ML20198T256

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Proposed Tech Specs,Reflecting Addition of Boron Dilution Mitigation Sys,Changing Conditions 16 & 12(a) & Upgrading Unit 1 RCS PORVs to safety-grade
ML20198T256
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 06/06/1986
From:
DUKE POWER CO.
To:
Shared Package
ML20198T233 List:
References
NUDOCS 8606110384
Download: ML20198T256 (16)


Text

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. When in MODE 3 or 4, at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by consideration of the following factors:
1) Reactor Coolant System boron concentration,
2) Control rod position,
3) Reactor Coolant System average temperature,
4) Fuel burnup based on gross thermal energy generation,
5) Xenon concentration, and
6) Samarium concentration.

4.1.1.1.2 The overall core reactivity balance shall be compared to predictel values to demonstrate agreement within i 1% ak/k at least once per 31 Effective Full Power Days (EFPD). This comparison shall consider at least those factors stated in Specification 4.1.1.1.le., above. The predicted reactivity values shall be adjusted (normalized) to correspond to the actual core conditions prior to exceeding a fuel burnup of 60 EFP0 after each fuel loading. .

C llp;i 52 eM g 4.1.1.1.3V At least bnce per 18 months, the Reactor Makeup Water pumps shall be demonstrated OPERABLE by verifying a total combined flow rate of less than or equal to 240 gpm and a flow rate of less than or equal to 120 gpm for each (M 2 )

4.1.1.1.4 hat least once per 31 days, while in MODE 4, one Reactor Makeup Water pump shall be demonstrated inoperable by verifying that the motor circuit breaker is secured in the open position.

8606110384 e60606 DR ADOCK0500g3 CATAWBA - UNITS 1 & 2 3/4 1-2

REACTIVITY CONTROL SYSTEMS SHUTDOWN MARGIN - Tava 1 200'F LIMITING CONDITION FOR OPERATION 3.1.1.2 The SHUTDOWN MARGIN shall be greater than or equal to 1% ak/k.

APPLICABILITY: MODE 5.

ACTION:

With the SHUTDOWN MARGIN less than 1% Ak/k, immediately initiate and continue boration at greater than or equal to 30 gpm of a solution containing greater than or equal to 7000 ppm boron or equivalent until the required SHUTDOWN MARGIN is restored.

SURVEILLANCE REQUIREMENTS 4.1.1.2.1 The SHUT 00WN MARGIN shall be determined to be greater than or equal to 1% Ak/k:

a. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after detection of an inoperable control rod (s) and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while the rod (s) is inoperable.

If the inoperable control rod is immovable or untrippable, the SHUTOOWN MARGIN shall be verified acceptable with an increased allowance for the withdrawn worth of the immovable or untrippable control rod (s); and

b. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by consideration of the following factors:
1) Reactor Coolant System boron concentration,.
2) Control rod position,
3) Reactor Coolant System average temperature,
4) Fuel burnup based on gross thermal energy generation,
5) Xenon concentration, and 6 Sa ar (Llnit) J. only)ium concentration.

4.1.1.2.2 + At least once per 18 months, each Reactor Makeup Water pump shall be demonstrated OPERABLE by verifying a flow rate of less than or equal to

. 120 gpm. At least once per 31 days, one Reactor Makeup Water pump shall be demonstrated inoperable by verifying that the motor circuit breaker is secured in the open position.

CATAWBA - UNITS 1 & 2 3/4 1-3

TABLE 3.3-1 .

1 REACTOR TRIP SYSTEM INSTRUMENTATION E

> MINIMUM i

TOTAL NO. CHANNELS CHANNELS APPLICABLE OF CHANNELS TO TRIP OPERA 8LE MODES ACTION g FUNCTIONAL UNIT 1

h 1. Manual Reactor Trip 2 2

1 1

2 2

1, 2 3*, 4*, 5* 10 g

e-m 2. Power Range, Neutron Flux 4 2 3 1, 2 2#

a. High Setpoint
b. Low Setpoint 4 2 3 1###, 2 2#

4 2 3 1, 2 2#

) 3. Power Range, Neutron Flux High Positive Rate Power Range, Neutron Flux, 4 2 3 1, 2 2#

4.

High Negative Rate

{

Intermediate Range, Neutron Flux 2 1 2 1###, 2 3 T

m 5.

6. Source Range, Neutron Flux 2 1 2 2## 4
a. Startup
b. Shutdown ( h i-f i 2 1 2 3? k 5" ElO A I R 3, 'f f i F (llnit G
7. Overtemperature AT 4 2 3 1, 2 6#

Four Loop Operation

8. Overpower AT 6#

4 2 3 1, 2 Four Loop Operation 4 2 3 1 6#

9. Pressurizer Pressure-Low 1

. t

TABLE 4.3-1 (Continued)

TABLE NOTATIONS

  • Only if the Reactor Trip System breakers happen to be closed and the Control Rod Drive System is capable of rod withdrawal.
  1. Above P-9 (Reactor Trip on Turbine Trip Interlock) Setpoint.
    1. Below P-6 (Intermediate Range Neutron Flux Interlock) Setpoint.
      1. Below P-10 (Low Setpoint Power Range Neutron Flux Interlock) Setpoint.

(1) If not performed in previous 7 days.

(2) Comparison of calorimetric to excore power indication above 15% of RATED THERMAL POWER. Adjust excore channel gains consistent with calorimetric power if absolute difference is greater than 2%. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(3) Single point comparison of incore to excore axial flux difference above 15% of RATED THERMAL POWER. Recalibrate if the absolute difference is greater than or equal to 3%. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

~

(4) Neutron detectors may be excluded from CHANNEL CALIBRATION.

(5) Detector plateau curves shall be obtained, evaluated and compared to manufacturer's data. For the Intermediate Range and Power Range Neutron Flux channels the provisions of Speci'ication 4.0.4 are not applicable for entry into MODE 2 or 1. g (6) Incore - Excore Calibration, above 75% of RATED THERMAL POWER. The provisions of Specification 4.0.4 are not applicable for entry into MODE 2 or 1.

(7) Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS.

(8) With power greater than or equal to the interlock setpoint the required ANALOG CHANNEL OPERATIONAL TEST shall consist of verifying that the interlock is in the required state by observing the permissive status light.

l (9) Monthly surveillance in MODES 3*, 4*, and 5* shall also include verifi-cation that permissives P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive status light. For u; M onlg enthly surveillance shall include verification of the Boron DilutionAlarm above background.

(10) Setpoint verification is not applicable.

(11) At least once per 18 months and following maintenance or adjustment of the Reactor trip breakers, the TRIP ACTUATING DEVICE OPERATIONAL TEST shall include independent verification of the Undervoltage and Shunt trips.

(12) CHANNEL CALIBRATION shall include the RTD bypass loops flow rate.

CATAWBA - UNITS 1 & 2 3/4 3-12

_ . _ _ _ _ _ _ . _ _ - - , _ _ _ . _ , . , _ _ _ _ . _ _ _ . . _ _ _ _ . _ _ - _ _ . _ , , _ _ . _ _ . . . _ . _ _ - _ . . - , , . _ _ . _ . ._..____.,,..__m.

4 INSTRUMENTATION 3/4.3.3.12 BORON DILUTION MITIGATION SYSTEM l

LIMITING CONDITION FOR OPERATION 3.3.3.12 As a minimum, two trains of the Boron Dilution Mitigation System shall be OPERABLE and operating with Shutdown Margin Alarm Ratios set at less than or equal to 4 times the steady-state count rate.

APPLICABILITY; MODES 3, 4, AND 5 (UNIT 1 ONLY)

ACTION:

(a) With one train of the Boron Dilution Mitigation System inoperable or not operating, restore the inoperable train to OPERABLE status l I

within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or (1) suspend all operations involving positive reactivity changes and verify that valve NV-230 is closed and secured within the next hour, or (2) verify two Source Range Neutron Flux Monitors are OPERABLE with Alarm Satpoints less than or equal to one-half decade above the steady-state count rate and verify that the combined flowrate from both Reactor Makeup Water Pumps is less than or equal to 200 gym (Mode 3) or 80 gpm (Mode 4 or

5) within the next hour.

(b) With both trains of the Boron Dilution Mitigation System inoperable or not operating, restore the inoperable trains to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or (1) suspend all operations involving positive reactivity changes and verify that valve NV-230 is closed and secured within the next hour, or (2) verify two Source Range Neutron Flux Monitors are OPERABLE with Alarm Setpoints less than or equal to one-half decade above the steady-state count rate and verify that the combined flow rate from both Reactor Makeup Water Pumps is less than or equal to 200 gpm (Mode 3) or 80 gpm (Mode 4 or

5) within the next hour.

(c) The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4

4.3.3.12.1 Each train of the Boron Dilution Mitigation System shall be demonstrated OPERABLE by performance of:

(a) A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, CATAWBA - UNITS 1 & 2 3/4 3-92a

SURVEILLANCE REQUIREMENTS (CONTINUED)

(b) An ANALOG CHANNEL OPERATIONAL TEST prior to startup if not performed in previous 7 days, and (c) An ANALOG CHANNEL OPERATIONAL TEST at least once per 31 days.

4.3.3.12.2 If using the Source Range Neutron Flux Monitors to meet the requirements of Technical Specification 3.3.3.12, (a) The monthly surveillance requirements of Table 4.3-1 for the Source Range Neutron Flux Monitors shall include verification that the Alarm Setpoint is less than or equal to one-half decade (square root .' 10) above the steady-state count rate.

(b) The combined flow rate from both Reactor Makeup Water Pumps shall be verified as less than or equal to 200gpa (Mode 3) or 80 gpa (Mode 4 or 5) at least once per 31 days.

CATAWBA - UNITS 1 & 2 3/4 3-92b

3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION LIMITING CONDITION FOR OPERATION l 3.9.1 The boron concentration of all filled portions of the Reactor Ciolant System and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of the following reactivity conditions is met either:

a. A K,ff of 0.95 or less, or
b. A boron concentration of greater than or equal to 2000 ppe.

APPLICABILITY: MODE 6.*

ACTION:

With the requirements of the above specification not satisfied, immediately i suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at greater than or equal to 30 gpm of a solution containing greater than or equal to 7000 ppa boron or its equivalent until K is reduced to less than or equal to 0.95 or the' boron 4

concentrationisrINoredtogreaterthanorequalto2000 ppm,whicheveris the more restrictive.

SURVEILLANCE REQUIREMENTS i 4.9.1.1 The more restrictive of the above two reactivity conditions shall be determined prior to:

a. Removing or unbolting the reactor vessel head, and
b. Withdrawal of any full-length control rod in excess of 3 feet from its fully inserted position within the reactor vessel.

4.9.1.2 The boron concentration of the Reactor Coolant System and the refueling

~

canal shall be determined by chemical analysis at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

WV-230 4.9.1.3 Valved %V 2 7 , ""-227, MV-200, ""-241, rd iiV 244 shall be verified closed and secured in position by mechanical stops er by ;;;; val eT eii er

-v = M ::' ; n r at least once per 31 days.

  • The reactor shall be maintained in MODE 6 whenever fuel is in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed.

f CATAWBA - UNITS 1 & 2 3/4 9-1

I j

REFUELING OPERATIONS 3/4.9.2 INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2.1 As a minimum, two trains of the Boron Dilution Mitigation System shall be OPERABLE and operating with Shutdown Margin Alarm Ratios set at less than or equal to 4 times the steady-state count rate, each with continuous indication in the control room.

APPLICABILITY: MODE 6 (UNIT 1 ONLY)

ACTION:

(a) With one or both trains of the Boron Dilution Hitigation System inoperable or not operating, (1) immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes, or (2) verify that two Source Range Neutron Flux Monitors are OPERABLE and operating with Alarm Setpoints less than or equal to one-half decade (square root of 10) above the steady-state count rate, each with continuous visual indication in the control room and one with audible indication in the containment and control room within the next hour.

(b) With both trains of the Boron Dilution Mitigation System inoperable or not operating and one of the Source Range Neutron Flux Monitors inoperable or not operating immediately suspend all operations involving core ALTERATIONS or positive reactivity changes.

(c) With both trains of the Boron Dilution Mitigation System inoperable or not operating and both of the Source Range Neutron Flux Monitors inoperable or not operating, determine the boron concentration of the Reactor Coolant System at least once per 12 4

hours.

SURVEILLANCE REQUIREMENTS 4.9.2.1.1 Each train of the Boron Dilution Mitigation System shall be demonstrated OPERABLE by performance oft (a) A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, (b) An ANALOG CHANNEL OPERATIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS and (c) An ANALOG CHANNEL OPERATIONAL TEST at least once per 31 days.

CATAWBA - UNITS 1 & 2 3/4 9-la

SURVEILLANCE REQUIREMENTS (CONTINUED) 4.9.2.1.2 If using the Source Range Neutron Flux Monitors to meet the requirements of Technical Specification 3.9.2, each Source Range Neutron Flux Monitor shall be demonstrated OPERABLE by performance of:

(a) A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, (b) An ANALOG CHANNEL OPERATIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS or within I hour after declaring the BORON DILUTION MITIGATION SYSTEM inoperable, and (c) An ANALOG CHANNEL OPERATIONAL TEST at least once per 7 days.

CATAWBA - UNITS 1 & 2 3/4 9-lb

. l REFUELING OPERATIONS i

3/4.9.2 INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2,2As a minimum, two Source Range Neutron Flux Monitors shall be OPERABLE and operating with Alarm Setpoints at 0.5 decade above steady-state count rate, each with continuous visual indication in the control room and one with audible indication in the containment and control room.

APPLICA8ILITY: MODE 6( ud t J on ly )

ACTION:

a. Witn one of the above required monitors inoperable or not operating, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes.
b. With both of the above required monitors inoperable or not operating, determine the boron concentration of the Reactor Coolant System at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

6 SURVEILLANCE REQUIREMENTS 4.9.2.2Each Source Range Neutron Flux Monitor shall be demonstrated OPERABLE by performance of:

a. A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />,
b. An ANALOG CHANNEL OPERATIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS, and
c. An ANALOG CHANNEL OPERATIONAL TEST at least once per 7 days.

l l CATAWBA - UNITS 1 & 2 3/4 9-2

INSTRUMENTATION f

k BASES 3/4.3.4 TURBINE OVERSPEED PROTECTION This specification is provided to ensure that the turbine overspeed protection instrumentation and the turbine speed control valves are OPERABLE and will protect the turbine from excessive overspeed. Protection from turbine excessive overspeed is required since excessive overspeed of the turbine could generate potentially damaging missiles which could impact and damage safety-related components, equipment, or structures.

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[o.c;p,.4 lim lfs. Th.se. ac.b3h rougni 2;l +ime:e. .umtc,nd rier I

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to a loss of $6%,n en.cgin.

CATAWBA - UNITS 1 & 2 8 3/4 3-7

3/4.9 REFUELING OPERATIONS BASES

3/4.9.1 80RON CONCENTRATION The limitations on reactivity conditions during REFUELING ensure that

(1) the reactor will remain suberitical during CORE ALTERATIONS, and (2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel. These limitations are consistent with the initial conditions assumed for the boron dilution incident in the safety analyses. The value of 0.95 or less for X,ff includes a 15 Ak/k conservative allowance for uncertainties. Similarly, the boron concentration value of 2000 ppe or greater includes a conservative uncertainty allowance of 50 ppe boron. The locking closed of the required valves during refueling operation precludes the possibility of uncontrolled boron dilution of the filled portion of the Reactor Coolant System. This action prevents flow to the Reactor Coolant System of unborated water by closing flow paths from

sources of unborated water.

i

. 3/4.9.2 INSTRUMENTATION g b K Q,%[O pIM Y ensures that sys4em The OPERA 8ILITY of the Source Range Neutron Flux Monitors

, redundant monitoring capability is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for reactor suberiticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time

! has elapsed to allow the radioactive decay of the short-lived fission products.

? This decay time is consistent with the assumptions used in the safety analyses.

i 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment building penetration closure and OPERABILITY of the Reactor Building Containment Purge System ensure that a release of radioactive material within containment will be restricted from leakage to the environment or filtered through the HEPA filters and carbon adsorbers prior to release to the atmosphere. The OPERA 8ILITY and closure restrictions are sufficient to restrict radioactive material release from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING MODE. Operation of the Reactor Building Containment Purge System and the resulting iodine removal capacity are consistent with the assumption of the safety analysis. Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours 1 in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. ANSI N510-1980 will be used as a procedural guide for surveillance testing, j CATAWBA - UNITS 1 & 2 8 3/4 9-1

ATTAC1 BENT 4 DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNIT 1 PROPOSED AMENDMENT TO THE TECHNICAL SPECIFICATIONS UPGRADE OF POWER OPERATED RELIEF VALVES f

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_ , , . , . , - _ , , , , , . , _ , , , .,- , ,,_ _,- , _ ,- _ , --_.i--- _ --.

Discussion of Amendment Request The proposed changes to the Technical Specifications are required to reflect the upgrade of the Reactor Coolant System Power Operated Relief Valves (PORV's) to safety grade for Catawba, Unit 1. Since the Unit 2 PORV's were upgraded to safety grade prior to fuel load, the changes eliminate the separate Unit i specification and modify the separate Unit 2 specifications so that it will be applicable to both Units.

The Safety Evaluation Report (SER) for the Catawba Nuclear Station required Duke Power Company to show that cold shutdown could be achieved using only safety related equipment. In response to this requirement, Duke proposed to upgrade the Unit 1 Reactor Coolant System PORV's to safety grade during the first refueling outage as stated in Mr. H. B. Tucker's letter of October 26, 1983 to H. R. Denton. This proposal was subsequently approved by the NRC staff in Section 5.4.4 of Supplement 2 to the Catawba SER.

JUSTIFICATION AND ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes to Technical Specification 9 4.4.4.3 and 4.4.4.4 are required to reflect the upgrade of the Reactor Coolant System power operated relief valves (PORV's) for Catawba Unit I as described in the response to question 440.149 of the Catawba FSAR. This will be accomplished during the first refueling outage. Since the Unit 2 PORV's were upgraded prior to fuel loading, the Technical Specifications for Units 1 and 2 contain separate specifications for Units 1 and 2. The proposed changes would eliminate the separate Unit 1 specification, Technical Specification 4.4.4.3, and change Technical Specification 4.4.4.4 so that it would be applicable to both Units 1 and 2.

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

4 The proposed changes do not involve a significant increase in the probability or consequences of an accident, as they are necessary to reflect the upgrade of the PORV's to safety grade which will provide additional assurance that the PORV's will function if needed.

! Similarly, the proposed changes do not create the possibility of a new or different kind of accident from those previously evaluated since the upgrade of the PORV's will not change the manner in which the plant is

] operated.

i J

! In addition, the upgrade of the PORV's provides additional assurance that I the PORV's will operate as intended if called upon to depressurize the Reactor Coolant System in the event of a design basis steam generator tube

! rupture accident. Therefore the proposed changes do not involve a reduction in a margin of safety.

Based upon the above discussion, Duke Power concludes that the proposed changes to Technical Specifications 4.4.4.3 and 4.4.4.4 do not involve significant hazards considerations.

1 i

i l

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n REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS z

4.4.4.1 In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERA 8LE at least once per 18 months by:

a. Performance of a CHANNEL CALIBRATION, and b.

Operating the valve through one complete cycle of full travel.

4.4.4.2 Each block valve shall be demonstrated OPERA 8LE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed with power remoted in order to meet the requirements of ACTION b. or c. in Specification 3.4.4.

T 4. 4. 3 (Unit 1 o y) The rgency p r supp

. ~l ves shall be for he PO Vs nd b ck nstr ed OPERA 8L at lea one per 18 sb.

a. Ma 11y tr sferring tive a con of p f t no 1 t emerg cy power upply, d
b. Operat g the v, ves th uch a E'omple cyc e o fu. tr el ' l 4.4.4.4f ('J 't 2 : ?y) The emergency power supply for the PORVs and block valves shall be demonstrated OPERA 8LE at least once per 18 months by: AgI a.

Manually transferring motive (N,) : d :::tr:? power from the normal (eti c')

sqply to the emergency sup y,

b. Isolating and venting t e normal (air) supply, and
c. Operating the valves through a complete cycle of full travel.

9 i

l CATAWBA - UNITS 1 & 2 3/4 4-11

_ _ . _ _ _ _ _ . _ _ _ _ _ _ _ ________ _ _ _ _ . . . . . _ _ _ . , _ . . , _ _ . . _ _ . _ . . . . . - _ _ _ _ _ _ , ._.- _ . , - _ _ _ _ . _ . . , _ . , . , _ . - - . . _ . . -