'"*"'3 Wi @

A*g g[\maptnyer> of immediately the Aove recuirecrA.C. busses JHft suspend all operations eneraireMn ena involvin re.ontrar-reactivity changes, or movement of irradiated fuel,g CORE ALTERATIONS, in.itiate corrective actionpositive to energize the required A.C. bu;ses in the specified manner as soon as

p. possible/ an Cthrough a s uu n o no depressurize ano venty neactor cgp+1rnt system 7 east a 4.5 uare inch vpdf.j l

SURVEILLANCE REOUIREMENTS M AC V)MQ Sgy,g,g, / W The spea1Ted) A.C.legsses gbafl be determmea enerauen .rn creautres metrner amaroonce per 7 days by verifying correct breaker alignment .5~2 and edicate@ voltageCo~n thmArosh

?

I CATAWBA - UNIT 1 3/4 8-21 Amendment No. 148 l

lf

- - . _ . - . -_ _ . _ _ - - . . .- -. .= .

Specification 3.8.10 INSERT 1 The necessary portion of AC, Channels of DC, DC Trains, and AC vital buses electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME ,

A. One or more A.1 Declare associated required AC, Immediately supported required channels of DC, DC feature (s) inoperable. .

trains, or AC vital bus (es) electrical power -

distribution .

subsystems , AC inoperable, s

A.2.5 Declare associated Immediately required residual heat i removal subsystem (s) inoperable and not in

> $N operation.

AND l

A.2.6 Declare associated Low Immediately Temperature Overpressure Protectionfeature(s) inoperable.

l

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Catawba (Jn .+ l Page 2of 3

d

'SpiFKATecM 3,3 ELECTRICAL POWER SYSTEMJ 3. F.10 g,g,jp ONSITE POWER O!STRIBUTIONCS GHUIDO_WN.j

{IMIJfflG CONDITI0MR OPERATM

_ i w Lco .8 s a mini e, the following A.C. electrical busses and(inverter 3sha11 g De OPERABLE and e rgized: '

a. One 4160-volt essential b s, A.D b. T - soo-voit essential usses in a single train and

c. Two - 120-volt A.C. vi al busses energized fro their respective inverters connected their respective O.C. annels.

1 APPLICABILITY MODES 5 and R m /t,77 ~

C p c.% & M cf ACTION: s MNM

.65 b' jgr With y of the abge required A.C Ausses not enerAred in the ra,fini 2 r, immediately suspend all operations involvin 4

reac ivity changes. or movement of irradiated fuel,g CORE initiateALTERATIONS, positive corrective action gj to energize the required A.C. busses in the specified manner as soon as possibly a within a n p rin rouah least a 4.5 y arauepressu inch vg.and/ vent ena waamors cooiant SystR SURVEILLANCE REQUIREMENTS AC V/YAb

$3.T.a).I @ The Esneettedl A.C.dIu~sser-stdIll be detaMad an rai,#4n tha acc uirarinanner a ,xeast)once per 7 days by verifying correct breaker alignment, andCindlested)voi~. age en theme 3. j s

CATAWBA - UNIT 2 3/4 8-21 Amendment No. 142 1

[

1

Specification 3.8.10 INSERT 1 The necessary portion of AC, Channels of DC, DC Trains, and AC vital buses electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME l l

l A. One or more A.1 Declare associated required AC, Inmediately channels of DC, DC supported required \  ;

feature (s) inoperable.

trains, or AC f  ;

vital bus (es) I electrical power -

distribution . ) *g 1 subsystems ,

inoperable.

A.2.5 Declare associated Immediately i

! required residual heat l

removal subsystem (s)

>MN inoperable and not in operation. I AND i

A.2.6 Declare associated Low l'

Immediately Temperature Overpressure 1

4. f.

Protection feature (s) inoperable.

i Catawba v/h A Page2._ of 3

Discussicn cf Ch:ng:s Sectica 3.8 - Electrical Power Systems TECHNICAL CHANGES - MORE RESTRICTIVE discussed in a less restrictive change addressed. These changes are acceptable to adequately nonitor the batteries for operability and are consistent with NUREG- M31.

M.15 Footnote (6) to current CTS Table 4.8-3 is deleted with the conversion to ITS format. The removal of the. temperature compensation from the float voltage limit of Category B parameter requirements deletes an allowance to adjust the float voltage range. The deletion of this allowance is acceptable because the plant staff does not use this alloviance. The change is considered only slightly more restrictive change and is consistent with NUREG-1431.

M.16 A second Completion Time requirement is added to CTS Action  :

3.8.2.1 and 3.8.3.1. This would limit the time from discovery of I failure to meet the LC0 to a total time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. This limit is considered reasonable for situations in which ITS 3.8.9 Actions A, B, C, or D are not met. This limit is considered reasonable for situations in which various Actions of the LCO could be entered. This type of completion time, which is discussed in example 1.3-3 of ITS Section 1.3, " Completion Times", limits the time period in which serial overlapping entries into independent sets of Conditions for a single LC0 can occur. The addition of this requirement to these Actions is a more restrictive requirement for plant operations. The change is consistent with the format of NUREG-1431.

M.17 CTS Action of 3.8.1.2, 3.8.2.2, and 3.8.3.2 requires if one or l more required AC or DC sources or inverters are inoperable in MODES 5 or 6, the movement of irradiated fuel assemblies should be immediately suspended. With the conversion to the proposed LCOs 3.8.2, "AC Sources-Shutdown," 3.8.5, "DC Sources-Shutdown," 3.8.8,

" Inverters-Shutdown," and 3.8.10. " Distribution Systems-Shutdown,"

the Mode of Applicability is modified to include "during movement l of irradiated fuel assemblies." This requirement would be l applicable in the condition with no fuel in the reactor. This is l not currently required. For the inoperable distribution system, l the ITS actions also require cascading to the applicable RHR LCO.

This is necessary in lower modes because the RHR LCO specifies additional necessary required actions for the loss of residual heat removal. Therefore, thcThese changes 4s-are more restrictive to plant operations. This is acceptable because the required i Catawba Units 1 and 2 Page M - 4 Supplement 59 l l

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Discussicn cf Ch:ng;s Secticn 3.8 - Elcctrical Power Systems TECHNICAL CHANGES - MORE RESTRICTIVE electrical power systems are required to be OPERABLE to attigate or preclude the potentfol for on event. provide nece;;ary equipment with electrical power to nitigctc the fuc! hendling cccident.

This is consistent with the safety analysis and with NUREG-1431.

M.18 Not used.

M.19 CTS 3.8.1.1 does not specify requirements for the lubricating oil inventory and the starting air receiver pressure for the DGs. ITS SR 3.8.3.2 and 3.8.3.4 require that these parameters be verified once per 31 days on each DG. Although the current broad definition of operability would require monitoring these types of parameters, specific values and frequencies are not specified in the CTS. The additions of these requirements is acceptable to ensure the Operability of the DGs. Therefore, the change is considered more restrictive and is consistent with NUREG-1431.

M.20 Two notes are added to CTS 4.8.1.1.2 a.5. The Notes require the ITS SR 3.8.1.8 to be performed on only one diesel at a time and the requirement is to be immediately preceded by the performance of either ITS SR 3.8.1.2 or 3.8.1.7, without a shutdown of the diesel. These requirements are additional restrictions for the

( testing of the diesel. These limitations are acceptable because diesel testing is normally conducted only on one at a time and the start of a diesel is normally conducted with either SR 3.8.1.2 or 3.8.1.7. The change is consistent with NUREG-1431.

l M.21 Not Used.

M.22/23 Not used.

M.24 CTS 4.8.1.1.2.g.15 requires that the DG be started within 5 minutes after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run test and specifies minimum voltage j and frequency requirements. ITS SR 3.8.1.15 adds a requirement for steady state voltage and frequency for the hot restart test.

Catawba Units 1 and 2 Page M - 5 Supplement 69 l

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AC Sourc:s - Opnrating 3.8.1 SURVEILI.ANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 - - ------ -

N OTE S ----------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test. '

3. This Surveillance shall be conducted on only one DG at a time. I

4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded and operates 31 days for2 60 minutes at a load 2 5600 kW and s 5750 kW.

SR 3.8.1.4 Verify each day tank contains a 470 gal of fuel oil. 31 days  :

I

(

SR 3.8.1.5 Check for and remove accumulated water from each day 31 days l tank.

SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer fuel 31 days oil from storage system to the day tank.

(continued) l l

I Catawba Units 1 and 2 3.8.1-6 Amendment No.

AC Sourc:s-Op: rating B 3.8.1 BASES SURVElLLANCE REQUIREMENTS (continued)

SR 3.8.1.6 This Surveillance demonstrates that euch required fuel oil system operates and transfers fuel oil from its associated storage tanks to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil valve is OPERABLE, and allows gravity feed of fuel oil to the day tank from underground storage tanks, to ensure the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for fuel transfer systems are OPERABLE.

The design of fuel transfer systems is such that the transfer valve operates automatically or the transfer valve bypass valve may be opened manually in order to main'iain an adequate volume of fuel oil in the day tanks during or iallowing DG testing. Therefore, a 31 day Frequency is appropriate.

SR 3.8.1.7 See SR 3.8.1.2.

SR 3.8.1.8 Transfer of each 4.16 kV ESF bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

The 18 month Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load Catawba Units 1 and 2 B 3.8.1-18 Revision No.

l M4f='n .511

, ELECTRICAL POWER SYSTEMS i

LINITING CONDITION FOR OPFRATION

~

L A."1- With I boura di el egenerator opera ng at greater than 57WkW within the diesel rator output to lessgan or, equal to { >

h. With the Cat ic Protection Sys l

' inoperable, resto the Systes to OPERABL tatus within 10 d s or prepare and s it a Special [

LA-(Report uant to Specifica on 6.g.2 outlining inaner 111tv mad the al for restoring the stem tocause of the OPERABLE SURVEILLANCE RE0UIREMENTS l .8.1.1.1#ch of the above ~ fired id,ei, Gad 1

~

ransmitfion nat=rk nad th*ECi'e r r-+ 4 =1 rcuits"betWHn iliary 'CliiV%TfsGte Power Systas(shall be:] "~ {*

5R3.T.LI @ wamured OPERABL541 leB once per 7 days by verif correct breaker alignments, indicated i power availabilf t 4r uA .m ca '.;D A i

! S4 3.f.LF @ . LDemons rated OPERR5i.t atm l

(manua'Iy and automatical'y?sP_once per 18 months by transferri . .'

circuit to the alternate r diiiiRD from the normal

. ..u Govetes) l 4.8.14 tach diesenenerator snul ne daaaaetratavfoPFDARiEh

@ At least once p I

(Un aMERED Ti.wrisASIS l 5A 13.L4 @ . VerifyGip ws seveL*Wday tan Gsp41ogj

• Qg% Verifyino the fuel level in the fuel storage taiiib ~

64 3 3.1.6 @

{

the fuel ransfer operate [to g t -- '

storage system day g &tanP'

'A s2.1 1 Veri dsERT 9 an neesar starts from standby re a condition

/ M the steady-stateq[e49PstoP) volt e and frequency _

4160_ 420 volts and 60 i 1.2 Hz, respecti elv. TThe dieseli rgenerator shall be startea t sais test by using one of the l

following signals:

a) Manual, or b) Slaulated ss of offsite power by itself, o j

c) Slaul ed loss of offsite power la con etion'with an ESF Act tion test signal, or I

d) ESF Actuation test signal by self.

4 3 % l1@0nce pt r 164 days, G: art wr aaataa from standby m.m +44 ,

QiPtYy-)Tentor,reaune

@D 3740 voi s prelu 157 Hz in s II second condition, and

. h twa CATAWBA - UNIT 1 3/4 6-4 Amendment No.155 ed avsa' sed d45

!- Sital $fn$t.

veli l'37fo gr el yte < ed.

uthsf.h Ts.1 EL tal di. H.E 84z.

l l

I P  % op 21 i 9

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- - . . _ ~ . - ._. _

p d G A a 19.1 .

ELECTRICAL. POWER SYSTEMS 1.IMITING CONDITION FOR OPERATION With a esel generator ope j 1 reduce the diesel g(/ttng at greater than do W. within (

d7 Wr nerator output to less4han or eoual t

. L With the M ic P m tection Sy em inoperable, resto the Systes to status within 10 [

Report s or prepare and s t a Special 4

rsuant to Specifica on 6.g.2 outlining cause of the inoper 111ty and the plan for restorino the Svs k to OPERABl.E SURVEfttANCE RE0UIREMENTS 4.8.1.1.1 ch of the above'-ilred fr.C---

ransmis I

' network and th d ite Essen E "A bi-t "cr- cir' Svetse Tts between sbd I be* the oWite

, SR 5.1.1.1 @ (Deterdined crumsi+ ntMsn once. per 7 days by verif@ correct bmaker alignments, ' ndicated power availabilit@w, ..a,

AA AT)

)

s 56'3.1 lJ @ v p=--Mated cruouu.e-at

s (manually and automatical y)emmonce per r 18 months by transferri -.

' ! 3.' " - circuit to the alternate . c from m

the normal sist Q.8.34.2 Each chese:

cenerator>Kall be d=-w# rated OPERABff) -

f @ At least once pe daysym 3ATAGGERED T58f BASIS l

Q 3.9.l._4 @ Verif@th, wo  ! = > An thA day tan

/twsl h g84'leh3) j )

eTC tu s.ta verirvina rn, e - - i += tha tuei storaoe +=A sg s.t.14 g.; p g CMdhM l \

4 VerifyGib ueucr belt the fue1ATransfer6TaWoperated a torggif flyg-l tha storage system tjgday tan , l N

58 lever 3.fl1@ yWITurt Verify @h the steady -

e eoeratorTvo; Cage stat qthe dreseD ndition starts from a 4160 generator shall 420 volts and 60 i 1.2 Hz, m spectively._

following signa s: started for this test b using one of the

' a) Hanual, r b). Sisu ted loss of offsite powe by itself, or '

c) $ lated loss of offsite la conjunction with ation test signal, or ESF d' An ESF Actuation test goal by itself. j J hv ~e44 tyrh r0#"

AJ1 WAl<BMnce per 184 days, start tae-esindfrom standby

/N5eRT 1 ( Wer1WaeneratoratacHD> 3740 volts andri 57 Hz prelube) condition, and Al i 9%3 second . l I CATAWBA - UNIT 2 3/4 8-4 Amendment No.147 f*4 me.Jisc

[4 Ast.

mo v ~

An 6 thTre v aal Ottuf x St.9 Hz. ud y f

dtl.1 f(r.- '

$ k 2\

i AC Sources--Operating 3.8.1 t I

. SURVEILLANCE REQUIREMEM S (continued) '

SURVEILLANCE FREQUENCY SR 3.8.1.3 - - - - - - - - - - - N01T.S - - - - - -

1. DG loadings may include gradual ~

loading as rec m .ided by the manufacturer.

2. Homentary transients outside the load range do not invalidate this test.  !

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and 7 mmediately follow without shutdown a .

successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded (As specitted ini and rates for h 60 minutes at a load h ,500] kW and :s(5jRIU]) kW.

TabicAf.8.1 1 j i

I (5'600) (575 % s j

Verify each day tank (find eppure mouTn eiD 31 days l SR 3.8.1.4 contains h ' gas or fuel oil.

SR 3.8.1.5 Check for and ve accumulated water from kays each day tank engine mounted tank). -

SR 3.8.1.6 Verify the fuel of: transfer system e days

@l operates t Mo*=rtimiMFfransfer fuel oil the day tank, dfrom storace(taoVs e0gine mW tank y,gg g (continued)

Wprr5TS '

3.8 7 Rev 1. 04/07/95 ca.J.~

1 AC Sources-Operating B 3.8.1 1

BASES l SURVEILLANCE SR 3.8.1.4 (continued)

REQUIREHENTS )

provided and facility operators would be aware of any large u;c= of fuel oil during this period. -

SR 3.8.1.5 1' Hierobiologicai fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in ordtr to survive. Removal cf water

~

from the fuel oil daygand enerne mounteJd tanks once every I i A317' days eliminates .the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition. it eliminates the ,

potential for water entrainment in the fuel oil during OG- I operation.

Water may come from any of several sources' .

including condensation, gmund water, rain water.

contaminated fuel oil, and breakdown of the fuel . '

l oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data  !

regarding the watertight integrity of the fuel oil sistem.

The Surveillance Frequencies are established by Regulatory H Uuice 1.1.$/ mer.@. This SR is for preventative i

maintenance. The presence of water does not necessarily represent failure of this SR. provided the acetnulated water is removed during the performance of this Surveillance.

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oi1@

arartsver oumploperates and transfers fuel oil from its associated storage tan @to its associated day tant. This is rt continuous operation of standby power theeg required sources. Thi to sbrveillance provides assurance that fuel  !

r (VMm oi1JransreF 6Giitbis OPERABlf.rthe

/g 6f,cf '

piping isfueTTii piping system 1s i

J intact. the fuel delivery obstructed, and the controls and control systems fo fuel transfer sys_tems are OPERABLE. h, . *Nk '

f -

y rval O '

ay frequency responas to me u mg ts for s contained in ASHE Code 4

(continued)

W9G4T5 B 3.8 19 Rev 1. 04/07/95 CdeM

AC Sources-0 prating 8 3.8.1

.h[ksto- VaY pan vnlvt SURVEILIMCE SR 3.8.1.6 (cortinued) 7 ge,%2f.].

( .J[he design o fuel tr I (systems is suctruaim- ically o valve,or o k J e= "*' 37 in # " "+=4n adequate pat a 1 fuel oil in the f "following DG t a MitMitanksWHna f

J2,.

1 ino. ' m,=uu.m . o .31 day Freodency 157 t

f, f OfM aporoorinta n i -

-r us aue n er st i t part ERAB .t Fr

_ k d be modi to reft ivi u y esigns.4

_ l SR 3.8.1.7 See SR 3.8.1.2. -

~

SR 3.8.1.8 -

Transfer of each 16 kV ESF bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit ,

s distribution network to power the shutdown loads. The J{18 month}T ncy of the Surveillance is based on engineering.1 . taking into consideration the unit conditions required to perform the Surveillance. and is intended to be consistent with expected fuel cycle lengths.

Operating experience has shown that these 'nts usually pass the SR when performed at thes[18 month requency.

Therefore, the Y a reliability sta int.

was concluded to be acceptable from 4 FThisSRis fled by a Note. ~

that, durir operation with the actor reason for the Note sI performan critical, of this SR could use perturbations to te electri distribution sys that could challe conti - steady state ope tion and, as a result unit saf systems. Credit y be taken for unpla _ events a t satisfy this SR.

SR 3.8.1.9 Each OG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine (continued)

M '

8 3.8 20 Rev 1. 04/07/95 caleuM I

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! l ENCLOSURE 3 CATAWBA NUCLEAR STATION PROPOSED LICENSE CONDITIONS l

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_ _. . _ _ . _. .- _. _ _ _ _ _ ~ . _ _ . _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ _ . . _ _ _

PROPOSED LICENSE CONDITIONS Section 2.C (2) of the Facility Operating License, NPF-35 and NPF-52, should be revised to include the following additional st3 paragraph:

For Surveillance Requirements (SRs) that are new in Amendment [ ] to Facility Operating License NPF-35 (NPF-52 for Unit 2), the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment [ ). For SRs j that existed prior to Amendment [ ], including SRs with modified acceptance criteria

and SRs whose frequency of performance is being extended, the first performance is due ,

at the end of the first surveillance interval that begins on the date the Surveillance was

' last performed prior to implementation of Amendment [ ).

Appendix D of the Facility Operating License, NPF-35 and NPF-52, should be revised to include l the following additional paragraph:

I l Amendment ' Additional Condition Implementation l Number Date l The licensee is authorized to relocate This amendment is j certain requirements included in effective immediately and

( Appendix A to licensee-controlled shall be implemented by I

documents. Implementation of this January 31,1999.

amendment shall include the relocation of these requirements to the i appropriate documents, as described in the licensee's letter dated May 27, 1997 and amended by letters dated March 9,1998, March 20,1998, April r 20,1998, June 3,1998, June 24,1998, July 7,1998, July 21,1998, August 5, 1998, and September 8,1998 evaluated in the NRC staff's Safety Evaluation enclosed with this

[ amendment.

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l l ENCLOSURE 4 CATAWBA NUCLEAR STATION PROPOSED TECIINICAL SPECIFICATIONS AND BASES i

t L