ML20210N315

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Proposed Tech Specs Changing TSs 3.3.2, ESFAS Instrumentation, 3.3.3, Post Accident Monitoring Instrumentation, 3.4.14, RCS Loops - Test & 5.3, Unit Staff Qualifications
ML20210N315
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/04/1999
From:
DUKE POWER CO.
To:
Shared Package
ML20210N308 List:
References
NUDOCS 9908110073
Download: ML20210N315 (63)


Text

ATTACIDDDIT 1 MARKED-UP TECHNICAL SPECIFICATIONS PAGES FOR CATAWBA i

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l 9908110073 990004 PDR ADOCK 05000413 P PDR

l Proposed Change to TS 3.3.2, Conditions Q and R for Nuclear Service Water System (NSWS) Suction Transfer-Low Pit Level channels i

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ESFAS instrumentation 3.3.2 ACTIONS (continued)

CONDITION ' REQUIRED ACTION COMPLETION TIME

O. One channelinoperable. O.1 Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required state for existing unit condition.

l OR d

O.2.1 Be in MODE 3. 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> l

AND l

l O.2.2 Be in MODE 4. 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> l P. One or more P.1 Declare affected supported immediately Containment Pressure system inoperable.

Control System channel (s) inoperable.'

O. One Nuclear Service Q.1 ---

NOTE---- J Water Suction Transfer- The inoperable channel Low Pit Level channel in may be bypassed for up to one or more pits 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance inoperable. testing of other channels.

Place channelin trip. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> R 0

$osrt)

Q.X AlIy4 . tf acle+r l Serial Wi\c r J1sicm for S-fedl/ Muchar O .1 Be in MODE 3. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> l

& t &ut. hiske Poc$, cebrevWs., py9 O .2 Be in MODE 5. 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> l (continued) l l

l Catawba Units 1 and 2 3.3.2-7 Amendment Nos.

L ESFAS instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME y more)

R. Two Nuclear Service R.1 Align the Nuclear Service 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 1 Water Suction Transfer- Water System for Standby Low Pit Level channels Nuclear Service Water in one or more pits Pond recirculation.

Inoperable.

_O_B R.2.1 Be in MODE 3. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> AND I

R.2.2 Be in MODE 5. 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 1

l Catawba Units 1 and 2 3.3.2-8 Amendment Nos.h3[65) u

p ESFAS Instrumentation B 3.3.2 BASES ACTIONS (continued) l O.1. O.2.1 and O.2.2 Condition O applies to the P-11 and P-12 interlocks.

1 With one channel inoperable, the operator must verify that the interlock is j in the required state for the existing unit condition. This action manually l

accomplishes the function of the interlock. Determination must be made -

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed l

in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the I following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full l power conditions in an orderly manner and without challenging unit I systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

_P_d Condition P applies to the Containment Pressure Control System Start and Terminate Permissives.

With one or more channels inoperable, the affected containment spray and containment air return systems components must be declared inoperable immediately. The supported system LCOs provide the appropriate Required Actions and Completion Times for the equipment made inoperable by the inoperable channel. The immediate Completion Time is appropriate since the inoperable channel could prevent the supported equipment from starting when required. Additionally, protection from an inadvertent actuation may not be provided if the terminate function is not OPERABLE.

W Q3 Obm1. and 00.2 Q

With one channel of NSWS Suction Transfer - Low Pit Level inoperable in one or more NSWS pits, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are allowed tofestore Ahe chanahl tB CPEFMBLE status or talplace it in the tripped conditioq The failure of one channel places the Function in a two-out-of-tw[o onfiguration. The Ora \?9 $WW 4e r%Jly vse Pod J Catawba Units 1 and 2 B 3.3.2-41 Revision No.@

l

1 ESFAS Instrumentation B 3.3.2 BASES

, , Dr %t inwt cedy0 49 ACTIONS (continued) e, *' t fulfill & xddY function failed channel must'be tripped to place the Function in a one-out-of-two configuration that satisfies redundancy requirements-Failure toGiore tpfe inoperable ch/nnel to OPEF/ABLE stafus oJ plac ___

l in the tripped condition within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requires the unit be placed in .rt,e AM MODE 3 within the fo owing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Qgp4ggggg The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, this Function is no longer required OPERABLE.

l

R.1. R.2.1. and R.2.2 With tw Is of NSWS Suction Transfer - Low Pit Levelinocerable j in one or more pits,(qne ch#nel must b(restored to OFERABLE4taiuh ghe NSWS must be aligned to the Standby NSWS Pond within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Failure tofestorefone chansfel or to]accomp!ish the realignment within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requires the unit be placed 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 MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, this Function is no longer required OPERABLE.

SURVEILLANCE The SRs for each ESFAS Function are identified by the SRs column l REQUIREMENTS of Table 3.3.2-1.

A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.

Note that each channel of process protection supplies both trains of the ESFAS. When testing channelI, train A and train B must be examined.

Similarly, train A and train B must be examined when testing channel ll, channel lil, and channelIV (if applicable). The CHANNEL l l CAllBRATION and COTS are performed in a manner that is consistent i with the assumptions used in analytically calculating the required channel ]

accuracies.

i i

Catawba Units 1 and 2 B 3.3.2-42 Revision No.$)

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J

Proposed Change to TS Table 3.3.2-1 to Delete Function 66, Auxiliary Feedwater Loss of Offsite Power I

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\

f

ESFAS instrument n SURVEtLLANCE REQUIREMENTS NOTE-- -

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.2.2 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.2.3 '


NOTE  ! --. / )

Final actuatiof of pumps or valvefnot requiref .

g - . - .

Perform T ' 7T. /

SR 3.3.2.4 Perform 6 ITER RELAY TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.2.5 Perform COT. 92 days SR 3.3.2.6 Perform SLAVE RELAY TEST. 92 days SR 3.3.2.7 Perform COT. 31 days (continued) i I

Catawba Units 1 and 2 3.3.2-9 Amendment Nos.

ESFAS Instrumentation 3,3.2 Table 3.3.2-1 (page 4 of 5)

Engineered Safety Feature Actuation System instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVElLLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

6. Auxiliary Feedwater
a. Automatic 1,2,3 2 trains H SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.32.6 Relays
b. SG Water Level 1,2,3 4 per SG D SR 3.32.1 29% 2 10.7%

Low Low SR 3.32.5 (Unit 1) (Unit 1)

SR 3.3.2.9 2 35.1 % 2 36.8 %

SR 3.32.10 {

(Unit 2) (Unit 2) i

c. Safety injection Refer to Function 1 (Safety injection) for all initiation functions and requirements.
d. Loss of [ site 1,2,3 3 per bus SR 3.3.2.3 23242 V 2 3500 V Power / SR 3.3.2.9 g] NR 3.3.2.10
e. Trip of all Main 1,2(a) 3 per pump K SR 3.32.8 NA NA Feedwater SR 3.32.10 Pumps
f. Auxiliary 1,2,3 3 per train M SR 3.32.8 A) 2 9.5 psig A) 210.5 Feedwater Pump SR 3.3.2.10 psig Train A and Train B Suction B) 2 5.2 psig B) 2 6.2 Transfer on (Urvt 1) psig Suction Pressure 2 5.0 psig (Unit 1)

- Low (Unit 2) 2 6.0 psig 7, ' Automatic Switchover (Unit 2) to Containment Sump I

a. Automatic 1,2,3,4 2 trains C SR 3.32.2 NA NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3.2.6 Relays
b. Refueling Water 1,2,3,4 4 N SR 3.3.2.1 2 162.4 2 177.15 Storage Tank SR 3.3.2.7 inches inches (RWST) Level- SR 3.3.2.9 Low SR 3.3.2.10 Coincident with Refer to Function 1 (Safety injection) for all initiation functions and requirements.

Safetyinjection  !

l (continued)

(a) Above the P-11 (Pressurizer Pressure) interlock.

Catawba Units 1 and 2 3.3.2-14 Amendment NoS.h

r ESFAS Instrumsntation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

d. Auxilia:V Feedwa[er-Loss of Offsite Power '

l Aloss of offsit power to the service buses ill be i g accompanie y a loss of reactor coolant umping power I hot V.re A and the sub quent need for some meth of decay heat removal. T e loss of offsite power is de cted by a voltage drop on e h essential service bus. Lo s of power to either essential ervice bus will start the turb' e driven and motor driven pumps to ensure that at ast one SG contains i enoug water to serve as the heat si k for reactor decay I heat d sensible heat removal foll ing the reactor trip.

Functions 6.a through 6 st be OPERABLE in MODES 1,2, i and 3 to ensure that the SGs remain the heat sink for the reactor.

These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation.

e. Auxiliary Feedwater-Trio of All Main Feedwater Pumos l A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat i and sensible heat removal to bring the reactor back to no load temperature and pressure. Each turbine driven MFW pump is equipped with three pressure switches on the trip oil system. A low pressure signal from two-out-of-three of these pressure switches indicates a trip of that pump. Three OPERABLE channels per pump satisfy redundancy

. requirements with two-out-of-three logic. A trip of all MFW pumps starts the motor driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor. This function must be OPERABLE in MODES 1 and 2. This ensures that at least one SG is provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an Catawba Units 1 and 2 8 3.3.2-24 Revision No.@

I

ESFAS Instrum:ntation B 3.3.2 i BASES ACTIONS (continued)

.' Phase B Isolation; and

. Automatic Switchover to Containment Sump.

This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable,6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to restore the train to OPERABLE status. The specified Completion Time is l reasonable considering that there is another train OPERABLE, and the J low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> total time). The j Completion Times are reasonable, based on operating experience, to l reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. ,

i The Required Actions are modified by a Note that allows one train to be l bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other j train is OPERABLE. The Required Actions are not required to be met I during this time, unless the train is discovered inoperable during the testing. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 7) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance. I D.1. D.2.1, and D.2.2 Condition D applies to:

. Containment Pressure-High;

. Pressurizer Pressure-Low;

. Steam Line Pressure-Low;

. Steam Line Pressure-Negative Rate-High;

{ Lcyds of of)6ite pow 9[; an)

. SG Water level-Low Low.

Catawba Units 1 and 2 B 3.3.2-33 Revision No.$

/

j

k ) 1 ESFAS Instrumentation B 3.3.2 i BASES I SURVElu ANCE REQUIREMENTS (continued) ,

SR 3.3.2.3

- [SR 3.3.2.3 is the erformance of r. TADOT every 31 days This test is a I check of the Lo of , asite Power Function. Each Fun on is tested up to, and includi , the master transfer relay coils.

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  • This test als includes trip devices that provide actuati n signals directly to the SSP . The SR is modified by a Note that wwi es final actuation of pumps d valves to minimize plant upsets t' at w uld occur. The Frequen is adequate based on operating e.xperie e, colisidering strume reliability and operating history data.

SR 3.3.fd SR C 3.2.4 is the performance of a MASTER RELAY TEST. The MAS .'ER RELAY TEST is the energizing of the master relay, verifying coat.act operation and a low voltage continuity check of the slave relay coil. Upon mter relay contact operation, a low voltage is injected to the slave relay ( This voltage is insufficient to pick up the slave relay, but large enougt. . demonstrate signal path continuity. This test is performea every 31 days or, a STAGGERED TEST BASIS. The time allowed for the testing (4 hou.sj nnd the surveillance interval are justified in Reference 7.

SR 3.3.2.5 SR 3.3.2.5 is the performance of a COT.

A COT is performed or. sach required channel to ensure the channel will perform the intended Function. The tested portion of the loop must trip ,

within the Allowable Values specified in Table 3.3.1-1. I The setpoint shall be left set uansistent with the assumptions of the setpoint methodology.

The Frequency of 92 days is justified in Reference 7.

l L

Catawba Units 1 and 2 B 3.3.2-44 Revision No[l

r:

LOP DG Start instrumsntation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start instrumentation  !

LCO 3.3.5 Three channels per bus of the loss of voltage Function and three channels per bus of the degraded voltage Function shall be OPERABLE.

APPLICABILITY: MODES 1,2,3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, "AC l Sources- Shutdown."

ACTIONS

-NOTE - - --

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel per bus A.1 @ ace channelin trg Q inoperable. ,f ,,

B. One or more Functions B.1 Restore all but one channel 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with two or more to OPERABLE status.

channels per bus inoperable.

C. Required Action and C.1 Enter applicable immediately associated Completion Condition (s) and Required Time not met. Action (s) for the associated DG made inoperable by LOP DG start instrumentation.

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Catawba Units 1 and 2 3.3.5-1 Amendment Nos. 47 6 N n m

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!- 1 LOP DG Start instrumentation 3.3.5 l I

SURVEILLANCE REQUIREMENTS 1

SURVEILLANCE FREQUENCY SR 3.3.5.1 -- - -----

- N OTE-------------------

Testing shall consist of voltage sensor relay testing excluding actuation of ad shedding diesel start, and time delay i e '

, wet 7

Perform TADOT. 31 days  !

i SR 3.3.5.2 Perform CHANNEL CAllBRATION with Trip Setpoint 18 months  !

and Allowable Value as follows:

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a. Loss of voltage Allowable Value 2 3242 V.

Loss of voltage Trip Setpoint 2 3500 V.

b. Degraded voltage Allowable Value 2 3738 V.

Degraded voltage Trip Setpoint2 3766 V.

SR 3. :1.F.3 ----

N OTE S - - - - - ~ ~ ~ -

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8 r WM h{V fivfnp unt',l @ Aourf 4h r f 6 f reJ!vrt \f > 400 p* ,

,1. Y l E0 51 MS afflsco Us 1bOC. A*yreheh Vol h o Furetn,t.

3. 4{t rR s's cet 1 opptL% is MOPES J, .t, anj

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! l TCET 6Artr t-l Catawba Units 1 and 2 3.3.5-2 Amendment Nos.

b

LOP DG Start instrumentation B 3.3.5 BASES 1 l

J APPLICABILITY The LOP DG Start Instrumentation Functions are required in MODES 1, 2,3, and 4 because ESF Functions are designed to provide protection in these MODES. Actuation in MODE S cr 6 is required whenever the required DG must be OPERABLE so that it can perform its function on an LOP or degraded power to the vital bus.

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1 l

ACTIONS in the event a channel's Trip Setpoint is found nonconservative with l i

respect to the Allowable Value, or the channelis found inoperable, then j the function that channel provides must be declared inoperable and the LCO Condition entered for the particular protection function affected.

Because the required channels are specified on a per bus basis, the Condition may be entered separately for each bus as appropriate.

A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in the LCO. The Completion Time (s) of the inoperable channel (s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

b.:1 Condition A applies to the LOP DG start Function with one loss of voltage or degraded voltage channel per bus inoperable.

If one channelis inoperable, Required Action A.1 requires that channel to be placed in trip within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With a channelin trip, the LOP DG start instrumentation channels are configured to provide a one-out-of-two logic to initiate a trip of the incoming offsite power.

The specified Completion Time is reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals.

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s ce k & 4 h ovrt a llc ~d S r +edey , are j ubOb RefucMe,.C, Catawba Units 1 and 2 B 3.3.5-4 , Revision No$

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3 LOP DG Start instrumentation i B 3.3.5 I BASES

]

SURVEILLANCE REQUIREMENTS (continued)

'SR 3.3.5.2 I j

SR 3.3.5.2 is the performance of a CHANNEL CAllBRATION.

l The setpoints, as well as the response to a loss of voltage and a degraded voltage test, shall include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.

A CHANNEL CAllBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CAllBRATION is a complete check of the instrument loop, including the sensor. The test l verifies that the channel responds to a measured parameter within the l necessary range and accuracy. l 1

The Frequency of 18 months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the lgff/2.T assumption of an 18 month calibration intervalin the determination of the

l. 3 g,3 magnitude of equipment drift in the setpoint analysis.

l REFERENCES 1. UFSAR, Section 8.3.

2. UFSAR, Chapter 15.
3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

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l Catawba Units 1 and 2 B 3.3.5-6 Revision No. @

l L  ;

INSERT for SR 3.3.5.3:

SR 3.3.5.3 This SR ensures the individual channel response times for AFW start are less than or equal to the maximum values assumed in the accident analysis. Response time testing acceptance criteria are included in the UFSAR (Ref. 4).

Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, 3

valves in full open or closed position). The response time  !

may be measured by a series of overlapping tests such that the entire response time is measured. l Response time tests are conducted on an 18 month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. The 18 month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure,'are infrequent occurrences.

This SR_is modified by three Notes. Note 1 clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 600 psig in the SGs. Note 2 clarifies that this SR is not applicable to the degraded voltage Function.

Note 3 clarifies that this SR is only applicable in MODES 1, 2, and 3, since automatic actuation of AFW is only '

required in these MO'JES.

Proposed Change to the Applicable Conditions for the RCS Subcooling Margin Monitor j

I

[L PAM Instrumentation 3.3.3 l

Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring instrumentation i

l

! FUNCTION REQUIRED CHANNELS CONDITIONS l

1. Reactor Coolant System (RCS) Hot Leg 2 B D,F,H Ternperature (Wide Range)
2. RCS Cold Leg Temperature (Wide Range) 2 B,D,F g
3. RCS Prersure (Wide Range) 2 B,D,F,H
4. Reactor Vessel Water Level 2 B,D,F,H
5. Containment Sump Water Level (Wide Range) 2 B,D,F,H
6. Containment Pressure (Wide Range) 2 B,D,F.H
7. Containment Area Radiation (High Range) 1 B,D
8. Hydrogen Monitors 2 B D,G,H
9. Pressurizer Level 2 B,D,F,H
10. Steam Generator Water Level (Narrow Range) 2 per steam generator B,D,F,H l 11, Core Exit Temperature-Quadrant 1 B,D,F,H 2(a)
12. Core Exit Temperature -Quadrant 2 B,D,F,H 2(a)
13. Core Exit Temperature -Quadrant 3 B,D,F,H 2(a)
14. Core Exit Temperature- Quadrant 4 B D,F,H 2(a) l 15. Auxiliary Feedwater Flow 1 per steam generator C,D,E H
16. RCS Radiation Level 1 B,D
17. RCS Subcooling Margin Monitor 2 ,D H l

l 18. Steam Line Prest,ure 2 per steam generator B,D,F.H

19. Refueling Water Storage Tank Level 2 B,D,F,H
20. Neutron Flux (Wide Range) 2 B,D,F H
21. Steam Generator Water Level (Wide Range) 1 per steam generator C,D,E,H (a) A channel consists of two core exit thermocouples (CETs).

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l l Catawba Units 1 and 2 3.3.3-4 Amendment Nos.

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l PAM instrumentation B 3.3.3 l

BASES I

LCO (continued)

One channel per SG of AFW flow is required to be OPERABLE.

Diverse indication of AFW flow is provided by SG level.

16. RCS Radiation Level a I

The RCS radiation monitor provides indication of radiation levels within the primary coolant and alerts the operator to possible fuel (

clad failures. 1 One channel of RCS radiation levelis required OPERABLE. This 4

monitor was not installed to quantify accident conditions and j

cannot be assured flow following an accident. Diverse or backup information for this variable is provided by sampling and analysis of the primary coolant. -

17. "#^

RCS Subcoolino Marain Monitor RCS subcoolingk provided to allow unit stabilization and cooldown control. RCS subcoolin @llow termination of SI,if stillin progress, or reinitiation of Si if it has been stopped.

%Aon A f50
  • The margin to saturation is calculated from RCS pressure and to & e M U U temperature measurements. The average of the five highest core exit thermocouples are used to represent core conditions and the wide range hot leg RTDs are used to measure loap hot leg temperatures. The ICCM System performs the calculations and comparisons to saturation curves. A graphic display over the required range gives the operator a representation of primary system conditions compared to various curves of importance (saturation, NDT, etc.). Two trains of RCS Subcooling Margin Monitor are provided and two trains are required to be OPERABLE. ,

I A backup program exists to ensure the capability to accurately monitor RCS subcooling. The program includes training and a .

procedure to manually calculate subcooling margin, using control room pressure and temperature instruments.

18. Steam Line Pressure Steam Line Pressure is provided to monitor operation of decay heat removal via the SGs. Steam line pressure is also used to determine if a high energy secondary line rupture occurred and which SG is faulted.

Catawba Units 1 and 2 B 3.3.3-10 Revision No.$ l

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Proposed Change to SR 3.4.17.2 to Reference P-10 and P-13 Instead of P-7 l

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RCS Loops -Test Exc:ptions 3.4.17 l

l 3.4 REACTOR COOLANT SYSTEM (RCS) l 3.4.17 RCS Loops-Test Exceptions i

l LCO 3.4.17 The requirements of LCO 3.4.4, *RCS Loops-MODES 1 and 2," may be suspended, with THERMAL POWER < P-7.

APPLICABILITY: MODES 1 and 2 during startup and PHYSICS TESTS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. THERMAL POWER A.1 Open reactor trip breakers. Immediately

> P-7.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.4.17.1 Verify THERMAL POWER is < P-7. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> SR 3.4.17.2 Perform a COT for each power range neutron flux-low Prior to initiation of and intermediate range neutron flux channe@ startup and PHYSICS TESTS

{p jpg,j go j3]

Catawba Units 1 and 2 3.4.17-1 Amendment Nos.

RCS Loops -Test Exceptions j B 3.4.17 )

BASES ,

SURVEILLANCE SR 3.4.17.1

= REQUIREMENTS Verification that the power level is < the P-7 interlock setpoint (10%) will ensure that the fuel design criteria are not violated during the performance of the PHYSICS TESTS. The Frequency of once per hour is adequate to ensure that the power level does not exceed the limit. Plant operations are conducted slowly during the performance of PHYSICS TESTS and monitoring the power level once per hour is sufficient to ensure that the power level does not exceed the limit.

SR 3.4.17.2 yIOodM M @ l The power range and intermediate range neutron detectors an the P-7 }

interlock setpoint must be verified to be OPERABLE and adjusted to the proper value. A COT is performed prior to initiation of the PHYSICS  !'

TESTS. This will ensure that the RTS is properly aligned to provide the required degree of core protection during the performance of the PHYSICS TESTS.

REFERENCES 1. 10 CFR 50, Appendix B, Section XI.

2. 10 CFR 50, Appendix A, GDC 1,1988.
3. 10 CFR 50.36, Technical Specifications, (c)(2)(li).

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l Catawba Units 1 and 2 83.4.173 Revision No.8)

I

Proposed Change to TS 5.3 to Delete Reference to the Stated Requirements for Licensed Operators and Senior Reactor Operators l

3

Unit Staff Qual;fications 5.3 5.0 ADMINISTRATIVE CONTROLS

. 5.3 Unit Staff Oualifications l-1 l

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except the Radiation Protection

! Manager, who shalj meet or exceed the qualifications of Reaulatory Guide 1.8.

l September __1975.lThe licensed Operators and niorReactorOperator shall Iso meet or e ceed the minimum qualification of the supplemental requirements cified in Sections A and C of nclosure 1 of the Mar 28,1980 NRC letter t alllicensees. However, the e i-described rience and other consi erations Duke Power Company's letters ated August 29,1985, nd July 8, 1986, are cceptable for the six and two ap licants for SRO license identified Qherein, spectively.

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Catawba Units 1 and 2 5.3-1 Amendment Nos.

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l ATTACHIGNT 2 REPRINTED TECHNICAL SPECIFICATIONS PAGES FOR CATAWBA l

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l Proposed Change to TS 3.3.2, Conditions Q and R for Nuclear Service Water System (NSWS) Suction Transfer-Low Pit Level Channels l

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ESFAS instrumentation I 3.3.2 ACTIONS (continued)

CONDITION . REQUIRED ACTION COMPLETION TIME O. One channelinoperable. O.1 Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> l required state for existing unit condition.

M O.2.1 Be in MODE 3. 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> A_NQ O.2.2 Be in MODE 4. 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> P. One or more P.1 Declare affected supported immediately Containment Pressure system inoperable.

Control System channel (s) inoperable.

Q. One Nuclear Service Q.1 -

NOTE Water Suction Transfer- The inoperable channel Low Pit Level channel in may be bypassed for up to one or more pits 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance inoperable. testing of other channels.

Place channel in trip. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> M

Q.2 Align the Nuclear Service 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Water System for Standby Nuclear Service Water Pond recirculation.

M Q.3.1 Be in MODE 3. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> AN_Q Q.3.2 Be in MODE 5. 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> l (continued)

Catawba Units 1 and 2 3.3.2-7 Amendment Nos. I

)

ESFAS instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME R. Two or more Nuclear R.1 Align the Nuclear Service 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> l Service Water Suction Water System for Standby Transfer-Low Pit Level Nuclear Service Water channels in one or more Pond recirculation.

pits inoperable.

QB R.2.1 Be in MODE 3. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> AtQ R.2.2 Be in MODE 5. 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> i

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Catawba Units 1 and 2 - 3.3.2-8 Amendment Nos.

I ESFAS Instrumentation )

B 3.3.2  !

BASES l l  !

ACTIONS- (continued) i O.1,0.2.1 and O.2.2 )

Condition O applies to the P-11 and P-12 Interlocks.

With one channel inoperable, the operator must verify that the interlock is l.

in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made ,

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time allowed I by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed  :

in the required state) for the existing unit condition, the unit must be -

placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for ,

OPERABILITY of these interlocks. l P_,d Condition P applies to the Containment Pressure Control System Start l and Terminate Permissives. I With one or more channels inoperable, the affected containment spray and containment air return systems components must be declared .

inoperable immediately. The supported system LCOs provide the l appropriate Required Actions and Completion Times for the equipment made inoperable by the inoperable channel. The immediate Completion Time is appropriate since the inoperable channel could prevent the  !

supported equipment from starting when required. Additionally, . I protection from an inadvertent actuation may not be provided if the terminate function is not OPERABLE.

4 l

l Q.1, 0.2, Q.3.1, and 0.3.2 l With one' channel of NSWS Suction Transfer - Low Pit Level inoperable in one or more NSWS pits,4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are allowed to place it in the tripped  ;

condition or align the NSWS to the Standby NSWS Pond. The failure of i one channel places the Function in a two-out-of-two configuration. The 1

l Catawba Units 1 and 2 B 3.3.2-41 Revision No.1

l ESFAS Instrumentation B 3.3.2 BASES ACTIONS (continued) failed channel must either be tripped to place the Function in a one-out-of-two configuration that satisfies redundancy requirements, or the NSWS realigned to fulfill the safety function.

Failure to place the channel in the tripped condition or to realign the -

NSWS suction and discharge within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requires the unit be placed 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 MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, this Function is no longer required OPERABLE.

R.1. R.2.1. and R.2.2 With two or more channels of NSWS Suction Transfer Low Pit Level inoperable in one or more pits, the NSWS must be aligned to the Standby NSWS Pond within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Failure to accomplish the realignment within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requires the unit be placed 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 MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, this Function is no longer required OPERABLE.

SURVEILLANCE The SRs for each ESFAS Function are identified by the SRs column REQUIREMENTS of Table 3.3.2-1.

A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.

Note that each channel of process protection supplies both trains of the ESFAS. When testing channel 1, train A and train B must be examined.

Similarly, train A and train B must be examined when testing channel 11, channelill, and channelIV (if applicable). The CHANNEL CAllBRATION and COTS are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.

Catawba Units 1 and 2 B 3.3.2-42 Revision No.1 L

Preposed Change to TS Table 3.3.2-1 t.o Delete Function 6d, Auxiliary Feedwater Loss of Offsite Power

ESFAS Instrum ntation 3.3.2 SURVEILLANCE REQUIREMENTS NOTE-Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function. ,

SURVEILLANCE FREQUENCY L

SR 3.3.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.2.2 Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED l TEST BASIS 1

SR 3.3.2.3 Not used. l l

l SR 3.3.2.4 Perform MASTER RELAY TEST. 31 days on a STAGGERED TEST BASIS l SR 3.3.2.5 Perform COT. 92 days SR 3.3.2.6 Perform SLAVE RELAY TEST. 92 days SR 3.3.2.7 Perform COT. 31 days (continued)

Catawba Units 1 and 2 3.3.2-9 Amendment Nos.

c ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 4 of 5)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

6. Auxiliary Feedwater
a. Automatic 1,2,3 2 trains H SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3.2.6 Relays
b. SG Water Level- 1,2,3 4 per SG D SR 3.3.2.1 29% 2 10.7%

Low Low SR 3.3.2.5 (Unit 1) (Unit 1)

SR 3.3.2.9 2 35.1 % 2 36.8 %

SR 3.3.2.10 (Unit 2) (Unit 2)

c. Safety injection Refer to Function 1 (Safety injection) for all initiation functions and requirements.
d. Not used l
e. - Trip of all Mair' 1,2(a) 3 per pump K SR 32.2.8 NA NA Feedwater SR 3.3.2.10 Pumps
f. Auxillary 1,2,3 3 per train M SR 3.3.2.8 A) 2 9.5 psig A) 210.5 Feedwater Pump SR 3.3.2.10 psig Tra'n A and Train B Suction B) 2 5.2 psig B) 2 6.2 Transfer on (Unit 1) psig Suction Pressure 2 5.0 psig (Unit 1)

Low 2 6.0 psig (Unit 2)

(Unit 2)

7. Automatic Switchover to Containment Sump
a. Automatic ' 2,3,4

, 2 trains C SR 3.3.2.2 NA NA Actuation Logic ' SR 3.3.2.4 and Actuation SR 3.3.2.6 Relays

b. Refueling Water 1,2,3,4 4 N SR 3.3.2.1 2 162.4 2 177.15 Storage Tank SR 3.3.2.7 inches inches (RWST) Level- SR 3.3.2.9 Low SR 3.3.2.10 Coincident with Refer to Function 1 (Safety injection) for all initiation functions and requirements.

Safety injection (continued)

(a) Above the P-11 (Pressurtzer Pressure) interlock.

l l

i Catawba Units 1 and 2 3.3.2-14 Amendment NOS.

o

ESFAS Instrumsntation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

d. Not used l Functions 6.a through 6.c must be OPERABLE in MODES 1,2, l and 3 to ensure that the SGs remain the heat sink for the reactor.

These Functions do not have to be OPERABLE in MODES 5 and 6 l because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation.

e. Auxiliary Feedwater-Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no I

load temperature and pressure. Each turbine driven MFW pump is equipped with three pressure switches on the trip oil system. A low pressure signal from two-out-of-three of these pressure switches indicates a trip of that pump. Three OPERABLE channels per pump satisfy redundancy requirements with two-out-of-three logic. A trip of all MFW pumps starts the motor driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor. This function must be OPERABLE in MODES 1 and 2. This ensures that at least one SG is provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an i

Catawba Units 1 and 2 B 3.3.2-24 Revision No.1

E ESFAS Instrumentation B 3.3.2 BASES l ACTIONS (continued) l

. Phase B isolation; and 1

. Automatic Switchover to Containment Sump.

This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable,6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> are allowed to restore the train to OPERABLE status. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> total time) and in MODE 5 within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. ,

The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other train is OPERABLE. The Required Actions are not required to be met during this time, unless the train is discovered inoperable during the testing. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 7) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.

D.1, D.2.1, and D.2.2 Condition D applies to:

. Containment Pressure-High;

. Pressurizer Pressure-Low;

. Steam Line Pressure-Low;

. Steam Line Pressure-Negative' Rate-High; and

. SG . Water level-Low Low.

1 Catawba Units 1 and.2 8 3.3.2-33 Revision No.1

I 3

, 1 ESFAS Instrum::ntation BASES SURVEILLANCE REQUIREMENTS (continued) i l SR 3.3.2.3

)

l Not used.

SR 3.3.2.4 SR 3.3.2.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the -

slave relay coil. This voltage is insufficient to pick up the slave relay, but  !

large enough to demonstrate signal path continuity. This test is performed every 31 days on a STAGGERED TEST BASIS. The time allowed for the testing (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) and the surveillance interval are justified in Reference 7.

l SR 3.3.2.5 SR 3.3.2.5 is the performance of a COT.

l A COT is performed on each required channel to ensure the channel will perform the intended Function. The tested portion of the loop must trip within the Allowable Values specified in Table 3.3.1-1.

The setpoint shall be left set consistent with the assumptions of the setpoint methodology.

The Frequency of 92 days is justified in Reference 7.

l Catawba Units 1 and 2 B 3.3.2-44 Revision No.1 I

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LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION l< 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start instrumentation LCO 3.3.5 Three channels per bus of the loss of voltage Function and three channels per bus'of the degraded voltage Function shall be OPERABLE.

APPLICABILITY: MODES 1,2,3, and 4,'

When associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources-Shutdown."

ACTIONS NOTE Separate Condition entry is allowed for each Function.

4 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 NOTE-------

with one channel per bus The inoperable channel inoperable. may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels.

Place channelin trip. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> i

B. One or more Functions B.1 Restore all but one channel 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with two or more to OPERABLE status.

channels per bus inoperable

'C. Required Action and C.1 Enter applicable immediately associated Completion Condition (s) and Required i

Time not met. Action (s) for the associated DG made inoperable by LOP DG start instrumentation.

' Catawba Units .1 and 2 3.3.5-1 Amendment Nos.

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LOP DG Start instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 -

NOTE Testing shall consist of voltage sensor relay testing excluding actuation of load shedding diesel start, and time delay timers. l Peiform TADOT. 31 days SR 3.3.5.2 ' Perform CHANNEL CAllBRATION with Trip Setpoint 18 months and Allowable Value as follows:

a. Loss of voltage Allowable Value 23242 V.

Loss of voliage Trip Setpoint 2 3500 V.

b. Degraded voltage Allowable Value 2 3738 V.

Degraded voltage Trip Setpoint 2 3766 V.

SR 3.3.5.3 - -- - - -


NOTES

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after SG pressure is 2 600 psig.
2. This SR is not applicable to the degraded voltage Function.
3. This SR is only applicable in MODES 1,2, and 3.

Verify channel response times are within limit for AFW 18 months on a start. STAGGERED TEST BASIS Catawba Units 1 and 2 3.3.5-2 Amendment Nos.  ;

l

I-LOP DG Start Instrum:ntation B 3.3.5 BASES APPLICABILITY The LOP DG Start Instrumentation Functions are required in MODES 1, 2,3, and 4 because ESF Functions are designed to provide protection in these MODES. Actuation in MODE 5 or 6 is required whenever the required DG must be OPERABLE so that it can perform its function on an LOP or degraded power to the vital bus.

l ACTIONS In the event a channel's Trip Setpoint is found nonconservative with I respect to the Allowable Value, or the channel is found inoperable, then I the function that channel provides must be declared inoperable and the l LCO Condition entered for the particular protection function affected.

Because the required channels are specified on a per bus basis, the ,

Condition may be entered separately for each bus as appropriate. l A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be l entered independently for each Function listed in the LCO. The Completion Time (s) of the inoperable channel (s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A_1 Condition A applies to the LOP DG start Function with one loss of voltage or degraded voltage channel per bus inoperable.

If one channelis inoperable, Required Action A.1 requires that channel to be placed in trip within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With a channelin trip, the LOP DG start instrumentation channels are configured to provide a one-out-of-two logic to initiate a trip of the incoming offsite power.

The specified Completion Time is reasonable considering the Function remains fully OPERABLE on every bus and the low probability of an event occurring during these intervals.

The Required Action is modified by a Note that allows the inoperable channel to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other channels. The 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed to restore the channel to OPERABLE status or to place the inoperable channel in the tripped condition, and the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed for testing, are justified in Reference 5.

1 l-Catawba Units 1 and 2 B 3.3.5-4 Revision No.1

v l LOP DG Start Instrumentation B 3.3.5 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.2

- SR 3.3.5.2 is the performance of a CHANNEL CAllBRATION.

1 The setpoints, as well as the response to a loss of voltage and a <

degraded voltage test, thall include a single point verification that the trip occurs within the requir d time delay, as shown in Reference 1.

A CHANNEL CAllBRATION is performed every 18 months, or <

approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The tot verifies that the channel responds to a measured para;r.eter wit .... the f'

necessary range and accuracy.

The Frequency of 18 months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an 18 month calibration intervalin the determination of the {

1 magnitude of equipment drift in the setpoint analysis. j l

SR 3.3.5.3  !

l This SR ensures the individual channel respoora times for AFW ste,t are less than or equal to the maximum values assumed in the accidern i analysis. Response time testing acceptance criteria are included in the I UFSAR (Ref. 4). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, j from the point at which the parameter exceeds the Trip Setpoint value at i the sensor, to the point at which the equipment in both trains reaches the l required functional state (e.g., pumps at rated discharge pressure, valves  !

In full open or closed position). The response time may be measured by a series of overlapping tests such that the entire response time is ];

measured.

Response time tests are conducted on an 18 month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. The 18 month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degmdation, but not channel failure, are infrequent occurrences.

Catawba Units 1 and 2 B 3.3.5-6 Revision No.1 l

LOP DG Start Instrumsntation B 3.3.5 BASES

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This SR is modified by three Notes. Note 1 clarifies that the turbine l

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driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 600 psig in the SGs. Note 2 clarifies that this SR is not applicable to the degraded voltage Function. Note 3 clarifies that this SR is only applicable in MODES 1,2, and 3, since automatic actuation of AFW is only required in these MODES.

i REFERENCES 1. UFSAR, Section 8.3.

2. UFSAR, Chapter 15.
3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).
4. UFSAR, Chapter 7.
5. WCAP-10271-P-A, Supplement 1 and Supplement 2, Rev.1, May, 1986 and June,1990.

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l Catawba Units 1 and 2 B 3.3.5-7 Revision No.1

Proposed Change to the Applicable conditions for the RCS Subcooling Margin Monitor I

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PAM instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation FUNCTION REQUIRED CHANNELS CONDITIONS

1. Reactor Coolant System (RCS) Hot Leg 2 D.D F,H Temperature (Wide Range)
2. RCS Cold Leg Temperature (Wide Range) 2 B,D,F,H l
3. RCS Pressure (Wide Range) 2 B,D,F,H
4. Reactor Vessel Water Level 2 B,D,F,H
5. Containment Sump Water Level (Wide Range) 2 B D,F,H
6. Containment Pressure (Wide Range) 2 B,0,F H j

/. Containment Area Radiation (High Range) 1 B,D

8. Hydrogen Monitors 2 B,0,G,H
9. Pressurizer Level 2 B D,F,H
10. Steam Generator Water Level (Narrow Range) 2 per steam generator B,D,F,H
11. Core Exit Temperature - Quadrant 1 2(a) B,D,F,H l
12. Core Exit Temperature - Quadrant 2 2(a) B,D.F,H
13. Core Exit Temperature - Quadrant 3 2(a) B,D,F,H
14. Core Exit Temperature - Quadrant 4 B,D,F,H l 2(a)
15. Auxiliary Feedwater Flow 1 per steam generator C,D.E,H
16. RCS Radiation Level 1 B,D
17. RCS Subcooling Margin Monitor 2 8,D,F,H l
18. Steam Line Pressure 2 per steam generator B D,F,H
19. Refueling Water Storage Tank Level 2 B,D,F,H
20. Neutron Flux (Wide Range) 2 B.D,F,H
21. Steam Generator Water Level (Wide Range) 1 per steam generator C,D.E,H (a) A channel consists of two core exit thermocouples (CETs).

Catawba Units 1 and 2 3.3.3-4 Amendment NoS,

PAM Instrumentation B 3.3.3 BASES LCO (continued)

One channel per SG of AFW flow is required to be OPERABLE.

Diverse indication of AFW flow is provided by SG level,

16. Ry r adiation Level

' i :v RCS radiation monitor provides indication of radiation levels within the primary coolant and alerts the operator to possible fuel clad failures.

One channel of RCS radiation level is required OPERABLE. This monitor was not installed to quantify accident conditions and -

cannot be assured flow following an accident. Diverse or backup information for this variable is provided by sampling and analysis of the primary coolant.

17. RCS Subcooling Margin Monitor RCS subcooling margin monitoring indication is provided to allow unit stabilization and cooldown control. RCS subcooling margin monitoring indication will provide information to the operators to allow termination of SI, if still in progress, or reinitiation of Si if it has ben stopped.

The margin to saturation is calculated from RCS pressure and temperature measurements. The average of the five highest core exit thermocouples are used to represent core conditions and the wide range hot leg RTDs are used to measure loop hot ieg temperatures. The ICCM System performs the calculations and comparisons to saturation curves. A graphic display over the required range gives the operator a representation of primary i system conditions compared to various curies of importance (saturation, NDT, etc.). Two trains of RCS Subcooling Margin Monitor are provi6d and two trains are required to be OPERABLE.

A backup program exists to ensure the capability to accurately monitor RCS subcooling. The program includes training and a procedure to manually calculate subcooling margin, using control room pressure and temperature instruments.

18. Steam Line Pressure Steam Line Pressure is provided to monitor operation of decay heat removal via the SGs. Steam line pressure is also used to detarmine if a high energy secondary line rupture occurred and which SG is faulted.

Catawba Units 1 and 2 B 3.3.3-10 Revision No.1 e

Proposed Change to SR 3.4.17.2 to Reference P-10 and P-13 Instead of P-7 i

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fr'r RCS Loops-Test Exceptions 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 RCS Loops-Test Exceptions LCO 3.4.17 - The requirements of LCO 3.4.4,"RCS Loops-MODES 1 and 2," may be suspended, with THERMAL POWER < P-7.

JAPPLICABILITY: ~ MODES 1 and 2 during startup and PHYSICS TESTS.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. THERMAL POWER A.; Open reactor trip breakers. Immediately

> P-7.

SURVEILLANCE REQUIREMENTS

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SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify THERMAL POWER is < P-7. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> SR 3.4.17.2 Perform a COT for each power range neutron flux-low Prior to initiation of and intermediate range neutron flux channel, P-10,' and startup and P-13. PHYSICS TESTS i,

. Catawba Units 1 and 2 3.4.17-1 Amendment Nos.

RCS Loops -Test Exc:ptions B 3.4.17 l

BASES l

' SURVEILLANCE SR 3.4.17.1 REQUIREMENTS Verification that the power level is < the P-7 interlock setpoint (10%) will ensure that the fuel design criteria are not violated during the

. performance of the PHYSICS TESTS. The Frequency of once per hour is adequate to ensure that the power level does not exceed the limit.

Plant operations are conducted slowly during the performance of PHYSICS TESTS and monitoring the power level once per hour is sufficient to ensure that the power level does not exceed the limit.

1 SR 3.4.17.2 The power range and intermediate range neutron detectors and P-10 and P-13 inputs to the P-7 Interlock setpoint must be verified to be OPERABLE and adjusted to the proper value. A COT is performed prior to initiation of the PHYSICS TESTS. This will ensure that the RTS is properly aligned to provide the required degree of core protection during the performance of the PHYSICS TESTS.

REFERENCES 1. 10 CFR 50, Appendix B, Sectic,n XI.

2. 10 CFR 50, Appendix A, GDC 1,1988.
3. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

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1 Catawba Units 1 and 2 B 3.4.17-3, Revision No.1

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l Proposed Change to TS 5.3 to Delete Reference to the Stated Requirements for Licensed Operators and Senior Reactor Operators s

Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N18.1-1971 for comparable positions, except the Radiation Protection Manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

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I Catawba Units 1 and 2 5.3-1 Amendment Nos.

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. l ATTACHNENT 3 DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION ,

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Description of Proposed Changes and Technical Justification Change #1 - Modify TS 3.3.2, Conditions Q and R for Nuclear Service Water System (NEWS) Suction Transfer-Low Pit Level Channels:

The purpose of this Engineered Safety Feature Actuation System'(ESFAS) Instrumentation function is to isolate the

.NSWS from Lake Wylie, align the NSWS to the Standby Nuclear Service Water Pond, close certain crossover valves in the NSWS, and start the NSWS pumps. This function is initiated l on a two-out-of-three logic emergency low pit level signal from either NSWS pump pit.

TS 3.3.2, Condition Q applies to the case of one inoperable i NSWS Suction Transfer-Low Pit Level channel. The required actions for this condition mandate either placing the inoperable channel in trip within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or to be in Mode .

3 and Mode 5 as specified. An additional required action option is being proposed to allow the alternative of aligning the NSWS for Standby Nuclear Service Water Pond  !

recirculation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This is acceptable from a safety standpoint, since aligning the NSWS in the described manner places the system suction and discharge in its safety configuration. The Standby Nuclear Service Water Pond cesign heatup analysis assumes accident initiation with the pond at its TS upper limit of 91.5 degrees F at 568 feet elevation. Even at these initial conditions, the accident loads of one unit plus the shutdown loads of the other unit do not cause the pond temperature to exceed the limit required for accident mitigation and equipment qualification concerns. Even if the NSWS were aligned to the pond in response to the inoperable pit level channel as being proposed in Condition Q, the pond thermal analysis would not be invalidated. The decision en whether to align to the pond or to place the inoperable channel in trip must be made based on the pond temperature at the time of the channel failure (i.e., time of year) and the potential need to place any of the remaining operable channels in the trip condition (e.g., for testing). Typically, the plant is not operated for long perieds with the NSWS aligned to the pond and would not normally operate in such a configuration with only one inoperable pit level channel. However, the proposed change provides additional flexibility and is consistent with the required action for two or more inoperable channels. (See the proposed change below associated with Condition R.)

TS 3.3.2, Condition R states:

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i "Two Ncclear Service Water Suction Transfer-Low Pit Level  !

channels in one or more pits inoperable.'

The Required Action for. Condition R is to either align the j NSWS for Standby Nuclear Servico Water Pond recirculation I within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or to be in Mode 3 and Mode 5 as specified.

Since there is no specified condition for three inoperable {

channels of this function, the affected unit (s) would have i to enter TS 3.0.3 should three channels become inoperable.

Prior to implementation of the Improved TS at Catawba, the previous TS contained an Action Statement (Table 3.3-3, Action 29b) which read as follows:

"With less than the Minimum Number of Channels OPERABLE l align the Nuclear Service Water System for Standby Nuclear j Service Water Pond recirculation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or be in at i least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least COLD l

SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

In previous TS Table 3.3-3, the MINIMUM CHANNELS OPERABLE requirement was specified as two per pit. Therefore, Action 29b was applicable in the event either zero or one channel was operable. In the Improved TS, Action 29b became )

Condition R. This translation was a purely administrative

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change; there was not intended to be any change in technical l requirements. Therefore, Improved TS 3.3.2, Condition R should have read-I "Two or more Nuclear Service Water Suction Transfer-Low Pit Level channels in one or more pits inoperable."

Consequently, Improved TS 3.3.2, Condition R is being changed to this proposed wording. There are no safety implications to this proposed change, since it merely corrects an editorial error that was inadvertently introduced during the Improved TS conversion process and it maintains the previous requirement that existed for three l

inoperable channels of this function. The Improved TS '

Required Action R.1 requirement of aligning the NSWS for Standby Nuclear Service Water Pond recirculation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the appropriate action whether two or three channels of this functica are inoperable.

Change #2 - Delete TS Table 3.3.2-1 Function 6d, Auxiliary Feedwater Loss of Offsite Power:

TS Table 3.3.2-1, Function 6d delineates requirements for Auxiliary Feedwater Loss of Offsite Power. This function reflects the fact that a loss of power (i.e., a voltage  ;

reduction) to either essential service bus will start the '

turbine driven and motor driven auxiliary feedwater pumps to ensure adequate heat removal via the steam generators.

. Function 6d specifies a requirement of three operable channels per hus. It also references a condition (Condition ,

D) for one channel inoperable. With one channel inoperable, '

the associated required action is to place the inoperable channel in trip within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Mode 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. There are no specified conditions stated for more than one inoperable channel; therefore, TS 3.0.3 would apply in this situation.

TS 3.3.5 delineates requirements for Loss of Power (LOP)

Diesel Generator (DG) Start Instrumentat.i on. This TS contains conditions for any number of incperable channels per bus, such that TS 3.0.3 does not need to be entered for any particular configuration of inoperable channels.

. Condition B pertains to "One or more Functions with two or more channels per bus inoperable." Required Action B.1 for this condition mandates restoration of all but one channel to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. It is therefore not necessary to enter TS 3.0.3 for the case of more than one inoperable channel per bus, since a specific condition exists for this situation. However, in TS Table 3.3.2-1, no specific condition exists for the case of more than one inoperable channel per bus; therefore, TS 3.0.3 would be l required to be entered according to Table 3.3.2-1. This  ;

represents an inconsistency in the TS requirements for this I function; the instrumen;ation channels (relays) addressed in TS Table 3.3.2-1, Function 6d and in TS 3.3.5 are physically j the same equipment. J Catawba is proposing to delete the TS Table 3.3.2-1 entry for Auxiliary Feedwater Loss of Offsite Power (Function 6d).

This is acceptable, since TS 3.3.5, Condition B represents a comparable and adequate control for the case of more than one inoperable channel per bus. The appropriate action for continued inoperability of more than one channel of LOP DG start instrumentation per bus is delineated by TS 3.3.5, Condition C, which requires immediate entry into the applicable conditions and required actions for the associated DG made inoperable by the LOP DG start instrumentation.

I' These proposed changes are acceptable, since entry into the DG specification conditions and required actions for ,

continued inoperability of-more than one channel of LOP DG I

'startLinstrumentation represents an acceptable remedial action. The DG specification (TS 3.8.1) requires an evaluation of required features that may be affected by the DG being inoperable, including features in the Auxiliary Feedwater System. It is not necessary to-require a TS 3.0.3 i entry and associated plant shutdown within the time limits of TS 3.0.3-for more than one inoperable channel, when a TS 3.0.3 entry is not required for the case of an inoperable DG.

Function 6d of TS Table 3.3.2-1 presently specifies three surveillances. They are:

SR 3.3.2.3 day Trip Actuating Device Operational Test SR 3.3.2.9 month Channel Calibration '

SR 3.3.2.10 month (staggered test basis) Response Time Verification TS 3.3.5 presently specifies two surveillances. They are:

SR 3.3.5.1 day Trip Actuating Device Operational Test SR 3.3.5.2 month Channel Calibration In support of this change, a new SR 3.3.5.3 is proposed, I which is the 18-month (staggered test basis) Response Time  !

. Verification. This SR is-only applicable to the Loss of Voltage Function, as it presently is in TS Table 3.3.2-1,

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l Function 6d. Also, this SR is only applicable in Modes 1, 1 2, and 3, as it presently is in TS Table 3.3.2-1, Function 6d. Therefore, all surveillances presently associated with

, Function 6d will continue to be applicable in conjunction with TS 3.3.5. Note that SR 3.3.2.3 can be deleted with the deletion of Function 6d, as this surveillance is not utilized for any of the other functions of TS Table 3.3.2-1.  !

Note that Required Action A.1 and its associated Bases for TS 3.3.5 is also modified to include the addition of the Note that is contained in TS 3.3.2, Condition D. This Note governs placing a channel in bypass for testing. The inclusion of this Note in TS 3.3.5 is necessary since Function 6d is being removed from TS 3.3.2.

Finally, a typographical error in SR 3.3.5.1 is also being corrected by this proposed amendment; " times" should be

" timers". I

Change #3 - Modify the Applicable Conditions for the RCS Subcooling Margin Monitor:

This proposed change revises TS Table 3.3.3-1, Function 17, 4 RCS Subcooling Margin Monitor, to reflect Conditions B, D, i F, H in lieu of Conditions C, D, E, H. The previous Catawba TS (prior to the Improved TS) only required one channel of this function to be operable. The initial Improved TS license amendment submittal of May 27, 1997 maintained the same requirement. During the NRC comment resolution phase of the amendment submittal review, Catawba proposed to increase the number of required channels from 1 to 2. This proposal was' included in Supplement 5 of the Improved TS amendment submittal dated June 24, 1998, as item 3.3-01.

The change increased the number of required channels without l changing the corresponding required actions. The required I actions currently specified in TS 3.3.3 for the RCS l Subcooling Margin Monitor (C, D, E, H) are for functions with only one required channel. Functions with two required l

l channels specify Conditions B, D, F, H. The completion '

times for these actions are the same; the only difference is that single channel functions rely on a diverse channel (in order to provide two overall indications of the function) and Conditions C and E are written to address the t operability status of the diverse channel. After the increase in the number of required channels from 1 to 2., the ]

RCS Subcooling Margin Monitor no longer needed to reference conditions associated with the diverse channel concept.

This proposed change is therefore an administrative change to correct an oversight during the Improved TS amendment process, as described above. There is no change in completion times for any required actions and no reduction in capability to meet the required monitoring function.

Note that on Table 3.3.3-1, Function 2 (RCS Cold Leg Temperature (Wide Range)), the typographical error (use of a

" after Condition F) has also been corrected.

Change #4 - Modify SR 3.4.17.2 to Reference P-10 and P-13 Instead of P-7:

TS 3.4.17 is the RCS Loops-Test Exceptions specification.

This test exception allows the requirements of TS 3.4.4, F.C?

Loops-MODES 1 and 2, to be suspended when thermal power is below P-7. This test exception provides an exception to TS 3.4.4 in order to permit reactor criticality under no flow conditions during certain tests (such as natural circulation demonstration, station blackout, and loss of offsite power).

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l These tests were performed using this test exception during )

Catawba initial startup testing.  !

l SR 3.4.17.2 of the test exception requires a COT (channel }

operational test) for each power range neutron flux-low and j intermediate range neutron flux channel'and P-7. In I actuality, P-7 is the Low Power Reactor Trips Block function, which has two inputs: Power Range Neutron Flux, ,

P-10 and Turbine Impulse Pressure, P-13. The P-7 interlock j is generated within the Solid State Protection System, with j the initiators being a two-out-of-four P-10 nuclear 1 instrumentation system power range channels greater than or equal to 10% power, or a one-out-of-two P-13 turbine impulse pressure greater-than or equal to 10% power. Verification of the P-7 interlock would therefore require a COT to be performed on each channel of nuclear instrumentation systen?

power range and each channel of turbine impulse pressure.

Since P-7 is a logic function, specification of a COT is incorrect. The' incorrect reference to P-7 in SR 3.4.17.2 occurred as a result of a similar error in Catawba's previous TS (prior to the Improved TS), as well as a similar error in NUREG-1431, Revision 1, " Standard Technical Specifications, Westinghouse Plants," which formed the basis for the Catcwba Improved TS. TS 3.3.1, Table 3.3.1-1, Funct3cn 16b, correctly specifies an actuation logic test for the P-7 function. In addition, Table 3.3.1-1, Functions 16e and 16f, correctly specify both a channel calibration and a COT for the P-10 and P-13 functions, respectively. To be consistent and correct with respect to the requirements of Table 3.3.1-1, SR 3.4.17.2 should specify a COT for P-10 and P-13, rather than for P-7. SR 3.4.17.2 is therefore 1 modified to specify a COT for P-10 and P-13, in addition to the COT already specified for the power range neutron flux-low and intermediate range neutron flux channels.

For Changes #1-4, appropriate changes to the TS Bases are also proposed consistent with the changes proposed to the TS themselves.

Change #5 - Modify TS 5.3 to Delete Reference to the Stated Requirements for Licensed Operators and Senior Reactor Operators:

TS 5.3.1, which governs unit staff qualifications, is proposed to be modified to delete those references to additional requirements pertaining to licensed Operators and Senior Reactor Operators. These additional requirements were included in the TS based on the March 28, 1980 NRC letter to all licensees. NUREG-1431, Revision 1, ' Standard Technical Specifications, Westinghouse Plants," formed the

F basis for the Catawba and McGuire TS. NUREG-1431 recommends specifying minimum qualifications for members of the unit staff by use of an overall qualification statement. NUREG-1431 does not include reference to any supplemental qualification requirements for licensed Operators and Senior

-Reactor Operators.

Deletion of the: reference to the stated requirements for licensed Operators.and Senior Reactor Operators is acceptable because 10 CFR 55. specifies requirements pertaining to operatIr licenses. Catawba's_ operator licensing program meets all requirements of 10 CFR 55; therefore, it is not necessary to include additional requirements in the TS. This philosophy is identical to that employed in other sections of the Improved TS where requirements specified in regulations did not need to be duplicated in the TS. In addition, the NRC has previously reviewed and accepted Catawba's operator licensing program. ,

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ATTACIDEMET 4 8I MIFI N HAZARDS CONSIDERATION DETERNINATION l

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No Significant Hazards Consideration Determination i The following discussion is a summary of the evaluation of the changes contained in this proposed amendment against the 10 CFR 50.92(c) requirements to demonstrate that all three standards are satisfied. A no significant hazards consideration is indicated if operation of the facility in accordance with the proposed amendment would not:

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1. Involve a significant increase in the probability or I

. consequences of an accident previously evaluated, or l l

2. Create the possibility of a new or different kind of accident from any accident previously evaluated, or i
3. Involve a significant reduction in a margin of safety. I First Standard l

Implementation of this amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. Approval of this amendment will have no effect on accident probabilities or consequences. For proposed changes #1-4, the systems and equipment referenced in the revised TS are not accident initiating systems; therefore, there will be no impact on any accident probabilities by the approval of this

  • amendment. The design of the systems is not being modified by these proposed changes. Therefore, there will be no impact on any accident consequences. For proposed change
  1. 5, the change is purely administrative; it will therefore have no effect on any accident probabilities or consequences.

Second Standard Implementation of this amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. No new accident causal mechanisms are created as a result of NRC approval of this amendment request. No changes are being made to the plant which will introduce any new accident causal mechanisms.

This amendment request does not impact any plant systems that are accident initiators; neither does it adversely impact any accident mitigating systems.

Third Standard Implementation of this amendment would not involve a significant reduction in a margin of safety. Margin of

safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The performance of these fission product barriers will not be impacted'by implementation of this proposed amendment. The systems and equipment referenced in the revised TS for proposed changes #1-4 are already capable.of performing as designed. No safety margins will be impacted. Since proposed change #5 is purely administrative, it will have no effect on any safety margins.

Based upon the preceding discussion, Duke Energy has concluded that the proposed amendment does not involve a significant hazards consideration.

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l ATTACHMENT 5 ENVIRONMENTAL ANALYSIS ,

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EnvironmentM1 Analysis PursuantLto 10 CFR 51.22(b), an evaluation of this license amendment. request has been performed to determine whether or I not it' meets the criteria for categorical exclusion set  ;

forth in 10 CFR 51.22 (c) (9) of.the regulations.

Implementation of this amendment will have no adverse impact upon the Catawba units; neither will it. contribute to any additional quantity or type.of effluent being available for adverse environmental impact or personnel exposure.

It has beenLdetermined there is:

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1. No significant hazards consideration,
2. No significant change in the types, or significant increase in the amounts, of any effluents that may be i released offsite, and
3. No significant increase in individual or cumulative J occupational ~ radiation exposures involved.

-Therefore, this amendment to the Catawba TS meets the criteria of 10 CFR 51.22 (c) (9) for categorical exclusion from ar2 environmental impact statement.

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