ML20151U336
| ML20151U336 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/08/1998 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20151U341 | List: |
| References | |
| TAC-M98964, TAC-M98965, NUDOCS 9809100361 | |
| Download: ML20151U336 (78) | |
Text
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Duke Energy Corpor; tion b,
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UU 526 South Church Street
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PO. Box 1006 (EC07H)
Charlotte, NC 28201 1006 M. S. kkman (704) 382-2200 onx1 Executive Vice hesident (704) 382-4360 iAx Nuclear Generation September 8, 1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
Subject:
Duke Energy Corporation McGuire Nuclear Station Docket Numbers 50-369 and -370 Improved Technical Specifications, Supplement 9 TAC Nos. M98964 and M98965 By letter dated August 11, 1998, the NRC transmitted the draft 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. of this letter provides a markup of the draft SE with annotated comments. of this letter provides the i
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. of this letter provides proposed license conditions to address the material proposed for relocation from the current technical specifications
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and to address the scheduling of new more restrictive e
surveillance requirements.
These proposals are consistent with
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license conditions incorporated into other Facility Operating Licenses for recently approved technical specification conversions. provides the final proposed Technical Specifications and Bases.
4 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 North Carolina officials.
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9909100361 990908 E PDR ADOCK 050003691 P
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Nuclear Regulatory Commission September 8, 1998 Page 2 If any additional.information is needed, please call Lee A.
Keller at. 704-382-5826.
Very truly yours,
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M.
S. Tuckman l
Enclosures i-
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w/ enclosures i
Mr.
L. A. Reyes l
Administrator, Region II l
U.
S. Nuclear Regulatory Commission i
Atlanta. Federal Center 61 Forsyth St.,
SW, Suite 23T85 l
Atlanta, GA 30303 Mr. F. Rinaldi l
U.
S._ Nuclear Regulatory Commission Office of' Nuclear' Reactor Re,qulation Washington, DC 20555 1Hr.
S. M. Shaeffer Senior Resident Inspector
'McGuire Nuclear Station Mr. Mel Frye Division of Radiation Protection t
3825 Barrett Drive Raleigh, NC 27609-7221 i
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U.
S. Nuclear Regulatory Commission September 8, 1998 Page 3 M.
S. Tuckman, being duly sworn, states that he is Executive Vice President of Duke Energy Corporation; that he is authorized on the part cf se.id Company to sign and file with the Nuclear Regulatory Commission revisions to the Facility Operating Licenses of McGuire Nuclear Station; and that all the statements and matters set forth herein are true and correct to the best of his knowledge.
1 j
M.
S.
Tuckman, Executive Vice President j
i Subscribed and sworn to before me this TD day of h d 1998 W
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OLLb CL)
Notary Put;1ic My Commission Expires:
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i ENCLOSUREI McGUIRE NUCLEAR STATION COMMENTS ON THE ITS DRAFT SAFETY EVALUATION I
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a QRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. TO FACILITY 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
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DOCKET NOS. 50-369 AND 50-370 1.
INTRODUCTION Afd i
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 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 dated 6 7,1997,as supolemerited by se arate letters dated March 9, March 20, April 20, $a?)6) June 3, June 24, 5lI the exi@ sting TS to t e improved TS. The improved TS are based upon NURE
' July 7, uly 21 Duke Energy Corporation (DEC or the licensee) proposed to convert I A I
' Standard Technical Specifications for Westinghouse Plants," Revision 1, dated April 1995, and M
upon guidance in the "NRC Final Policy Statement on Technical Specification improvements for S9 Adyg Mudear Power Reactors" (Final Policy Statement), published on July 22,1993 (58 FR 39132),
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( fpg and 10 CFR 50.36, as amended July 19,1995 (60 FR 36953). The overall objective of the 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 Specifications."
Catawba and McGuire Draft Safety Evaluation
2 Hereafter, the improved TS are the ITS, the existing or current TS are the CTS, and the i
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 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 lons, the lic ee proposed tiers of a (generi ature that we not in STS. The staff requ ed that the lic eo submit ch 6kkk Igen c issues as a oposed change to S through e NRC/Nucl car ergy institu s
, T hnical Specifi tions Task Force TF). The generic issues re considere or i 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 Report (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 !TS 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.
SorMIJDS.
The Commission's proposed actions on th CNS and MNS applications for amendments both dated May 27,1997, were published in the Federal Registeron July 14,1997 (62 FR 37628) for CNS, and on July 15,1997 (62 FR 37940 The staff's evaluation of these applications, including 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, Apnl 15, April 28, j
May 14, May 22, and July 6t 1998. The plant-specific changes contained in these supplements l
serve to clarify the ITS with respect to the guidance in the Final Policy Statement and STS.
6 Therefore, these plant-specific changes are within the scope of the action described in the i
' #I Federa/ Register notices, except for the beyond scope changes that were the subject of 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.
Catawba and McGuire Draft Safety Evaluation 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 imorporated as appropriate into the ITS, are the following:
Catawba Nuclear Station, Units 1 and 2 Date Amendment No.
Issued Unit 1 Unit 2 Description 7/21/97 160 152 Revised TS ;cquirements for the standby she.down system.
These requirements are not retained in the ITS but are relocated to Chapter 16 of the UFSAR "seETabl@R Discussiori.o[ChirIg'6l3;7IM
,(p, 8/22/97 161 153 Changed licensee name from Duke Power Company to 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.
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 conditions and exemptions, and to correct errors.
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.
6/17/98 166 158 Revision of surveillance requirements for pressurizer heaters to be consistent with current plant design -
incorporated into ITS 3.4.9.
[h 7/9/98 167 159 Relaxed Applicability of control room area ventilation actuation instrumentation function - incorporated intg I'3.7)
ITS 3.3.7.JEIus vise Bas or ITS 3.7jrD to discue ack
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yo start rCRAVS' tside Mode /1,2,3, a" 4.
continued
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Deletion of ASME pressure test of diesel generator fuel oil system - incorporated in ITS 3.8.3.
Catawba and McGuire Draft Safety Evaluation
Catawba Nuclear Station, Units 1 and 2 j
Date Amendment No.
Issued Unit 1 Unit 2 Description
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Revised TS requirements for low temperature overpressure protection (LTOP) - incorporated into ITS 3.4.3 and 3.4.12.
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Revised trip set point and allowable value for nuclear e service water suction transfer on low pit level - incorporated into ITS 3.3.2 and Table 3.3.2-1.
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Relaxed TS requirements for stored ice weight -
incorporated into ITS 3.6.12.
,Ah 4 C hente M fretuInC Ysor inspecfibns of tre to/dersser
'W g/Mhf 5#//' #M to McGuire Nuclear Station, Units 1 and 2 cNS
- "d"re did s'urnih IMnes 8
-l Date Amendment No.
- j Issued Unit 1 Unit 2 Descrintinn Revised trip set pointbe' 11/25/97 177 159 c switchover to recirculatio - incoroorated into ITS 3.3.2 and Table 3.3.2-1.
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4/8/98 178 160 kvisedreferencu to COLRxtliodokyies - incorporatedinto H35.6.5.
rih 7/30/98 179 161 Revised CTS Figure 5.1-1 regarding location of the meteorological tower. Not retained in ITS - EE51Tabls.LA DiVcusii6n ofiCfisiiiiQ l
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7 Added allowance for 72 cumulative hours of operation with elevated temperatures in the containment lower compartment - incorporated into ITS 3.6.1.5
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Remove references to steam line low pressure safety injection function - incorporated into ITS 3.3.2 and Table 3.3.2-1.
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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.
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l 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 l
acknowledges that, as indicated in the Final Policy Statement, the conversion to ITS based on Catawba and McGuire Draft Safety Evaluation
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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 stnit approves the licensee's changes to the CTS with mnetifirmtinns documented in the supplemental submittals.
I eMember C in the letter ofMst XX 9_98, the licensee proposed license conditions for the implementation of the ITS. Also, in this lerer, the licensee submitted revised ITS pages. The license conditions and revised ITS pages do not change the notices in the f_ deral Reoisteron
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e 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 Federa/ Reaisterfor the beyond scope issues associated with the conversion, as 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 j
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 wit" the common defense and security and provide adequate protection of the health and safety u, the public.
II. 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 tv,aterial required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation deem 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,"
j 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 particu!ar requirements to be included in a plant's TS.
Catawba and McGuire Draft Safety Evaluation 4
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.SefClf)
- g gg,f[ comments were document as request r additional information (RAls) and forwarded in letters dated January 16, anuary 30 arch 27, April 15, April 28, May 14, May 22, and July 6, 1998. The licensee pro ed res ses in letters dated March 9, March 20, April 20, June 3, June 24, July 7, July 21, anQ 1998. The letters clarified and revised the licensee basis for l
'.ranetina the CTS requirements into ITS. The NRC staff finds that the licensee's submittals including responses to RAls provide sufficient detail to allow the staff to reach a conclusion i
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 I
the following CTS change categories, as appropriate:
i Administrative Changes, (A), i.e., non-technical changes in the presentation of CTS e
requirements; Technical Changes - More Restrictive, (M), i.e., new or additional CTS requirements; Technical Changes - Less Restrictive (specific), (L), i.e., changes, deletions and relaxations of CTS requirements; Technical Changes - Less Restrictive (generic), (LA), i.e., deletion of CTS requirements by movement of information and requirements from existing specificauons (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-comrolled document) and placed in licensee-controlled documents.
These general categories of changes to the licensee's CTS requirements and STS differences j
may be better understood as follows:
1 A. Administrative Changes Administrative (non-technical) 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 editorial in 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.
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.;
I Catawba and McGuire Draft Safety Evaluation I
_ 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 l
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:
Category l Relaxation of Applicability Category 11 Relaxation of Surveillance Frequency Category til Relaxation of Completion Time Category IV Relaxation of Required Actions l
Category V Relaxation of Surveillance Requirement Category VI Relaxation of LCOs and Administrative Controls Category Vil Deletion of Surveillance Requirements Category Vill Deletion of Requirements Redundant to Regulation l
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
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experience, industry practice, industry standards, or manufacturers' 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 do not reduce, but can increase system reliability.
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 contribute 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, consistent with the STS, only specifies staggered testing for certain systems or components where this method is most practical or where it contributes to safety.
Therefore, the elimination of stagerettestingrequirements, consistent with the the STS, is acceptable.
l 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 i
performing the surveillance at an optimum time or plant condition. Such an exception l
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 performance is expected to be of short 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-1 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 ll are acceptable.
Relaxation of Completion Time (Category Ill)
Upon discovery of a condition in which an LCO is not met, the CTS require performing 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 Catawba and McGuire Draft Safety Evaluation CTS contain requirements that are redundant to regulations in 10 CFR. For example, 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 Vill are acceptable.
Table L - Less R ictive 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 l
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 case 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 relaxaticns 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 beyond the scope 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 necessary for the current methodology (relaxed axial offset control) for AFD and are thus deleted. Logging of AFD was previously required to establish penalty rninutes 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 prnviding increased monitoring af ter 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 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.
4 Catawba and McGuire Draft Safety Evaluation For a system to be considered Operable, the definition of Operability as it pertains to the system must be satisfied. In addition, the specified SRs associated with the LCO governing the system must be met. Some CTS LCOs contain information concerning design and configuration implying that they relate 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 Operability requirements for the affected systems and supporting SRs are being 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, format, and presentation of information in the STS. In addition, existing regulations and TS administrative controls will ensure an effective level of regulatory control of this information and will 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, Bases contro(Trogram, speafies contro(sforchanging the US Bases. It is acceptable to remote details and s
descriptions ofsystem operationfrom ecause this type ofinfonnation wi((6e adequately centroEedin z/
the UFM plant operatingproedures, nd es, as appropriate. mielefore, changesfamng unthin
' Type 2 are accepta6(e.
7 TroceduralDetaihforMeetirur'15 nements(Type 3) c.
Detailsforperfonning CTS action andsurteinance requirements, maintaining andcontroEing CTS administratite requirements, andstatementsproviding clanfication ofCIS requirements are more appropriately /
speafiedin the UFM Qg plan, SelectedLicenser commitments Manua[(SLC), or WS Bases as appropriate. \\
Changes to the informationgovernedby one of these documents requires an etuluation in accordance with 10 CR50.54,10 CR50.59, or HS 5.5.14, Bases ControlTrogram.
Catawba and McGuire Draft Safety Evaluation
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~-a % controlof theplant coditions appropriate toperfonn a suntiEance test is typicaEy an issueforprocedures andschedufing (e:ccept u4ere a S(de or codition speafiedin the AppGca6tGty of the Lco mustfirst 6e enteredin order to perfonn the suntiEance). % inclusion of routine proeduralguidance has previously been detenninedto be unneassary as a 'I5 restriction. As indicatelin generic Letter 91-os aEcuing thisprocedural controfis consistent with the vast majority ofotherSRs that do not dictate spuificplant coditionsfor suntiEances. In addition, Gsts or tables containing TS relatedinfonnation or data hatt alsopreviously been detenninedto be unnecessary as a 95 restriction. generic Letter 932 speaficaVy approzedthe remova[from the 'I5 of the suntiEance acaptance criteria in the instrument response time tables. % FIS egends the aEcuenceprovidedin genaic Letter 934 to inc[de the rematulofmost tables andGsts ofinfonnation pertaining to suntiEances orLcosfrom the'I5. Similarly, prescriptistprocduralinfonnation in action requirements are unneassary as a TS restriction. % inclusion ofspeaficproceduraldetailin action requirements is unGkely to contain aG theproedura[ considerations necessaryfor theplant operators to complete the actions required, adreferraltoplantprocedures is therefore requiredin any ettnt. % C15 also contain inanygeneralsta tements intended to eq(ain or clanfy the intent of requirements in LCOs, action staternents, andsun'eiEances. % FIS Bases document protides a rnore appropriate locationfor these types of l infonnationalstatanents.
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CTS aho contain procedura[deta '[sfor rnecting CTS adininistratitt centroh such as requircinentsfor the NuclearSafety Reziew Board ($Q). % CTSspeafy such details as thefunction, composition, afternatizes, consultants, meetingfrequency, quorum, review, adits, adrecords of the $xB. %se details of the NSU actitatics can be dequately ddressedin the @ T[an documentation addo not needto be incidedin the r15 c(nanges to the @ T[an must be evaluatedin aaordance uith theguidance in 10 CFR50.54; thus adequate regulatory controlls ensured. In addition to the @ T(an, othersimilarproceduraidetai&formeeting c15 dministratist controls are movedto the 71FS%RorSLc unich are dequatefy controEedby theprovisions of 10 c1R50.59.
Other changes intelving the remotu[ofprocduraldetails inc[de those details remot&from the CTS u6tch are associatedwith Gmits retainedin the n3. For etample, the n3 requirement inay simply refer toprogrammatic requirements such as the Ventilation gifter Testing Tmgram (V71T), includedin rTS 5.5.11, unich speafies the limits adtest requirements containedin the V71T. % PTS V71T dequateprogrammatic contro[of the associate 1procduraldetai[s removedfrom the OTS. Changes to nust be apprmdby the NRC j
5.S.}/)
'Ihese changes are consistent uith the content,fonnat, andpresentation of onnation sn the 313. In addition, c.t sting regulations and'TS administratist contro& uiEenture an effectize [estiofregulatory controlof this i
information andwiEyrotide a more appropriate change contro[ process. 'ITserefore, changesfaEing uithin Type 3 are acaptable.
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 specific change type, as discussed abm 9, for not including the information or specific l
requirements in the ITS.
Catawba and McGuire Draft Safety Evaluation
.n.
The licensee, in electing to implement the specifications of the STS, also proposed, in accordance with the criteria in the Final Policy Statement and 10 CFR 50.36, to entirely remove certain specifications 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 injection Flow Paths. Modes 5 and 6 (3.1 - R.1) 3/4.1.2.2 Minimum Boron iniection Flow Paths. Modes 1. 2. 3. and 4 (3.1 - R.2) 3/4.1.2.3 Charaina Pumo 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 Sources. 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 soecifies requirements for boration flow paths borated water sources
- "j -
JAOURS 54nd3(CIS&T.2.6 spep&es reauirernerits for boratejarater soyrces) The 8"'YpM.N'.
boration subsystem of the chemical and volume control system (Uvus) provides the means to meet one of the functional requirements of the CVCS, i.e., to control the
' Mehold/m ' chemical neutron absorber (boron) concentration in the reactor coolant system (RCS)
(b/ V6 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.
The boration subsystem is not assumed to be operable to mitig f
a design basis accident (DBA) or transient. In the case of a malgf nction of the CVCSj that causes a boron dilution event, the operator must take actiorPlo close tne l
appropriate valves in the reactor makeup system before the shutdown margin is lost.
Operation of the boration subsystem is not assumed to raitigate this event. In addition, the boration subsystem 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 ar'y of the criteria in 10 CFR 50.36 and 4
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 and McGuire Draft Safety Evaluation
QQ, )l~S L 7.lblSW NC0M/
) t irradiated fuel assembli s within the fuel building so that an automatic actuation is not necessary. ITS 3.7.13 also requires a suspension of fuel handling activities, should the f
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.
1 The fuel storage pool criticality radiation monitor (EMF-15) for Catawba monitors 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 unon 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 i
monitors radioactivity in the fuel storage pool area. This monitor does not provide any mitigation of a DBA. It is provided as a criticality monitor, and it does sound the
(%tattimerft,edgud@falarm upon detection of high radiation.
f Cofw)b ceMS The control room air inta -
radiation monitors (EMF-43A,43B) a provioed to j
identify increasing level of radioactivity in the control room intakes. The control room area ventilation syste perates continuously in a filtered modeQdoes not rely on these monitors to perform any actuation function to mitigate the ettects of a RThe CiPA
.l The auxiliary building ventilation gaseous 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 for n B
The safety function for the ventilation system is to filter the ECCS
}
4 (OCA 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 monitor only provides indication of offluent 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 t ctuation function and serve only to alert operators to isolate a leaking heat exchanger. No credit is taken for radiation monitor 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)
Catawba and McGuire Draft Safety Evaluation l
in a ready state for mitigative action, this requirement is directed more toward prevention of degradation and continued long term maintenance of acceptable structural conditions.
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 flywheelin ection 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)
The reactor vessel head vents are provided to exhaust noncondensible gases and steam from the RCS which could inhibit natural circulation core cooling foliowing 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 TMI Action Plan Requirements,"
however, the operation of these vents is an operator action after the event has occurred and is only required when there is indication that natural circulation is not occurring.
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 requirements 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 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 Monitorina 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 ar y 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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- 8*
[ Ysn 13.
3/4.6.5.4 Ice Condenser inlet Door Position Monitorina System (3.6 - R.2) f 5
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). Howevar 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, sufficient 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 toprevent 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)
Catawba and McGuire Draf t Safety Evaluation
29-CTS 3/4.7.9, " Sealed Source Contamination," provides limitations on sealed source contamination to ensure the total body and individual organ irradiation doses do not exceed allowable limits in the event of ingestion or 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 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.
17.
3/4.7.12 Ground Water Level near Reactor and Auxiliary Buildinas (CNS) 3/4.7.13 Ground Water Level near Auxiliary Buildina (MNS)
(3.7 - R.4)
Groundwater levellimits are required to be maintained at or below the top of the of.oug adjacent floor slabs of the reactor containment building and the auxiliary building to
/g8 f'S #-
preclude movement of the building from the floating effect of groundwater. These limits, N#">
. however, are not necessary to ensure safe reactor operation'becsUsb([lic,epectn}
/Af u p1peasts Therefore, the ground water level requirements in CTS 3/4.7.12 for CNS I
Nd4 nd
/4.7.13 for MNS do not meet any of the criteria in 10 CFR 50.36 and may be
%4f /43 40 removed from the CTS and relocated to the SLC Manual. Any changes to these former gffegg.g requirements regarding thhroundwater level limits, as relocated to the SLC Manual, I
/41/n t'f
- will require a safety evaluation pursuant to 10 CFR 50.59. Thus, under 10 CFR 50.59,
,j) sufficient regulatory controls exist to ensure continued protection of the public health O
and safety.
}((4 he.
n 18.
3/4.7.12 Area Temperature Monitorina (MNS)(3.7 - R.2)
CTS 3/4.7.12 requires area terrperature monitoring to indicate that safety-related equipment in various areas of the plant is not being subjected to conditions beyond the 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 1
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 area temperature monitoring 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.
19.
3/4.7.13 Standby Shutdown System (CNS) (3.7 - R.6) c53/4.7.13 identsfia dieselgenerators, ma&uppumps, andfatten'es as standby shutdown system i
j A
equipment which is used to ensure that a fire requiring evacuation of the control room j
J f
will not preclude achieving safe shutdown. This equipment is independent of areas
, g where fire could damage those systems normally used to shutdown the reactor. 7his system is creditedin certain beyonddesyn basis foss offunction scenarios (eg, foss ofservice water or component cooling nuter) to minimize core damagefrequency andoffsite releases..stndthu system is subject to
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Catawba and McGuire Draft Safety Evaluation
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I i
.50 I
h' f the repfations associateluith the maintenance nde andfire l
regulatory contro[over the availabiGty of this equipmentforstandby shutdown. However, this system is 4
not used to detect a degradation of the reactor coolant pressure boundary, nor is it assumed 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 these 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 Af M /' s d f ot & S lrcphl-The primary function of th containment penetration conductor overcurren rotection I
devices is to open appropriate control and power circuits whenever the oad conditions exceed the present(curfefit depdhWB) Doing so will protect the circuit conductors in the j
c containment penetrations trom 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 0.sa;4
[
division of protective functions can be lost, withoutdoSiDtWcapability to adequately v
respond to a DBA event. Therefore, CTS 3/4.8.4 does riot 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 Refuelina 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 l
changes to these former requirements regarding the requirements for communications Catawba and McGuire Draf t Safety Evaluation
. 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 identified licanwa-enntrolled documents as cnccif!-
Sug/t/M/[ddM//d//M5 d M n the licensee's letter dated May 27,19 45 MerCh 9<rcA gds QVo/How.wuo 2f h/y 7,h/yMggjnff ag Sepfgh&llq F. Uontrol of specifications, HequirEfffUntS78tidifffGrmmion HeiocateG Trom Ine Uld l
in the ITS conversion, the licensee will be relocating specifications, requirements, and detailed information from the CTS to license 9-controlled documents outside the CTS. This is discussed in Section Ill.D and Ill.E above. The facility and procedures described in the UFSAR and SLC Manual, incorporated into the UFSAR by reference, can only be revised in accordance with the 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 n king changes consistent w' other applicable regulatory requirements; for example, th n oc changed int.EOC_
[
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 administrat!ve instructions that implement the OA plan can be changed in accordance with 10 CFR 50.54(a) and 10 CFR Part 50, Appendix B. Temporary procedure changes are also controlled by 10 CFR 50.54(a). The documentation of these changes will be maintained by the licensee in accordance with the record retention requirements specified in the licensee's OA plans for CNS and MNS and such applicable regulations as 10 CFR 50.59.
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 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 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.
m 1.
. Steam Generator Water Lew(LowLow - Deletion of%e Constant Tequirementfrom Cftannefcalifration CNS tinit 10133/43.1, Table 43-1 Functionaf tinit 12, Table 9{otatior 13 l&
CNS tinit 1 17333.1, Table 33.1-1, Function 13, SR33.1.10 f
l Catawba and McGuire Draf t Safety Evaluation
&? C%fS33-A.687he CB Channe[ cab 6tation surttilfance requiranentfor the CNS Unit 1 steangenuator uuter (ett((oun[ow instrumentationfunction speafies setting thefilter time constant to a value s*1.5 seconds.
Thh criterion uus introducedby CNS Unit 1 Operating License.knendment N9 13 on September 30,1986.
The associatedsafety evaluation statedthat thefilta time constant uns to reduce spurious reactor trips and aun[iaryfteduettiinitiations. Despite this adouunce, in its 173 submittaf the licensee statedthat CNS Unit 1 cunently has nofilter time constant associateduith this circuitry, andthat thefilter time constant uns nettr impfemented Titus the licensee proposedto omit the requirementfor this time constan:from the FIS Channel Calibrationfor this instrumentfunction,15SR33.1.10. 7his change & administrative 6ecause it deletes a menningless requirementfrom the CS anddoes not alterhow CW Unit 1 & operated. In addition, it 6 rings the Unit 1 ChannelCalibration requirementsfor thisfunction into conformity with Unit 2. Therefore, this change is acceptable.
2.
Turbine'1 rip and Teeducter Isolation Instrumentation - Addition oft -Low Coincident unth TeactorTrio Actuation Tunction S{NS C53/43.2; Tables 33-3,3.4-4, and43-2; Functionaf Unit 5 S{NS 1533.2, Ta6(e33.2-1 Function 5.d S[MS33-%f.24 9fte CB3/43.2 requirementsfor the turbine trip andfeeduuterisolation instrumentation function are increased to also require an initiation syna[from T,,g owcoincident with reactor trip (T-4). This l
sgnalrelationsftip [imits an egessitt reactor coolant system (RCS) coo [downfo((owing a reactor trip by tenninatity mainfeeducterflow to the steamgenerators. 7he inclusion of this initiation signalin ITS 33.2.5. dis acceptable because it enhances plant safety andis consistent uith the plant desyn andsafety analysis.
3.
Containment Tressure Contro(Sustem - TetisedAction Tequirements CNS CI53/43.2, Table 33-3, Functiona[ Unit 7, Action 166.a CNS F1333.2 Action T, Table 33.2-1 Function 9 S{NS CIS3/43.2, Table 33-3, functionalUnit 6, Action 2a S{NS 11333.2 Action R Table 33.2-1 Function 9
'llackaround 7he Containment Tressure Contro[ System (GG)is describedin CNS UFSARSection 7.6.4 and S[NS UFSARSection 7.6.16. It consists of tuu redundant trains unthfour diferentialpressure transmitters f
or channels per train, each channe[ supporting a redundant independent component or system. These systems are 1
the containment spray system and the air returnfan system, in addition, the GGfor S[NS supports the f
hydrogen skimmersystem. In the ettnt one of the eight channels is inoperable, CI5 spect y action requirements.
These action requirements hatt been retiselso that the 75 action requirementsfor CNS ands {NS are the same.
'Eacft GG instrument channelperfonns a start pennissist/tenninatefunctionfor its associatedsystems. The purpose of the start pennissitt/tenninatefunction is to present egessite depressurization of the containment through inadttrtent or eyessitt operation of certain engineeredsafetyfeatures sucft as the containment spray system.11%en containment pressure is below the tennina te setpoint, the start /tenninatefunction wiO autornatica8y stop orprettnl actuation of the associatedfeatures toprotect against inadttrient actualion and the resultiry negatittpressure transient in the containment. 7he start /tenninatefunction 6 locks actuation of the associatelfeatures unti[ containment pressure has increasedto tbe start permissitt setpoint. %%en Catawba aad McGuire Draft Safety Evaluation
h/1d f containment pressure is above the start penmssive setpint, thefeatures are ena6(dto perfonn their containmentprotectittfunctions; e.., toprettnt ottipressuneation of the containment in the ettnt ofa 'URA.
g 7Nese instrumentation controls to blockandpennit actuation of the assodatedfeatures are cutomatic, but each channefunay inditidually 6e unanuaEy overridden byplacing the channelin the test mode andsetting the setpoint to eitherpennit orpresent (or tenntnate) system operation. Seleaing emeprnfwin the othct.
CMS 33-Sf.25:'Ducussionfor CMS In the etent one channelis inoperable, the CW c5 requireplacing that channelin trip uithin one hour. For example, shouldthe start pennissitt/tenninatefunctionfor the channel 6e inoperable, manuaEyplacing the channelin the start pennissitt mode uvuldrender the tenninatefunctionfor that channelunatuitable. Theproposedm action requirement dou not requireplacing the channelin trip, an action unich uvulddisable the othersafety mde ofifiat channel Rather, it requires immediately declaring the associatedsuppnedfeature inoperable. This is a more rutrictite action beause the CTS uvuldadow operation to continue indefinitelyprovuledthe channelis in trip, u6ereas the supprteffeature's action requirements, in most casa, uvuldplace a limit on unit operation. 'Inis change is acapta6(e because the spectftdactior equirements associatedunth the LCOfor the supportelfeature are adequate to ensure protection of.ae public fiealth andsafety.
In the etent more than one CPCS channelis inoperable, the C$ c5 provide no action requiremeuts; thus a unit shutdown in acardance uith c53.03 uvuld6e required. In some casu this may be overly rutrictite.
7hepropsedm action requirement to immediately enter the LCOs of the suppneffeatures applies eten tf more than one cTCs channelis inoperable. 'Mth tuo or errore channels inoperable, tfie m may aequire a unit shutdown, unich is consistent with the C5. In othercases, houtver, the suppnedfcatures' action requirements may aEow operation to continue temprarily to aEow time to restore the inoperable arcs channels to operable status. In tfiese cases, the m action requironent uvuld6e less restriaire. % m action requitanent protides adequate assurance that operation uith any number ofinoperable cTCS instrument channels is limitedconsistent with the RequiredAction completion 7ima associateduith the Lcosfor the suppneffeatures. 7his change is acceptable 6eause the speafielaction requirements associatedwith the LCO for the suppondfcature are adequate to ensureprottaion of thepubGc health arufsafety.
SfWs33-L28:'Discussionfor SfWs in the etent one CTCJ channelis inocerable, the Sf6 c5 require placing that channelin the start permissite mde uitfiin one hour. Ifother channels 6eame concurrently inoperable, the same action requirement appBu; a shutdown in accordance with c53.03 uvuldnot necessarily be required, unicis uvuld6e the case under the CW CB. In aHition, the Sf4 c5 require applying the appBcable aaion statement of thefeatures suppnedby the inoperable channel % m action requirement retains this action requirement but omits the c5 requirement to place the inoperable channelin the stan pennissitt mde. This is las restriaire beause it penniugreater operationaffleg6tSty; in some plant conditions, it may be altantageous toplace the channelin the tenninate mde. 7he FTS anions are acceptable beause they aHappropriatefleg6inty unite maintaining the [etelofsafety affordedby the CTS action requirements.
4.
9(udroaen Sionitors ' Deletion ofAnaloa channeloperationa[' Test. Telaxation ofchannelchec{c 'Treauencu.
anddemormlofStaagered' Test keautrementfrom channe(Calibration C$ c5 4.6.4.1 C$175SR333.1 andSR333.2 Catawba and McGuire Draf t Safety Evaluation
35 CMS 332 C54.6.4.1for the hydrogen monitors requires a ChannelCheckonceper12 hours, an Analog Channeloperationa[ Test (Aay1; COTin the 15)onceper31 sfays, anda ChannelCalibration ettry 92 t{ays on a StageredTest Sasis. % FIS relagdthe test intenulof the Channe[Checkto31 days in FTSSR333.1.
G is accepta6[e because it is consistent uith the FIS S* Trequencies esta6Gshelfor aKotherpost-accit{ent unonitoring fr%{} instrumentation. % ITS aho omittea the stageredtesting requiranentfrom the Channel CaG6ratiori in 15SR333.2. '1&is is aatytable because the hydrogen anonitors do not perform a mitigatite function. In addition, deleting the stageredtesting requirement simplifies scheduGng anduinpretlude missing a Channe(Calibration simply because ofa missedstagendtest intenul finaEy, the m omits the Cor *Inis is acceptable because the hyifrogen monitors arepassive elevices, t{o not initiate any automatic actuations, andare usedon(y duringpost accident conditions. % staffagrees that the revisedSRs are commensurate uith the anonitoringfunction of the hydrogen anonitors. 'Iherefore, these changes unich are consistent uith the STS, are acceptable.
5.
Tost-Arcident Sfonitorinn System Instrumentation - TevisedAction Trauirements j
CiQS CB3/433.6 Actions CNSCIS3/4.6.4.1 Actions CNS FI5333 Actions CHS33-L8 C.NS CI33/433.6 Action a andc a((ow 7 days to restore an inoperable channelofpost-accident rnonitoring (PMi)instrutnenta tion. Corresponding 115333 Actions A, S, andC reland this to 30 days. 'Ihis change is acceptable basedon operating egerience and6ccause these channels arepassist andperform no actuationfunction. In addition, the remaining operable channels, the remaining operable dittrse variable, or alternate anonitorir$g methoduidensure adequate monitoring ofplant conditionsfodourng an accident.
CMS 33-L9 CNS CTS 3/433.6 Action a and3/4.6.4.1 Action a require a unit shutdoum u6en one required TA%fchannelis inoperable andthe actions cannot be completedwithin the aEouthtime. TIS 333 Action D replaces the shutdoum requitanent uith a requirement to immediately initiate action in accordance uith TTS 5.6.7, *1%{ Report.' 'Inis change uiEaEow continuedoperation in this conditionforfunctions uith tum requiredchannels andfor those with one requiredchanneltf the associateddittrse channelor afternate anonitoring methodis operable, provideda specialreport is written to the NRC uithin 14 days detailingplanned correctite actions. 'Ihis change is acceptable 6ecause uith either a remaining operable channe{ or a dizerse operable channel the monitoringfunction is not fost.
In the ezent one channefof the containment area radiation inonitor or reactor coolant radiation fett[rnonitor is inoperable and the alterna te monitoring methodis also inoperable, the CTS uvuldrequire a unit shutdoum in accordance with CNS CIS3.03 6ecause CNS CIS3/433.6 does not speafy an action requirementfor this speafic condition. % FI5 addresses this situationforTMf radiation monitoring instrumentation by requiring, in ?IS333 Action D, that afone of the inoperable channels cannot be restoredto operable status uithin 7 days a specialreport uvuld6epreparedandsubmittedto the NRC uithin 14 days. 'Ihis is consistent with the STS andis accepta6(efor the reasonsgiten a6ott.
CMS 33-L10 CNS CIS3/433.6 Action 6 requires a unit shutdoum tf the minimum numberofoperable TMf channels cannot 6e restoredwithin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. % ETS refaqs this Completion ' Time to 7 days in ?TS33.3 Actions 'E andF. 'Ihis change is acctytable basedon the [cwprobability ofan etent requirir5g TMfinstrument operation andthe atui[ ability ofa(ternate means to obtain the requiredinformation.
Catawba and McGuiro Draft Safety Evaluation
=. 6.
Reactor Coolant System fTCS) LourTemperature Oitrvressure Trotection (UlOT) System - Addition of Alfonunce to Overate Tuv Cftaraina Tumps Concurrentfu l
S(S(S C53/4593 Action a atidfootno'te
- S(h(S ?S3.4.12 kquiredAction A.4 S{MS3.4-L.26 In the ettnt tuo ormore centnfuga[chargingpumps or tuo or more safety injection pumps are capable ofinjecting into tfit reactor coolant system (RG) ufsen L'IM is required, CB3/4.4.93 Action a requires immediately redudng the number ofcapablepumps to the number allourdby CB3.4.93. 9(outztr, Fo' otnote
- to 05 Action a specsfies an eyeption to this actionfor the condition of tuo centnfugalcftarging pumps being capable. 'Inis egeption permits tuo capable centnfya(chargingpumps afien tuoyoutr-operatelrelief tultes (IOR%) are securedopen uith blockvaftes open unth theiryoutr remoted 153.4.12 Action A alsopermits this alTouencefor tuo capable chargingpumpsfor the additionalafternatite condition in kquiredAction A.4 that the RG is depressurizedandan RG vent ofgreater than or equalto 4.5 square inches is established. 'Ihis change is acceptable because the tent size uus evaluatedin the S{A(S [ou' temperature oserpressureprotection analysis andis apprcqimatedby the tuo open TOR %. 'Ihat is, u4th tuu capable chargingpumps, the lettiofettrpressureprotection affordedby a tentedanddepressurizedRG is equitufent to thatprovide16y tuu TORVs uith open de-energize 16(ockva[zes.
7.
Reactor Coolant System Leafaae 'Inetection Instrumentation - RnGedAction Tequirements CS(5 ands {}{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 o'1 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 syntem design.
CNS and MNS 3.4-L.12. In the event a containment atmosphere 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
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.
CNS and MNS ITS 3.4.15 Action B differs from the STS and the CTS because it does not require re~ storing the inoperable monitor within 30 days. In addition, the ITS does not adopt the STS's option to verify the Operability of the CVCDT level monitor within 30 days. Omitting these two STS action requirements is beyond the scope of the ITS conversion. The ITS emit 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 action requirement to verify the Operability of the CVCDT level monitor within 30 days is 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 requiret 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 thesis, if the C7LW(evelmonitoris operable, then the secondoptionalaction requirement uvuldbe taken, andoperation of the unit couldcontinue indefinitely. If the C1LW[ett[ monitor is not operable, how:ve, then this action requirement to strify the opera 6tlity of the C7tW(etelmonitor n'ithin30daysis unnecessary 6ecause the containment floor and equipment sump monitor and the containment atmosphereparticulate monitorwould be available 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 continde indefinitely with an inoperable containment atmosphere radioactivity monitor (gaseous orfaniculateforc$;gaseousforM$).
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 t.5.1.1.c CNS and MNS ITS SR 3.5.1.5 Catawba and McGuire Draf t Safety Evaluation
38 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 cited Westinghouse Nuclear Safety Advisory Letter (NSAL)97-003 to support this change. NSAL 97-003 addresses operating bypasses and compliance with IEEE 279-1971. The revised pressure setpoint is consistent with the operability assumptions 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 for Performina RWST Temperature Verification Surveillance CNS andMS(S OTS 4.5.4.6 CNSandMNS l'15SK3.5.4.1 cms andMMs3.M(.3 'Every 24 (wurs, CTS 4.5.4.6 requires senfying that the refueGng unterstorage tank (MVSI) temperature is uithin the range 70 *F to 100 *F "ufen the outside air temperature is less than 70 *For greater than 100 *F." 'InisSRis retainet(as rTSSR3.5.4.1. % ambient temperature condition is deletedso that the daily requirement to momtor the MVSTtemperature appGes utthout regardto tfie ambient temperature. tinder the current Section 4.5.4.6, Rcenseepersonnelhate to tenfy the outside temperature ezery 24 (wurs, ant (detennine if there is any need to senfy mVsruuter temperature; under the proposeifSR3.5.4.1, personne[ simply senfy the MVSTtemperature ezery 24 (wurs regardless ofoutsitle ambient temperature. %
proposedchange is acceptable 6ecause it increases the monitoring ofDVSTtemperature to unenezer the MVST is requiredto 6e operable.
10.
S(ydroaen Mitiaa tion System - Tethet(Minimum 9(umber o,fTeauiredS(ydrogen laniters pyygg MNS CTS 4.6.43.a y,7 MNS HSSR3.6.9.1 3g mms 3.6-A37 CIS 4.6.43.a requires that 32 of33 ftydrogen tyniters 6e operable on e train. Corresponding MSSR3.6.9.1 requires 34 ynitersper train to be operable. % actualdesyn contai jnitersper train.
l
'1his cfiange is administratitt 6ccause it corrects an inaltertent error in the CTS andis consistent uith current operation of the system. % correct num6er ofjniters uns increased as discussedin MNSSERSupplement 7, Attachment C, after thefirst refueling outage ofeacfs unit. G change corrects the 'IS uitfi the approted Rcensing 6 asis as describedin theSLRsupplement. '1herefore tfils change is acceptable.
11.
h.ejed-Telaxation ofST 'Treauencu to ' Verify 'lloron Concentration and16{
CNS andM.NS OTS 4.6.5.1.6.1 CNSandMNS FISSR3.6.123 packaround % boron in the ice of the ice 6edis usedto reduce the tv{atiGty ofradiciolines and to ensure ifiat the ozera86cron concentration in the sump is not dilutedduring the ice meltfollowing a destyn basis foss of coolant accident. %pS{of the icefacilitates remotufof ratliciodines andminimizes cetrosion uithin containment during the recirculation pfsase ofa desyn basis foss ofcoolant accident.
Catawba and McGuire Draf t Safety Evaluation j
39 cms 3.6-L26 c54.6.51.61 requires renfying ihe boron concentration and 9[of the ice 6edis utthin Gmits 7
onceper9 months, u6ich is tfe tut intenulpiten in the 35. correspnding MSR3.6.12.3 increases the suneiKance intennf to 18 months. Sampling of the ice 6askets isperfonnedat random by sampGng the topfew feet after remoting afewinches oficefrom the top of the basket. Datafrom past sampling of the ice beds indicata that there hate 6eenfewfailuresfor this suneiEance. G 6oron in the ice is in theform ofsodium tetn borate (a salt), andis not tv[ati[e eten though the la itsel may sublimate. As a result, not only uvuldthe f
boron concentration not deaease, it uGincnase in interseproprtion to the quantity ofla remaining. '1his uus demonstrated 6 past sunetKance data, showing that the Soron concentration associated 9[ routinely met 5
7 the acceptance criteria (speafulin c53.6.51.a andretainedin mSR3.6.12.3). According[y, theSK Frequemy may 6e relandto onaper18 months, consistent with thefrequency ofrefueBng outages. A 6enefit of this refgation is that it udreduce the number of routine containment entria duringpouer operation. G rela.zation is aweptable 6ecause of thefatorable antiEance recordandthe tendency of the ice bedboron conctntration to increase oter time.
mms 3.6-L26 c54.6.51.6.1 requires renfying the boron conantration and 9[of the ice 6edis utthin limits 7
onceper9 months, udich is the test intenulpiten in theSTS. Correspnding m SR3.6.123 increases the suneiEana intenalto 18 months. SampGng of the tu baskets is performedat random by sampling the topfew feet after remoting afewinches oficefrom the top of the 6asket. Data rom 6oron sampGng in the ia 6eds indicates that there hate 6eenfewfailures for this sunciEana i fAprt*o M86) de r[yfailure.nrw x&awmatinouted a the smisat ia loading or ice makeup techniqua in use at l
t time. During the initialyears ofoperation, ice subGmation rates uere fuyher than eqectedandsezeraf metfwds uere usdto increase the ice basket ueyht. %se incfuledreloading witfifreshflake ia, reloading with ice blocksfonndfrom a Boraxsolution in molds, andthe direct addition ofborax to the baskets. As a result, effective sampGngfor these 6askets sluring timeframe uns dafficult because t(se sample may not hate 6een representatite. % da:a revieuelfo rperiod(1SS6 to 19%) indicate that of the oter 500 e
6askets sampled 26 fuulconantrations [us than 18mppm, and that 7 of these 266askets utre reloas[d, and the remaining baskets uere attragedunth the other baskets.
% 6 aron in the ice is in thefonn ofsdium tetra 6 orate (a salt), andis not relatile eten tfwugh the ice itself may subGmate. As a ruult, not only avuldthe boron concentration not decrease, it uGincrease in interse proprtion to the quantity ofice remaining. '1his uns demonstratdbypast suneiEance data, sfwutng that the boron concentration andassociated 9[ routine [y met the acceptana criteria (speafiedin CB.3.6.51.a ans[
7 retainedin MSR3.6.123), eyept as notedabote. Accordingly, the SR7requency may 6e relagdto onceper 18 montIns, consistent unth thefrequerug ofrefuenng outages. A 6enefit of this re[a.tation is tf,at it uGreduce the number of routine containment entries duringpouer operation. % refantion is acceptable because of the faturable suneiEana recordof recent years and the tendency of the ice bed 6eron concentration to increase oter tirne.
12.
Containment %'alve lm ction WaterSustem - Deletion ofSurne'Tanf WaterSupply Tequirement and Teluction ofRequiredSealInfection 'llow Tate.
CNS C5 4.6.6.1 and4.6.6.2 CNS MSR3.6.17.1 andSR3.6.17.2 l
Catawba and McGuire Draft Safety Evaluation
i 40 Backaround
% containment suht injection uutersystem presents leakage ofcontainnwnt atnwsphere past certaingate vahts uselfor containment isolationfodouang a loss-of-coolant accident (LOCR) by injecting sea [uuter at a pressure egreding containment pressure 6etuten tuu stating surfaces of theflexedge tuhts as descnbedin C$ 11FSRRSection 6.2.4.2.2.
C9fS3 6-L23 C134.6.6.1 requires stnfication ettry31 days that the surge tanks of the system hatt a.% day supply ofunter. Corresponding 173SR3.6.17.1 omits this requirement because the nuclearsenice unter system (Qt$)is the assuredautomatic source of unter after a LDCA. '1he Q13 is desQnedfor fory tenn (30 day) cooling. kefore, it is not necessary in speafica8y require this to 6e tenfiedon a rnonthly 6 ash. 'Ihus the supply ofunter is assureduith or uithout the sunti8ance requirement. kefore, deletion of the surge tankuuter supply requirementfrom this sunti8ance is accepta6fe.
i C134.6.6.2 requires tenfyiry onceper18 months that system pressure is 2 45psy, andthat the systemflow rate is (ess than 1.7gpinforTrain A and1.4gymfor Train B uith a tankprusure 2 45ps@. he criteria are 6asedon tuu Qt5 pumps in operation. % 113 criteria are baselon a sitgle Qt$ pump in operation.
Speafica8, corresponding US SR3.6.17.2 requires aflow rate to be (as than 1.29ppmfor Train A and(as 5
than 1.16gpmforTrain B with a surge tankpressure 2 36.4psy. In its submittal, the [iansee statedthat at this (outrsurge tankpressure, thepressure at the vaht with thegreatest system headfossfrom the surge tankis 216.2 psy, uniich is 110 percent ofpeakcontainment pressurefo80uing a LOCR. 'Ihus speafying the required system prusure uith a surge tankpressure of 2 36.4psy is equitulent to specifying a system prusure of 216.2 psy. he changes in sunti8ance requirement acaptance criteria are acaptable 6aause they are adequate to i
ensure that the containment suht injection untersystem undperfonn its containment isolationfunction fodouing a desyn basis LOCA.
13.
S{ain Steam Safetu 'I'ahts (S(SSVsl-TettedAction Tequirements C$ CTS 3/4.7.1.1 Action a andTable3.7-1 C$ WS3.7.1 Action A andTable3.7.1-1 Backaround % main steam safety vahts are code safety tehts (fitt assoaateduith each of thefoursteam Benerators)andensure that the secondarysystem pressure uiE6e (unitedto within 110 percent (1304psg)ofits des @npressure of1185psy during the most setere anticipatedsystan operationaltransient. 'Ench vaht provides 20 percent of the relieving capacity. C$ CTS 3/4.711 adowsplant operation during the operational conditions ofSlot Stand 6y, Startup, andTouer Operation (S{ odes 3,2, and1) uith some of these tultes inoperableprovidedthe steamflow and thennalpouer are limited. % staff transmit tedWestinghouse's Nuc[ car Safety Aft 4 cry Letter (NS9L)94-OO1 to licensers by Informaticn Nptice 94-60, date.[ August 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.
I These new setpoints were calculated using the formula provided 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 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'
/nsert MM2-c./t t&l(,
VL 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 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 le proposed conversion from the CTS to the ITS for the CNSwd-MNS_ Arem%, ased upon l
the environmental assessment, the Commission has determined that issuance of this amendment will not avn a_si nificant effect on the quality of the human environment.
If N/)
Included in t se amenaments are changes that were beyond the scope of the 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 (62 FR 37628), and l
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 l
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 occupational radiation exposure. The Cornmission 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 l
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 environmental impact statement or environmental assessment need be prepared in connection with the issuance of the j
amendment.
Vill. CONCLUSION l
The CNS and MNS ITS provide clearer, more readily understandable requirements to ensure safer operation of the stations. The NRC staff concludes that the ITS 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 i
A Catawba and McGuire Draft Safety Evaluation
l l
Insert for Section V 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.
l The relocations are provided in Table LA of Removal of Information from the Current 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."
i
. Catawba and McGuire Draft Safety Evaluation i
~...,.,
TABLE A-ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION tigu - -
g3 _ -
- 3
_;% q pqcqG
%.: Te ; 5.Wy gg[; y ; q
~
h&
N
.M & qrg & &
- fhQ&f&
3'
- ~ n' n 'ai &-^==v
^
- V
\\
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 MOD 5 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 requirements.
i bM O
i 1.0 A.14 Not used.
1.0 A.15 in the o
excore detecfor is inoperable, the CTS definition of OUADRANT POWER SR 3.2.4.1 Note 1.25 1
TILT RATIO (OPTR) requires computing OPTR using the three remaining excore
[
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 i
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 l
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 app!! cable ITS SRs in the SR Frequency column, independent l
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.
6 i
(C) Catawba specific (M) McGuire specific j
Catawba and McGuire Nuclear Stations 3
f t
TABLE A-ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION 1
h 6
-. 3
'c
.i.
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 n 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." Th!s change is administrative because this note also 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."
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 and if l'
y gC~T.4 - Frequency, to ensure consistent understanding and use of the ITS format and presentation style. These new sections do not change any CTS operational restrictions or limits. Their addition is, therefore, an administrative 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 i
Table 1.2 was changed to NA (not applicable) in corresponding ITS Table 1.1-1. In the ITS, individual specification applicability statements specify the applicable average reactor I
coolant temperature limits in MODES 1 and 2. In particular, the 350*F MODE 1 and 2 temperature specified in the CTS table is unnecessary because the minimum required reactor coolant temperature for MODES 1 and 2 is specified in the appropriate ITS l
Section 3.4 specifications. The ITS definitions for MODES 1 and 2 retain the CTS theshold values of reactivity (14) and thermal power level. These thresholds are the i
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
i
TABLE A-ADMINISTRATIVE CHANGES SECTION 1.0 USE AND APPLICATION icis60isf6 Mis $$E Jjdh.3%[pisg-1 WMO@nM Tik,R ;f'f Of.1 WMt
's t
' 7-af-A TOG'CHARdliEy WMt
(
3 ~ ~ ~ - ek-g 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 clarite or completeness to preclude misinterpretation. Specifica!!y, 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 actualindustry practice.
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 upper 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 consistant with current practice.
1.0 A.24 The CTS definition of CHANNEL CAllBRATION 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 fucctions and do not have a " required
- display function. However, CTS 4.3.3.6 ru ms a calibraibn of the post accident monitoring channels. The safety function performt Oy these channc% is a display function only. Therefore, the inclusion of required displays within the ITS definition of CHANNEL CAllBRATION is an administrative change because it is consistent with the CTS calibration requirements for the post accident monitoring system instrumentation channels and with current practice.
I f
1 (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 5
TABLE A-ADMINISTihTIVE CHANGES
^
SECTION 3.2 POWER DISTRIBUTION 1.lMITS WM.%y$$hM XY@ifl S M 97 ~ ( '
fEh SN.M E ~ "
'J) P "N-d M Nf)& Q gh'.E f @ Mhwuig:pc4gLg kihl$di[5NdAE
.g,{ypfl jp Mjp chgjmp=.6 ceg;iggsstrEnate 4WMg
?OFldH NGE$
3.2 A.7 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 meet the required actions if, prior to reducing power below 75% (or 50%), Fn@M is a
restored within limit. No technical requirements are added or deleted by this change.
3.2 'A.8 The CTS Action that allows operation to proceed and THERMAL POWER to be increased 3%d 3,2&fc'tions,.
l*
provided Fs(X,Y) is demonstrated within limit prior to increasing THERMAL POWER y,g*g,4ejg,3 y,,.),3 ge,j7,3 g a
whenever power is reduced because FL(X,Y) is not within limit has been reformatted as a l
Note to the required actions in ITS Actions.
3.2 A.9 The CTS allowance for an exemption to the provisions of Specification 4.0.4 that a!! owed SR 3.2.2.1 4.2.3.1 the plant to change MODES (enter MODE 1) without requiring the Surveillance Requirement to be performed is retained in the Frequency requirements of the corresponding ITS Surveillance Requirement.
3.2 A.10 The CTS Surveillance Requirements for verification of hot channel factors after the OPTR 3.2.4 Actions 4.2.2.2.b and 4.2.3.2.b l
indicated by the excore detectors is normalized using incore detectors was converted to an action in the ITS OPTR LCO. The CTS requirements are retained intact in the form of Actions.
~
l 3.2 A.11 Not used.
i 3.2 A.12 The CTS SRs fora determination that Fan is within the surveillance limit and for an SR 3.2.2.2 4.2.3.2.c.1 and extrapolation of recent Fas measurements to determine if the surveillance limit would be 4.2.3.2.d r
exceeded in the next 31 EFPD were reformatted and retained in the corresponding ITS f
Surveittance Requirement. No, technical changes were introduced when reformatting the CTS requirements.
3.2 A.13 The CTS Surveillance contains Actions if the Fan surveillance margin has not been met.
3.2.2 Actions 4.2.3.2.c.2 The Action requirements in the Surveillance are redundant to the Actions provided in the I
associated LCO. Since,if the Survei!!ance was not met the LCO Actions would be applicable, the Actions contained in the CTS Surveillance are not required and have been
- deleted, t
I t
(C) Catawba specine (M) McGuire specific 2
Cetawba and McGuire Nuclear Stations I
J
TABLE A-ADMINISTRATIVE CHANGES.
SECTION 3.3 INSTRUMENTATION Ef90' E T j%Q[%5@ ?
igys6bf5M
" " L E '
p" M )
h UOYCHAMUE4 jF4MO.
g nuer n-1, mets.
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 i
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.
j 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 f
Function. The Note provides explicit 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 i
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," " Channels to Trip," and (C) Tables 3.3.2-1,
'Tabte 3.3-3 I
- Minimum Channels Operable" was replaced with one ITS column that lists the, " Required 3.3.6-1, 3.3.7-1, and Channels.' The ITS actions classify inoperabilities based on the required channels, 3.3.8-1 i
whereas the C'S actions were constructed based on total channels and minimum number g
of channels. A clar4ication was also made to the APPLICABLE MODES column. The (M)Tabitr3.3.2-1 l
l phrase "or other specified conditions" was added to the APPLICABLE MODES column g
title. This change is intended to cover the Notes used to modify the modes listed in this
( ) 3'3' b column. The Notes modify the modes in the Table 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.
l I
(C) Catawba specific f
(M) McGuire specific 1
f Catawba and McGuire Nuclear Stations 6
l
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION GG l
3.3 A.60 (C)
The CTS ESFAS Control Area Ventitation Operation function which includes requirements 3.3.7 3.3.2 for a loss of power initiation with specific channel requirements, actions, and surveillance requirements was moved to the ITS LCO specifically for this instrumentation (3.3.7). The requirements for the loss of powerinitiation feature of this system are redundant to other TS requirements and were eliminated from the new ITS instrumentation LCO for this system.pe loss of power DG start function is addressed by ITS LCO 3.3.5 and the f
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.
3.3 A.61(C)
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 protection mode if automatic transfer to the chlorine gas protection mode is inoperable.
This addition is cons' stent with the requirements of CTS 3.3.3.7 which has been relocated l
from the TS.
3.3 A.62 (C)
T he CTS requirements for the Auxiliary Building Fittered Ventilation Exhaust System 3.3.8 3.3.2 (ABFVES) actuation instrumentation were moved to a new LCO in the ITS.
3.3 A.63 (C)
A Note was added to the CTS that allows separate condition entry for each ABFVES 3.3.8 3.3.2 Actions 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 t
existing actions for the ESFAS Instrumentation.
3.3 A.64 (C)
The CTS requirements for survelliance testing of the Source Range Neutron Flux Monitore SR 3.3.9.6 4.3.3.11.2.a consistent with CTS Table 4.3-1 when relying on these monitors to meet the requirements SR 3.3.9.4 Table 4.3-1 I
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.
3.3 A.65 The CTS requirement for a TADOT on the manualinitiation function for Containment SR 3.3.6.4 Table 4.3-2 Purge and Exhaust was revised to clarify that verification of the setpoint is not required for l
the surveillance. The TADOT definition includes setpoint verification, however, this is a manual actuation with no associated setpoints.
[
(C) Catawba specific j
(M) McGuire specific Catawba and McGuire Nuclear Stations 12 i
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION Idid6USEI6N) @WWQh.6.g ;.. x eyew.Wed$ws.=.(; E M@N#W iM$N'EEi7
'4
~N'
' WN # ?WM Mpi iId6CNANGE$
3.3 A.66 CTS requirement for a TADOT on the manual initiation function for St. Containment Spray, (C) SR 3.3.2.8 Table 4.3-2 Phase A, Phase B, and Steam Une isolation was revised to clarify that the verification of (M) SR 3.3.2.7 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.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 thts 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 Table 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.
September 30,1986, via license amendments 13 and 5 for Units 1 and 2, respectively.
[
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 i
subject filter time constant was never actually implemented.
f 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.
i l
1 3.3 A.70 (C)
The CTS Channel Calibration requirement for the overtemperature and overpower detta T SR 3.3.1.10 Table 4.3-1 i
functions was revised by the addition of a clarifying note which states that the surveillance f[
sha!! include verification that the time constants are adjusted to thefroscribe alues. The overpower and overtemperature delta T functions have several time constants speci i
-6[
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 l
reminder that the Channel Calibration should include the time constants.
{
I i
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 13
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION l
F GE
+
n gl3;se 3.3 A.71 A new ITS Note has been included in the ESFAS Channel Calibration survei!!ance (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 i
Time constants are specified in the ESFAS as part of the setpoint. In CTS Table 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 setpoint, the addition of the ITS note provides a clarification and does not introduce a technical change in the calibration of any ESFAS function.
I 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 i
Testing that provides an exception for the performance of Response Time Testing of the (M) SR 3.3.2.9 t
Turbine Driven AFW pump. The addition of this ITS note is consistent with an existing CTS 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 i
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 Table 3.3.2-1 Action #25 k7 loss of one entire train (less than the minimum required number of channels operable or Function S.e f
more than one channel inoperable). Therefore, the typical conversion to the ITS of the 9 S 3,p.y l
CTS Total number of channels with an Action for one channelinoperable does not apply.
Conditions L and M L
Instead of the total number of channels being used in the ITS
- Required Channels" column, the CTS specified minimum number of channels per train is used in the ITS. The i
ITS Required Channels and Action Conditions preserve the CTS requirements in the ITS format.
I (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 14 j
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.3 INSTRUMENTATION GE 3
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 Table /3.3-3, Table
)
P-11 interlock and may be blocked below P-11 when Safety injection on low steam line 4.d.(2)
Notation ##
pressure is not blocked
- was revised in the ITS Applicability to state the signal may be blocked below P-11 when Steam Line isolation Steam Une 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.
(C) Catawba specific L
(M) McGuire specific Catawba and McGuire Nuclear Stations 15
l TABLE A-ADMINISTRATIVE CHANGES
/wCNSAN( Janary/2/f45 SECTION 3.4 REACTOR COOLANT SYSTEM g g. g
.~....
I 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 f
month interval was left over from a previously deleted requirement to perf a precision heat balance to determine RCS total flow. This requirement was delete y license
'i amendment dated February 17,1995 (TAC Nos. M88480 and M88658). The deletion of this requirement should have included 4.2.5.3. As the resulting CTS 4.2.5.3 is effectively l
the same as the requirements 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.
l 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.
1 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 i
the STS and split into two separate Actions. This change 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 f
-2% was revised to apply the tolerances to the setpoint and state the limits as 22435 psig and52559 psig.
3.4 A.11 The CTS Actions were revised by the addition of a note to indicate that separate Condition 3.4.11 3.4.4 i
entry is permitted for each PORV. This Note provides a clarification of the ITS format for j
permitting multiple entry into the Conditions, as described in ITS Section 1.3, Completion l
Times and is consistent with the intent of the CTS requirements.
f 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.
3.4 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. Thbse types of cross references are not used in the ITS.
l i
(C) Catawba specif.;:
(M) McGuire specific Catawba and McGuire Nuclear Stations 2
f I
s
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM
[.Qf Q Q.
. ! > [. ~ [
~
~
1 6':j 3-
$hwd.iw *5 Cdget:
, ] 7y.. l l
3.4 A.14 (M)
A note has been added to the applicab!!ity 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,i.e., the actions place the unit outside the mode of applicability. The CTS Action has also been clarified to include this statement.
l 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.
l i
l l
3.4 A.16 Not used.
3.4 A.17 The CTS Act!on 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 and collected into a single Action in the ITS.
3.4 A.18 The CTS requirement for an ANALOG CHANNEL OPERATIONAL TEST or ACOT 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 I
aspects of the ANALOG CHANNEL OPERATIONAL TEST. Any changes to the definition which are the result of the changes in[(ny)n 1.1, are described in the Discussion of l ;,
ctio Changes for that section.
3.4 A.19 Several CTS serveillance requirements have been combined into one ITS surveillance SR 3.4.12.1 4.1.2.3.2, 4.1.2.4.2, requirement.
4.5.3.2 t
(M) 4.4.9.3.3 3.4 A.20 The CTS interval for verification that the RCS vent is properly maintained has been (C) SR 3.4.12.3 4.4.9.3.2 i
reformatted from an SR and footnote, to a SR with two Frequencies. The intevals (M) SR 3.4.12.4 i
retained in ITS remain the same.
3.4 A.21 The CTS requirements regarding the RCS Controlled Leakage have been moved M a 3.5.5 3.4.6.2.e and separate ITS specification for Seal Injection Flow.
4.4.6.2.1.c 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 (PIV) section c. 4.4.6.2.2, Leakage.
and 4.5.2 (C) Catawba specific (M) McGuire specific r
Catawba and McGuire Nuclear Stations 3
i i
i f
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM k
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.
.i 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.
L 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 i
ciarified 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 change clarifies that tFis monitor is a level monitor in the containment floor and equipment sump. Leakaps rate or flow is actually calculated by a rate of change in level i
using the plant computer.
3.4 A.42 The CTS requirement that the reactor coolant DOSE EQUIVALENT l-131 5 0 pCi/gm be SR 3.4.16.2 Table 4.4-4 1
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 f
surveillance to ensure iodine remaine w: min limit during normal operation and following fast power level changes when fuel failure is more likely to occur. Power level changes l
>15% cannot occur in MODES 2 and 3.
3.4 A.43 (M)
The CTS Actions that take exception to declaring the PORVs inoperable due to inoperable 3 4.11 Required 3.4.4 Actions e, f, and i
l block valve actions which require disabling the PORV were Gitainedin3he ITS Actions for Act'ons B.I and B.2 g
t one block valve inoperable. This exception is not necessary for two three block valres inoperable since the actions do not require disabling the PORV for th se subsequent inoperabilities.
I 0 COO f
(C) Catawba specific j
(M) McGuire specific i
i f
Catawba and McGuire Nuclear Stations 6
t
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.7 PLANT SYSTEMS
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. 3.7 A.34 (C)
The CTS surveillance requirement fo ihe control room and nearby area temperature was 3.7.11 3.7.6, 4.7.6 a.
revised into a separate LCO for"Cc'irol Room Area Chiiled Water Systems (CRACWS "
The creation of a new LCO for this squirement is a change in format and presentatio the l;
limits and intent of the CTS SR were retained.
3.7 A.3S (C)
The CTS Action requirements for inoperable ventitation 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 S.0," Administrative Controts". The applicable ITS SR is constructed to require the testing in accordance 'vith the Ventilation Filter Testing Program as described in Chapter 5.0.
No technical enanges to the requirements were made.
3.7 A.37 The CTS SR requirement for an actuation test signal to be used during testing was revised (C) SR 3.7.12.3 4.7.7 d.2 to allow an actual, as well as a simulatec test signal, to meet the Surveillance Requirement (M) SR 3.7.11.3 in ITS. The acceptance criteria of the survei!!ance remains unchanged and unaffected by this revision.
j 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 I
4 were revised by the addition of an Action to enter LCO 3.0.3 with the loss of 2 (C) 3.7.12 CRACWS trains. This addition does not change the CTS which implicitly required the (M) 3.7.11 i
same Action.
3.7 A.39 The CTS requirement for the Operable Fuel Handling Ventilation Exhaust System (C) 3.7.12 4.9.11.1 (FHVES) 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.
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 6
i TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS
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SONCHANDER s 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 LCO 3.8.1 l
CTS LCO. The OPERABILITY of the sequencers is required by the SRs in CTS 4.8.1.1.2 gg ggg to demonstrate OPERABILITY of the diesel generators. Therefore, this change only clarifies the CTS operability requirements.
M /* /* M
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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 electrical 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.
l 3.8 A.4 Not used.
3.8 A.S 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 l
is administrative because the note reflects the CTS 3.0.1 requirement to meet the l
associated action requirements fo LCOs that are not met-in this case the action requirements for any denergize a istribution bus. This note is needed because the ITS I
contains a new provision, LCO 3.. i, which would only require entering the Actions of ITS 3.8.1. The ITS 3.8.1 Note to Action D wt ich requires entering ITS LCO 3.8.9 is an l
exception to ITS 3.0.6 See Table F/l, DOC 3.0-M.3 regarding ITS LCO 3.0.6.
I (C) Catawba specific (M) McGuire specific Cetawba and McGuire Nuclear Stations 1
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS
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3
. l 3.8 A.11 Three ITS SR Notes were added to the CTS SR. The Notes maintain the technical SR 3.8.1.2 4.8.1.1.2.aA f'
requirements of the CTS and onry represent a change in presentation and format to A
conform with the ITE stsie.
/
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 invoMng 4.8.1.1.2.a.4 ITS note used in each applicable ITS SR consistent with manufacturer recommendations.
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.S 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 l
i 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 invalidate the test. This change is considered a clarification of the existing requirements l
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 l
_l 3.8 A.16 Not used.
s (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 3
TABLE A - ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS 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 also 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 TuS5ystems maintain @s the current interpretations for required DG subsystems. Thus, this specified in the CTS sources LCO. The addition of the new requirements for these change is administrative.
3.8 A.27 A Note was added to the DG support system requirements to a!!ow 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 Completion Times g,g,ggy gg of the support system Actions Conditions are not met. The addition of the ITS Action does 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
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Section 5.0, Administrative Controls. The corresponding ITS SR refers to the 5.5.13 4.8.1.1.2.f.
requirements in Section 5.5.1Q but does not modify any technical requirement
- 73gypg (M) 4.8.1.1.2.c and 4.8.1.1.2.d.
3.8 A.30 Not used.
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
t TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS 6 ':. W C = a
/
-.I N 3.8 A.47 (C)
In the event either battery EBA or EBD inoperable, CTS 3/4.8.2.1 Action d allows 10 days 3.8.4 Action A 3.8.2.1 Action d 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 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.
3.8 A.48 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 4.8.3.1 maintains the technical requirements of the CTS.
(M) 4.8.2.1.1 and 4.8.3.1
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3.8 A.49 Portions of two(CTSspecificationhere reformatted and used in the new ITS specification 3.8.9 3/4.8.3.1 3/4.8.2.1 for" Distribution Systems - vperaung" No technical changes were made to the CTS requirements.
l3/4.8.3.2 3.8.10 3.8 A.50 The CTS specification is reformatted into the ITS specmcation for Distribution Systems during shutdown. The technical requirements of the CTS are maintained.
l j
l 3.8 A.51 Not used.
3.8 A.52 Two CTS SRs are combined and refc: matted to form a single ITS SR. The technical SR 3.8.10.1 l 4.8.2.2.1 and 4.8.3.2 l
requirements of the CTS are maintained.
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j (C) Catawba specific 7
(M) McGuire specific i
8 Catawba and McGuire Nuclear Stations 4
TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS G
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3.8 A.53 (C)
The CTS actions requirements in the event one or more required electrical distribution 3.8.10 Required 3.8.3.2 Actions subsystems are inoperable were revised by the addition of new ITS action requirements.
Action A.1 Tliis" abs ~ s ITS 3.8.10 Required Action A.1 requires immediately declaring inoperable associated i
Mill" nder taff supported featuresyt.icepsee to exclain nowanis is consistent witlithe curreDP l
fdiii ;
Imercretauon _oune CTSV meet aWacAed Attematively, the operators may follow ITS 3.8.10 Required Action A.2. Required Actions 3.8.10 Required 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.
~
n addition equired Action A.2.
quires immed ely declariDytf$e associt RH 8
Re irep' subsy inoperable and in operation. ' ~' nsee'.to exDf5IhWtf 6dnsisish ion,. 5/
i (wi.t. e~ctIrFnfiht6rpr318Uoliof,the UTS!
dded lyWM /)f./
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.
Thi'chandsiT5htirnedIfflT571DGeliSRTire;adfRrnis!FiWe~becidsTihs 6En~cT65 technibat 6hW6gssfrith[re:htd6tf6tjil;dflths' CTS)requir&hients'nW6odslitshtWith7th~e 60ffeht16taipfut&ti6h 6fJh wy[sa/sof s
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 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 days for CTS 3.8.2.1, for batteries _ replacement e ompletek_perore apo#atM f
was deleted. The applicable modifications i Qpergbog1icense anjerament issjymfthe ITJ;)thus t e ex
' n provided by the note is no longer required.
, pp 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 c 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 ce!!s was deleted. This type of cell 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.
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 9
l l
l I
Insert 3.8 A.53 (C) l
)
l.
The CTS definition of OPERABILITY requires the normal or emergency power source, therefore, if the bus were deenergized, the supported equipment wocid be considered
)
inoperable. The addition of ITS 3.0.6 would not specifically require the actions of J
L supported equipment be taken, therefore this action maintained this option.
4 l
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Catawba and McGuire Table A 3.8 DRAFT SER 1
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6 l COW TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEj#
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s ;L=cupe,i i 3.8 A.57 (M)
Th CTS LCO note which provides conditions when an inverter m e disconnected from 3.8.4 Required 3.8.3.1 Note f
4f its e 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 satisfied as 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 4
hours providec' 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 wits the corresponding ITS Action but maintains the technical content of the CTS.
l 3.8 A.59 Not used.
4 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 l
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 ver.t was retained and reformatted consistent with the ITS. EEI6M65HM ITS 3.8110 req @UifBTActIUftN.
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2
.i change maintains the technical requirements of the CTS, and is administrative.
Shadtnq l
3.8 A.61 Not used.
l 3.8 A.62 Not used.
l j
3.8 A.63 Not used.
l
' 3.8 A.64 Not used.
i l
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
- l which also states that it applies to both units are clarifications that were deleted. The deleted clarifications were applicable to shared system!!dthd necesjary wnen Dot (15 wer3,e6mbined. LiGwpwapvaas=E vu=3=piv.mur.guuurprONT@@gunits) sj f
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e xco s.o.t ad S & 3.o,5 stok dat ico.s ud S&S Aff Y h t'CI! UMY lYi*W""5b l
(c) catawba specific (M) McGuire specific ffs g [c o ffro f g & p g gf d g g { g g g g sy M e s S d q,
y Catawba and McGuire Nuclear Stations 10 f
1 TABLE A-ADMINISTRATIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS
^
The CTS Actions were clarified to require ITS LCO 3.0.3 to be entered immediately if two 3.8.9 3.8.3.1 and 3.8.2.1 3.8 A.67 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.
TAIS 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 nesd only be energized (inverter or regulated voltage transformer) consistent with current requirements and the definition of operability.
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i b
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i F
(C) Catawba specific (M) McGuire specific Cetawba and McGuire Nuclear Stations 11 i
r TABLE A - ADMINISTRATIVE CHANGES SECTION 5.0 ADMINISTRATIVE CONTROLS bwu i
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5.0 A.10 -
Not used.
t 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."
t 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 ITS because the individual reports described in the CTS and retained as ITS have been except 5.6.4 t
modified to include the required submittal dates.
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 f ;
any CTS restrictions on plant operation.
4 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 Surveillance Program."
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, 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
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, Reactor Building Containment Purge System; and a.2, b, c.1
[
Fuel Handling Ventilation Exhaust System Catawba - 4.6.1.8.b.1, b.2, c, d.1, d.5; L
4.7.6.c.1, c.2, d, e.1, e.4; 4.7.7.b.1, b.2, c, i
d.1, d.5; 4.9.4.2.b.1, b.2, c, d.1, d.2; and 4.9.11.2.b.1, b.2, c, d.1,d.4 i
L (C) Catawba specific (M) McGuire specific i
Catawba and McGuire Nuclear Stations 2
I TABLE M - MORE RESTR!CTIVE CHANGES SECTION 3.3 INSTRUMENTATION
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-4 3.3 M.6 The CTS Actio Turbine Trip-Low Emergency Trip Fluid Pressure (Interlocked with P-9) 3.3.1 N 3.3.1 Action 6.a m/
f, and 11 for Turbine Trip-Turbine Stop Valve Closure requires an LCO 3.0.3 entry if an
[M/045 Ou
//
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.
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 i
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
. l 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 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 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 range neutron flux monitor becomes inoperable. This CTS Action was revised by the addition of requirements to suspend all j
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 operationa! 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 Table 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),
i 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 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> 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 pdor to beginning the shutdown.
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 2
^
l
. l
TABLE M-MORE RESTRICTIVE CHANGES SECTION 3.4 REACTOR COOLANT SYSTEM (RCS) e
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3.4 M.15 Not used.
3.4 M.16 Not used.
3.4 M.17 The Frequency of the CTS SR to verify all but one charging pump is inoperable 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 lenguage. 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 coofant 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.
3.4 M.20 in the event the containment floor and equipment sump monitoring system is inoperable, 3.4.15 Action A 3.4.6.1 Action the CTS allows continued operation for up to 30 days. The ITS retains this allowance but adds the conditional action to perform a precislori water balance of the RCS 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 during this 30-day period.
I h.4M.21 The restri range of operation region in CTS 3. 5 Figure 3.2-1 has been effited.
3.4.1 Figure 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 cool system flow be 382,000 gpm, regardless of the owerlevel. This change w mede because e restricted range of operation is n nger supported by the existi safety analysis described in LER 97-10 for M
~ e Nuclear Station and LER 97 for Catawba N ear Station. goleawtsyga/wa. oppengem psgujpgmancypyn gn_eJeyJsecjjydiIguAre o
exml
/
/
~ AO!d&/75(,g)ffgggl;hyjgGyf b
Cf
- f/Y (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 3
i TABLE M-MORE RESTRICTIVE CHANGES SECTION 3.7 PLANT SYSTEMS e
l 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 /> es 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 />.
[
t 3.7 M.3 The exception in the CTS MSIV Applicability in Modes 2 and 3 was revised by the addition 3.7.2 3.7.1.4 of a festik,iien requiring that inoperable MSIVs be de-activated as well as closed.
t 3.7 M.4 The CTS Actions to ciose 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 l
closed once per 7 days.
2 i
3.7 M.5 The CTS Plant Systems Section was revised by the addition of a new LCO containing 3.7.3 3.7 requirements for the Main Feedwater Control Valves (MF s), Main Feedwater Isolation Valves (MFIVs), their bypass valves and the(temperin~g va The new ITS requirements f!
add an LCO, as well as the associated Actions, ano survema Requirement for the (cTir ye pp yyo)gwAfggg& & h s M/pgsfM)]}
l valves.
3.7 M.6 (M)
The CTS Plant Systems section was revised to include specifickEirements for the 3.7.4 3.7 l
Steam Generator Power Operated Relief Valves (SG PORVs). The new requirements i
include a new LCO, Actions, and Surveillance Requirements for these valves.
j 3.7 M.7 The CTS requirements for AFW were revised to include requirements to address the 3.7.5 3.7.1.2 condition where a steam generator is being required for heat removal in Mode 4. In this I
condition, an Operable AFW train muct be available to supply a source of makeup water to i
the required steam generator. This change represents new operability requirements for the AFW.
l 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 j
requirements of the LCO. This addition represents a new restriction on plant operation.
I i
I t
(C) Catawba specif'c (M) McGuire specific Catawba and McGuire Nuclear Stations 1
TABLE M - MORE RESTRICTIVE CHANGES SECTION 3.7 PLANT SYSTEMS k
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 survell!ance to periodically 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 invofve actions to a!!eviate 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 3.7.6 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 radioiodines and once per 6 months whenever the gross radioactivity determination indicates concentrations less than or equal to 10% of the allowable !!mit for radiolodines was revised to simp equire the DOSE EQUIVALENT I-131 to be determined once per 31 days, regardiess of the gross radioactivity.
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 2
j 4
TABLE M-MORE RESTRICTIVE CHANGES f
SECTION 3.8 ELECTRICAL POWER SYSTEMS f. o.,, e w hhf;hi[ Y T Y N
E'"
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[Nk[M[N ND MY O~"42Y 3 j,u.
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yg.gg a..7 7
[
a 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 Action c (C) d(Af) {!
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 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 i
feature are inoperable.
L i
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.
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, -
sunreillance 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 4.3.1.1.2.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, t
a DG power factor of s 0.9.
4.8.1.1.2.e.8 t
3.8 M.E 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) l emergency bus be verified to remain energized from the (M) 4.8.1.1.2e.5 i
offsite source after the DG start.
i 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
,I was revised to include acceptance criteria for both @@rjptfhishvoltage and (M) 4.8.1.1.2.f l
frequency requirements.
~
3.8 M.8 Not used.
l 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 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.
I (C) Catawba specif'c i
(M) McGuire specific t
a t
Catawba and McGuire Nuclear Stations 1
l t
m.
[
f TABLE M-MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS
. _ ~
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j
[
3.8 M.11 Not used.
[
3.8 M.12 Not used.
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; f
thus ITS would requires immediately entering LCO 3.0.3 which requires a plant shutdown.
L 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 verify that the battery cell parameters 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.
g 3.8 M.15 The CTS battery cell parameter requirements were revised by the deletion of the 3.8.6 Table 4.8-3, footnote f
k temperature compensation allowance from the float voltage limit of Category B parameter Table 3.8.6-1 (6) (c), foo(note (c/N) }
requirements. This change also deletes an allowance to adjust the float voltage range.
3.8 M.16 The CTS Actions were revised by the addition of a second Completion Time requirement 3.8.9 Actions 3.82.1 Actions to limit the time the LCO is not met. This additional requirement limits the time from -
3.8.3.1 Actions I
discovery 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.17 The CTS Applicability requirements for the AC or DC sources or inv rters in MODES S or 6 3.8.2 (C)
(C) 3.8.12, 3.8.22 I
was revised to include "during movement of irradisted fuel assem tes."
3.8.5 and 3.8.32 i
(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 l
inimediately: declare the affected required features inoperable, uspend Core Alterations, 3.8.10
{
suspe nd movement of irradiated fuel assemblies, initiate action to suspend operations involiing positive reactivity additions, and initiate action to restore required equipment to OPERABLE status.
l For ?noperable distribution systems, the ITS also added requirements for cascading to the l
appiicable RHR LCO and declaring the affected LTOP features inoperable. (g) l 3.8 M.18 Not used.
3.8 M.19 (C)
The CTS DG requirements were revised by the addition of specific c.urveillance SR 3.8.32 and 4.8.1.1 i
requirements for the lubricating oil inventory and the starting air receiver pressure.
3.8.3.4 i
(C) Catawba specific l
(M) McGuire specif~c Catawt>a and McGuire Nuclear Stations 2
t
TABLE M - MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS falo no/f5
,, g g xn, m, mg.,
-; DISCUSSION (
W=
, gf,~ 1a-g jg; g. j a v eD & (3M f,.L.h.7
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- Ye * $ 415 n;;c, G., O > g g ;:3@t@ g g 50MMARYQP;CHANGG ph_.
~m W (ITS. REQUIREMENT 4 JCTS Rad 0lAEMENTi YOKCHANGEN 3.8 M.20 The CTS DG survei!!ance requirements were revised by the addition of The Note' (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 immediate' (M) 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 o.i.e diesel.
3.8 M.21 Not used.
3.8 M.22 (M)
Me CTS Applicability was revised by the addition the condition of " movement of irradiated 3.8.2 Applicability 3.8.1.2hliedfiiIih f
f >el assemblies." This change requires the necessary electrical equipme't 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 gations of fuelin 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 survei!!ance 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 /> run SR 3.8.1.15 (C) 4.8.1.1.2.g.15 was revised by the addition of a requirement to verify steady state voltage and frequency (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 oil 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 DG 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 eoualizing 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 2 440 3.8.4 4.8.2.1.2 d.2 amps for 60 minutes while maintaining the battery terminal voltage 2105 VDC.
(C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 3
TABLE M - MORE RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS mam-maest If the regulhaources are inoper)ble when the plant is in Mode 5 with the RCS loops '
3.82 Required 3.8.1.2 Action 3.8 M.29 not filled or in Mode 6 with water leve less than 23 feet, the CTS requires immediately Actions A2.4 and initiating action to restore the requi sources to operable status. This action B.4
}*
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.
l Table 4.3-8 3.8 M.30 The CTS limits for battery cell specific gravity which specify that battery charging current Table 3.8.6-1 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 (C) Catawba specific (M) McGuire specific Catawba and McGuire Nuclear Stations 4
= -
t TABLE L-LESS RESTRICTIVE CHANGES SECTION 3.1 REACTIVITY CONTROL SYSTEMS 3.1 L1 The CTS LCO for " Shutdown Margin - T, greater than 200 'F" was revised by the 3.1.2 IV ll addition of appropriate actions consistent with the associated surveillance 4.1.1.1.2 i
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 i
surveillance 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 j
in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
I 3.1 L2 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 i
and if not within the limit, to continue the surveillance and measure MTC every 14 i
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.
t 3.1 L3 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 j
3.1 L4 Not used.
i 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 Vil minutes prior to withdrawal of any control rods during an approach to criticality was j
deleted.
3.1 L 6 The CTS Actions which add ~ess 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.
1
(
(C) Catawba specific Categories:
1.
Relaxation of Applicability V.
Relaxation of Survei!!ance Requirement (M) McGuire specific IL Relation of Surveiffence Frequency VI.
Relaxation of LCO and Administrative Controts l
III. Relaxation of Completion Time Vll.
Deletion of Surveillance Requirement IV. Relaxation of Required Actions VIII. Deletion of Requirements Redundant to Regulations i
Catawba and McGuire Nuclear Stations 1
f
TABLE L-LESS RESTRICTIVE CHANGES i
SECTION 3.3 INSTRUMENTATION l
3.3 L1 The requirement to reduce the power range neutron flux high trip setpoints is 3.n1 Condition D 3.3.1, Action 2c IV r
deleted.
~
y 3.3 L2 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 l
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 L.3 The CTS requirements for the intermediate Range Neutron Flux instrumentation 3.3.1, Condition H 3.3.1 Action 3.a IV l
(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.
i 3.3 L4 The CTS requirements for the RTBs were revised by the addition of a one hour (C) 3.3.1 Action 3.3.1 Action til I
Completion Time to restore the RTBs to operable status. This one hour is in Q
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.
(M) 3.3.1, Action t
R
[
h.2C
[!
3.3 L 5 The CTS 3.3.1 S/U (startup) frequencies for the Power Range Neutron Flux Low, SR 3.3.1.7 and Table 4.3-1 Source Range Neutron Flux, and Intermediate Range Neutron Flux Channel SR 3.3.1.8 j
Operational Test requirements were revised from 31 days prior to startup to 92 t
days prior to startup.
e t
3.3 L.6 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 l
\\
i
'M 4CYicri d,(MC (()
(C) Catawba specific Categories:
1.
Relaxation of Applicability V.
Relaxation of Survei!!ance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controts Ill. Relaxation of Completion Time Vil Deletion of Surveillance Requirements IV.
Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 1
[
l
[
i b
TABLE L-LESS RESTRICTIVE CHANGES 1
SECTION 3.3 INSTRUMENTATION 5.
3.3 L9 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 channel is inoperable and the actions cannot be completed C and H and 3.6.4.1 Action were revised to allow continued operation in this condition for functions with two a
required channels and to those with one required channelif the associated diverse channel or attemate monitoring method is operable provided a special repo written to the NRC detailing the planned corrective actions.
[A
} f 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 L10 3.3.3 Conditions 3.3.3.6 Action b Ill were extended to 7 days for 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 />.
l 3.3 L11' The CTS requirements for t.re Hydrogen Monitors that specify a channel check SR 3.3.3.1 and 4.6.4.1 il t
once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a month!y analog channe! operational test, and a channel SR 3.3.3.2
?
calibration 92 days on a staggered test basis were revised to require a channe!
{
check once per 31 days and a channel calibration once per 92 days. The channel operational test was eliminated.
l 4
3.3 L12 The CTS requirement for the inoperable remote shutdown system instrument 3.3.4 Condition A
'3.3.3.5 Action a.
til channels to be restored to operable status within 7 days was increased from 7 i
days to 30 days.
l 3.3 L13 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.
l 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
6 refueling was revised by the addition of a Note allowing the neutron detectors to be excluded from the CHANNEL CALIBRATION.
I h
i (C) Catawba specific Categories:
I.
Relaxation of Applicability V.
Relaxation of Surveillance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controls Ill. Relaxation of Completion Time Vll.
Deletion of Survei!!ance Requirements IV.
Relaxation of Required Actions Vill Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 2
i a
TABLE L-LESS RESTRICTIVE CHANGES
[
SECTION 3.3 INSTRUMENTATION 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 days [)
[
a 3.3 L21 Not used.
-f 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 I
(placed in trip) until the next performanca of the COT were revised by the addition D, J and P Actions 15 and l
of a note that a!!ows the channel to be placed in bypass for surveillance testing on 15b r
other channels.
I p
3.3 L23 (C)
The CTS requirements for Diesel Building Ventilation support system operability 3.32 Table 3.3-3,3.3--
VI f'
have been deleted in the ITS.
4, and 4.3-2 j
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 ill p
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 j
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 />.
i 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 l
(placed in trip) until the performance of the next operational test were revised 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 1
(ABFVES) Manual initiation were deleted from the ESFAS LCO. The deletion 16a j
includes the Function and all associated Actions and Surveillances.
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
BDMS upon receipt of a trip signal is revised to allow an actual or simulated signal i
to be used for the testing.
l (C) Catawba specific Categories:
1.
Relaxation of Applicability '
V.
Relaxation of Surveillance Requirement l
(M) McGuire specific II.
Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controls Ill. Relaxation of Comp:;n. Time Vll.
Deletion of Surveillance Requirements i
IV.
Relaxation of Required Actions Vill. ' Deletion of Requirements R0dundant to Regulations Cr_tawba and McGuire Nuclear Stations 4
i
TABLE L-LESS RESTRICTIVE CHANGES t
SECTION 3.4 REACTOR COOLANT SYSTEM 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 va!ve in the closed position was revised to require the valve to be and Action F i
placed in manualcontrol.
l 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 II i
entry into the LTOP mode of applicability, and at least once per 31 days thereafter g
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 applicability to complete the required surveillance test.
j 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 monitam nnem ner 12 N/A 4.4.6.2.1.a i
hours, and by use of the reactor head flange leakoff systemf5ncediir2AffounO N/A 4.4.6.2.1.b i
N/A 4.4.6.2.1.e
[
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 i
3.4 L12 in the event of one or more flow paths with leakage from one or more PlVs greater 3.4.14 Action A 3.4.6.2 Action c lit, 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 i
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 I
.l (C) Catawba specific Categories:
1.
Relaxation of Awhu~ti V.
Relaxation of Survei!!ance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controls i
III. Relaxation of Completion Time.
VII.
Deletion of Surveillance Requirement
[
IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations t
Cotawba and McGuire Nuclear Stations 2
t l
l
TABLE L-LESS RESTRICTIVE CHANGES to SECTION 3.4 REACTOR COOLANT SYSTEM 3.4 L19 (C)
The CTS requirement for a shutdown 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 contint,ed operation provioed either a channel check of the required containment atmosphere radioactivity monitoris 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 Applicability 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 Appilcability 2500'F.
3.4 L21 The CTS requirement to verify RCS gross activity 5 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 Il 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 lil 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 11 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 Appficability V.
Relaxation of Surveritance Requirement (M) McGuire specific 11.
Relation of Surveittance Frequency VI.
Relaxation of LCO and Administrative Controts
!!I. Relaxation of Comptetion Time VII.
Deletion of Surveittance Requirement IV.
Relaxation of Required Actions VIII. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 4
TABLE L-LESS RESTRICTIVE CHANGES SECTION 3.5 EMERGENCY CORE COOLING SYSTEM
+
3.5 L9 The CTS Actions that a!!ow 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 hout to correct the inoperability prior to requiring a unit i
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-i 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 wgs revised to only require that the limits be maintained in MODES 1-3.
L 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 b
i h
i i
(C) Catawba specific Categories:
I.
Refaxation of Applicability V.
Relaxation of Surveillance Requirement (M) McGuire specific II.
Relation cf Surveillance 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
i
I TABLE L-LESS RESTRICTIVE CHANGES SECTION 3.6 CONTAINMENT SYSTEMS E
b 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, 4.6.2.0, 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) i 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 />.
[
t 3.6 L30 The GTS 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 ar.d IV i
administrative control was revised by the addition of an ITS note to the ACTIONS Note footnote (M) l -[
which provides an allowance to open any containment isolation valve required to g/g,gc) be closed (except for the large containment purge / exhaust va!ves) under administrative controls.
i 3.6 L32 The CTS requirement for restoring inoperable valves to OPERABLE status was 3.3.2, Required 3.6.1.9, Action c IV replaced by the ITS Action which specifies isolating the affected penetration flow Act.'on E.1 path by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange.
E 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 rate 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 retested following opening.
l (C) Catawba specific Categories:
1.
Relaxation of Applicability V.
Relaxation of Survei!!ance Requirement (M) McGuire specific Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controls til. Relaxation of Completion Time Vll.
Deletion of Surveillance Requirement IV.
Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Cataw* a and McGuire Nuclear Stations 5
j t
6[
TABLE L-LESS RESTRICTIVE CHANGES q //p cd SECTION 3.7 PLANT SYSTEMS CHAPTER Y
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 uso of an ac ual or simulated actuation signal for testing purposes.
3.7 L.27 The CTS requi ment that the AFW automatic valves be verified to actuate to the SRs 3.7.5.3 and 4.7.1.2.c.1 and 2 V
correct positi and that the AFW pumps start on the specified test signals was 3.7.5.4 revised t oow the use of an
- actual or simulated" test signal.
3.7 L28 The CTS requirement that each automatic valve be verified to actuate to the (C) SRs 3.7.7.P.
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 L29 The CTS requ!rements that each automatic valve in the flow pathhactuate to its (C) SRs 3.7.5.3, 4.7.1.2.1.c.1, V
/
correct position upon receipt of an actuation test signal were revise exclude 3.7.7.2, and 4.7.3.b.1, and I
automatic valves that are locked, sealed or otherwise secured in po ition from this 3.7.8.2 4.7.4.b.1 verification.
(M) SRs 3.7.5.3, S
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.
(C) Catawba specific Categories:
1.
Relaxation of Applicabliity V.
Relaxation of Surveillance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VL Relaxation of LCO and Administrative Controls Ill. Relaxation of Completion Time VII.
Deletion of Surveitiance Requirement IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Citawba and McGuire Nuclear Stations 4
L TABLE L-LESS RESTRICTIVE CHANGES i
SECTION 3.8 ELECTRICAL POWER SYSTEMS
[
.,=J t
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 ll f
STAGGERED TEST BASIS was deleted from the corresponding ITS surveillance SRs.
requirements.
3.8 L2 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 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 4.8.1.12.a.5.
f 3.8 L3 The CTS Action requirement to verify redundant equipment OPERABLE within 2 3.8.1 Required 3.8.1.1 Action c ill hours after discovery of an inoperable DG was revised to require 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 />.
((W. W41/c mt/skEspsNagt J N#Mf d) 3.8 L4 Not used.
The CTS requirement for testing the DG foad rejection capability of a load of 576d SR 3.8.1.9 (C) 4.8.1.12.g 2)
V l
3.8 L 5 420 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.
An new action requirement is added to the CTShoNes specification in the 3.8.3 Action A 3.8.1.1 Actions III
/ f 3.8 L 6 event the quantity of fuel oil for the DG is less than required. By the definition of l
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 Not used.
.l 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 j
would require immediately declaring the associated DG inoperable.
t 3.8 L9 Not used.
I t
t I
(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 l
Ill. Relaxation of Completion Time VII.
Deletion of Surveillance Requirement r
IV.
Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 1
I
TABLE L-LESS RESTRICTIVE CHANGES i
SECTION 3.8 ELECTRICAL POWER SYSTEMS L
3.8 L.10 The CTS reoprement 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 ill
/.
fuel oil is revised to allow 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.
f 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 pressurtzed 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 l
11 seconds or less. This surveillance was replaced with the ITS requirement to Section verify that the air start receiver pressure is 2210 psig every 31 days.
III.G.14 L
3.8 L12 (M)
The CTS surveillance 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 i
more than 4000 kW.
3.8 L.13 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
I performance discharge test instead of the performance discharge test, when 4.8.2.1.1.f, and
[
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.
3.8 L15 (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 Vll electrolyte leakage for the DC channel batteries was deleted.
t 3.8 L16 The CTS time allowed to restore Categery A and B battery parameters to within 3.8.6 Required Table 4.8-3 Notes Ill
'imits was increased from 7 days to 31 days.
Action A.3 (1) and (2) t i
(C) Catawba specific Cataries:
1.
Relaxation of Applicability V.
Relaxation of Surveillance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VI.
Relaxation of LCO and Administrative Controis 111. Relaxation of Completion Time VII.
Deletion of Surveillance Requirement IV. Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations Catawba and McGuire Nuclear Stations 2
...m 4.,
s.:
.4e- - - n
.ai---'-------------
w-d TABLE L-LESS RESTRICTIVE CHANGES SECTION 3.8 ELECTRICAL POWER SYSTEMS I,.._.-
am m.
m m. arf %y r
a 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 l
150 volts, the CTS require verifying within 7 days that there is no visible corrosion SR 3.8.6.2 l
at either terminals or connectors and that the average electrolyte temperature of six connected cells is within limits. This surveillance is deleted for the DG batteries.
3.8 L18 The CTS time allowed to demonstrate the OPERABILITY of the remaining 3.8.1 Actions A, 3.8.1.1 Action b Ill 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 />.
i 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 which allows the DG starting air supply to decrease below the required capacity of See Safety 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 Ill.G.14 l
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) ll revised to delete the requirement to perform this surveillance during shutdown.
f,f,/,/,p, f (/er)
[
i 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 Vil 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.
I i
A note was also added to exempt performance of certain surveillances for the DG SR 3.8.2.1 Note V
I and offsit c ources being used to satisfy the operability requirements of ITS LCO 3.8.2.
/tC 3.8 L.22 The CTS surveillance requirement for the DC Source.t - Shutdown was revised by SR 3.8.5.1 Note 4.8.2.2.2 VII 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.
i r
(C) Catawba specific Categories:
1.
- Relaxation of Applicability V.
Relaxation of Surveillance Requirement (M) McGuire specific II.
Relation of Surveillance Frequency VI. - Retaxation of LCO and Administrative Controls l
111.
Relaxation of CeiryMan Time VII.
Deletion of Survei!!ance Requirement IV.
Relaxation of Required Actions Vill. Deletion of Requirements Redundant to Regulations l
Catawba and McGuire Nuclear Stations 3
y
~
TABLE LA - REMOVAL OF INFORhlATION FROM THE CTS SECTION 3.2 POWER DISTRIBUTION ve'm y
g:ggy gg;
{gg g gy:
g g 7gg
@fggf 50MMARVOFMEidN$[4s-l$13% dipDOCOMENQ [PROCESSI[i$sW4
[ [ M ES 1
q The formulas in the CTS for determining the values of Fy(X,Y,Z), P, 32.1 Bases Bases control 3
3.2 LA.1 32.2 program Fa'*', and K(Z).
4 3.2 LA.2 3.2.2, Action c The CTS references to trip setpoint constants and instrument scales.
32.1 Bases Bases control 1
program and 4.222.c 3.2 LA.3 4.22.2.e The CTS exceptions for various core planes and core regions used 3.2.1 Bases Bases control 3
4.2.2.2.d when determining Fy(X,Y,Z).
program f
3.2 LA.4 4.22.3 The CTS requirements for the measured value of Fo(X,Y,Z) to be COLR 5.6.5 3
increased by 3% to account for manufacturing tolerances and 5% for measurement uncertainties.
3.2 LA.5 422.2 The descriptive information for how the peaking factor surveillances are 3.2.1 Bases Bases control 3
program 42.32 to be performed.
3.2 LA.6 3.2.3 Definitions of FL(X,Y) an Fa X,Y)".
3.2.2 Bases Bases control 1
l t
l Ag program f
The CTS references to trip setpoint constband instrument scales.
3.2.2 Bases Bases control 1
3.2 LA.7 3.2.3 program j
t 3.2 LA.8 42.4.2 The CTS information regarding how the incore detectors are used for SR 3.2.4.2 Bases Bases control 2
program l
determining QPTR.
k i
i 7
(C) Catawba specific LA Change Types:
1.
Details of System Design 2.
Descriptions of System Operation (M) McGuire specific l
3.
Procedural Details for Meeting TS Requirements 1
Catawba and McGuire Nuclear Stations l
TABLE LA - REMOVAL OF INFORMATION FROM THE CTS SECTION 3.3 INSTRUMENTATION LdC{ M[hw[e
SUMMARY
OliCHANGEENO +Oh fdMjk.MN[; N ^ Nhh
{DESTINATIONj ;'[;ddNTROt3i; {bH NGE ig
~
[dlSCbs5iUU[M TCiS M d$
Lif* W
$ DOCUMENTS MPROCESSR iTYPE9
&OF. CHANGES EREQUIREMENT;i t
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.
3.3 LA.13 3.3.2 Actions The descriptive details in the CTS Actions regarding the relationship 3.3.2 Bases Bases control 3
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
3.3-4, and 4.3-2 the functions initiated by a safety injection signal (e.g., Reactor Trip, program 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 3.3 LA.16 Table 3.3-4 The CTS d ighhscriptions of the FeedwaterIsolation 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 functiorMtrip setpoints and allowable values as
" narrow range instrument span," wgmoved to the ITS Bases.
hCy 3.3 LA.17 Not used.
3.3 LA.18 Not used.
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 6:ydrogen and the specific calibration points is moved to the ITS Bases.
3.3 LA.20 Not used.
(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 Catawba and McGuire Nuclear Stations 2
TABLE LA - REMOVAL OF INFORPdATION FROM THE CTS SECTION 3.8 ELECTRICAL POWER SYSTEMS P
iDESTINATIONc CCONTROth IUI-IANGE'
~
(DisbS$iUIh
_?iCT5sk [$$((rM EMS MN$$[
, d[^ N ROECHANGEs ! REQUIREMENTL iMdB ' i.
J ISUMMAR_YOE CHANGEK
~U
/ DOCUMENT 5 JPROCESS2 (TYPEf 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 ITS Bases.
3.8 LA.30 (C) 4.8.1.1.2.g.14 The 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 )'/.B././.Sc./V )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 shutdowri SR 3.8.1.13 Bases control 3
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 (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 Catawba and McGuire Nuclear Stations 4
f 'pr V
5 bl*
yoj@gr O
gr TABLE R - RELOCATED SPECIFICATIONS T$0 REQUIREMENTAks[m;mM b;# M [fjf ff {O5E$TiiOLTION)k
%YM$EN@$$
l
.,, M.
N NNb J -[M
.HANGEM $EQGh i_. :b sdi il. _ j)O$
4DOCUMENTdT iCONTROLPROCGS$i s
3.4 R.4 3/4.4.10 Structural integrity of ASME Code Class 1,2, and 3 components SLC 10 CFR 50.59 10 CFR 50.55a j
3.4 R.5 3/4.4.11 RCS vent paths operable and closed for reactor vessel head and SLC 10 CFR 50.59 l
pressurizer steam space (C) and Reactor vessel head vent paths operable l
and closed (M)
[
f 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 condenserinlet door position monitoring system SLC 10 CFR 50.59 f
3.7 R.1 3/4.7.2 Steam generator pressure / temperature limitations SLC 10 CFR 50.59 3.7 R.5 3/4.7.8 Snubbers SLC 10 CFR 50.59 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)
3/4.7.13 (M)
Ground water level near auxiliary building (M) i 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 3.8 R.1 3/4.8.4 Containment penetration conductor overcurrent protection devices SLC 10 CFR 50.59 3.9 R.1 3/4.9.5 Communications between Control Room and Refueling Station SLC 10 CFR 50.59
[
3.9 R.2 3/4.9.6 Reactor building manipulator crane and auxiliary hoist SLC 10 CFR 50.59 j
3.9 R.3 3/4.9.7 Load handling restrictions over fuel assemblies in storage pool SLC 10 CFR 50.59 t
s I
I (C) Catawba specific i
(M) McGuire Specific Catawba and McGuire Nuclear Stations 2
I 1
.m.
.m.
.m m
.