Text

Forwards Request for Addl Info Re Proposed Improved Standard TS
	ML20217L049
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	04/28/1998
From:	Berkow H; NRC (Affiliation Not Assigned)
To:	Tuckman M; DUKE POWER CO.
References
	TAC-M95298, TAC-M95299, TAC-M98964, TAC-M98965, NUDOCS 9805040280
	Download: ML20217L049 (50)
	v • d • e

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E

~, APRIL 28,1998 :

' IMM. S. Tuckm n !

Executive Vice President i" Nuclear Generation Department Duke Energy Corporation P. O. Box 1006 Charlotte, NC 28201

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SUBJECT:

CATAWBA AND MCGUIRE NUCLEAR STATIONS - REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED IMPROVED STANDARD t

TECHNICAL SPECIFICATIONS (TAC NOS M95298, M95299, M98964, AND [

M98965) g g

Dear Mr. Tuckman:

[

P By two separate letters dated May 27,1997, Duke Energy Corporation (formally Duke Power [

Company) submitted proposed amendments to revise the Catawba and McGuire Technical e

' Specifications to be consistent with the Improved Standard Technical Specifications (ISTS) :

conveyed by NUREG-1431 (dated April 1995). By letters dated January 16, January 30, i

March 27, and April 15,1998, we issued requests for additional information (RAls). 3

~

E Enclosed please find the fifth installment of our RAI, covering Sections 3.3.1, 3.8, and 3.9. [

Please provide your response within 45 days of receipt of this letter. Contact Frank Rinaldi at [

. (301) 415-1447 or Peter Tam at (301) 415-1451 if you have any questions regarding this RAl.

Sincerely, (original signed by) y b

Herbert N. Berkow'2 Project Directorate ll-Director l Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation .

I Docket Nos. 50-413, 50-414, 50-369 DISTRIBUTION g and 50-370 Docket File OGC PUBLIC ACRS E

Enclosure:

As stated PDil-2 RF FRinaldi LPlisco,Rll COgle,Rll l

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cc w/ encl: See next page PTam JZwolinski CHarbuck,0-13H15 [,'

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DOCUMENT NAME: G:\ CATAWBA \ CAT 95298. RAS f

To receive a copy of this document, indicate in the box: $

"C" = Copy w/o enci "E" = Copy w/enci "N" = No copy *See previous concurrence

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OFFICE PDil-2\PM* PDil-2\LA* l PDil-2/PM* l PDy-Q/p* l $

NAME PTam:cn LBerry FRinaldi H8erlMw> L DATE 04/28/98 04/28/98 04/28/98 04/28/98 5 OFFICIAL RECORD COPY E 9905040200 900428

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., APRIL 28, 1998 Mr. M. S. Tuckm:n Executive Vice President Nuclear Generation Department Duke Energy Corporation P. O. Box 1006 Charlotte, NC 28201

SUBJECT:

CATAWBA AND MCGUIRE NUCLEAR STATIONS - REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M95298, M95299, M98964, AND M98965)

Dear Mr. Tuckman:

By two separate letters dated May 27,1997, Duke Energy Corporation (formally Duke Power Company) submitted proposed amendments to revise the Catawba and McGuire Technical Specifications to be consistent with the improved Standard Technical Specifications (ISTS) conveyed by NUREG-1431 (dated April 1995). By letters dated January 16, January 30, March 27, and April 15,1998, we issued requests for additionalinformation (RAls).

Enclosed please find the fifth installment of our RAI, covering Sections 3.3.1,3.8, and 3.9.

Please provide your response within 45 days of receipt of this letter. Contact Frank Rinaldi at (301) 415-1447 or Peter Tam at (301) 415-1451 if you have any questions regarding this RAl.

Sincerely, (original signed by)

Director Herbert N. Berkow'2 Project Directorate ll-Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-413,50-414,50-369 DISTRIBUTION and 50-370 Docket File OGC PUBLIC ACRS

Enclosure:

As stated PDll-2 RF LPlisco,Rll FRinaldi COgle,Rll cc w/ encl: See next page PTam CHarbuck,0-13H15 JZwolinski DOCUMENT NAME: G:\ CATAWBA \ CAT 95298. RAS To receive a copy of this document, indicate in the box:

"C" = Copy w/o enci "E" = Copy w/enci "N" = No copy *See previous concurrence l OFFICE PDil-2\PM* l PDil-2\LA* l PDil-2/PM* l PDy-Q/D*

lNAME PTam:en LBerry FRinaldi HBeriMw>

[DATE 04/28/98 04/28/98 04/28/98 04/28/98 OFFICIAL RECORD COPY i

j@st?u g '4 UNITED 3T/TES l g Ij NUCLEAR REGULA "'sY COMMISSION WASHINGTON, D.C. 20066 4001

\.....[E April 28, 1998 Mr. M. S. Tuckman i

Executive Vice President I Nuclear Generation Department Duke Energy Corporation P. O. Box 1006 i Charlotte, NC 28201

SUBJECT:

CATAWBA AND MCGUIRE NUCLEAR STATIONS - REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED IMPROVED STANDARD TECHNICAL SPECIFICATIONS (TAC NOS. M95298, M95299, M98964, AND l M98965)

Dear Mr. Tuckman:

i l By two separate letters dated May 27,1997, Duke Energy Corporation (formally Duke Power

Company) submitted proposed amendments to revise the Catawba and McGuire Technica!

l Specifications to be consistent with the improved Standard Technical Specifications (ISTS) conveyed by NUREG-1431 (dated April 1995). By letters dated January 16, January 30, March 27, and April 15,1998, we issued requests for additional information (RAls).

Enclosed please find the fifth installment of our RAI, covering Sections 3.3.1,3.8, and 3.9.

l Please provide your response within 45 days of receipt of this letter. Contact Frank Rinaldi at (301) 415-1447 or Peter Tam at (301) 415-1451 if you have any questions regarding this RAl.

Sincerely, e rt N. Berkow, Director Project Directorate 11-2 Division of Reactor Projects - 1/11 l Office of Nuclear Reactor Regulation l

! Docket Nos. 50-413, 50-414, 50-369 l and 50-370 l

Enclosure:

As stated cc w/ encl: See next page f

l

McGuire Nuclear Station Catawba Nuclear Station cc:

Mr. Paul R. Newton Mr. Richard M. Fry, Director Legal Department (PBOSE) Division of Radiation Protection Duke Energy Corporation North Carolina Department of 422 South Church Street Environment, Health, and l Charlotte, North Carolina 28242-0001 Natural Resources

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3825 Barrett Drive i County Manager of Mecklenburg County Raleigh, North Carolina 27609-7721 720 East Fourth Street Charlotte, North Carolina 28202 Ms. Karen E. Long Assistant Attomey General Mr. Michael T. Cash North Carolina Department of Regulatory Compliance Manager Justice Duke Energy Corporation P. O. Box 629 McGuire Nuclear Site Raleigh, North Carolina 27602 12700 Hagers Ferry Road Huntersville, North Carolina 28078 L. A. Keller ;

Manager - Nuclear Regulatory l J. Michael McGarry, lli, Esquire Licensing l

Winston and Strawn Duke Energy Corporation i 1400 L Street, NW. 526 South Church Street Washington, DC 20005 Charlotte, North Carolina 28242-0001 Senior Resident inspector Regional Administrator, Region ll clo U. S. Nuclear Regulatory U.S. Nuclear Regulatory Commission l

Commission Atlanta Federal Center i 12700 Hagers Ferry Road 61 Forsyth Street, S.W., Suite 23T85 Huntersville, North Carolina 28078 Atlanta, Georgia 30303 Mr. Peter R. Harden, IV Elaine Wathen Account Sales Manager Lead REP Planner Westinghouse Electric Corporation Division of Emergency Management Power Systems Field Sales 116 West Jones Street P. O. Box 7288 Raleigh, North Carolina 27603-1335 Charlotte, North Carolina 28241 Mr. T. Richard Puryear Dr. John M. Barry Owners Group (NCEMC)

Mecklenburg County Duke Energy Corporation Department of Environmental 4800 Concord Road Protection York, South Carolina 29745 700 N. Tryon Street j Charlotte, North Carolina 28202 i

I

)

l McGuire Nuclear Station -

Catawba Nuclear Station cc:

l Mr. M. S. Kitlan . North Carolina Electric Membership l

Regulatory Compliance Manager Corporation Duke Energy Corporation P. O. Box 27306

4800 Concord Road Raleigh, North Carolina 27611 L York, South Carolina 29745 Senior Resident inspector North Carolina Municipal Power 4830 Concord Road Agency Number 1 York, South Carolina 29745 1427 Meadowwood Boulevard P. O. Box 29513 Mr. G. R. Peterson i Raleigh, North Carolina 27626-0513 Site Vice President l

Catawba Nuclear Station I County Manager of York County Duke Energy Corporation York County Courthouse 4800 Concord Road York, South Carolina 29745 York, South Carolina 29745 l Piedmont Municipal Power Agency Mr. H. B. Barron 121 Village Drive Vice President, McGuire Site Greer, South Carolina 29651 Duke Energy Corporation 12700 Hagers Ferry Road Saluda River Electric - Huntersville, North Carolina 28078 P. O. Box 929 Laurens, South Carolina 29360 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201

McGuire & Catawba improved TS Review Comments ITS 3.3.1, Reactor Trip System (RTS) Instrumentation 3.3.1-01 CTS Table 3.31, Action 2.c ITS LCO 3.3.1, Condition D, Required Action D.1.2 DOC L.1 CTS Table 3.3-1, Action 2.c specifies reduction of thermal power to less than or equal to 75% within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS LCO 3.3.1, Condition D, Required Action D.1.2 also specifies j reduction of power to 75%, but the Completion Time is specified as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . DOC L.1 1 does not address this less restrictive change. Comment: Provide justification for this less {

restrictive change. I DEC Response:

3.3.1-02 ITS Table 3.3.1-1, Function 2.b CTS Table 4.3-1, Functional Unit 2, Low Setpoint DOC LA.3 JFD 5 -

ITS Table 3.3.1-1, Function 2. b requires SR 3.3.1.11 to be performed, which includes l Note 2 that excludes detector voltage plateau verification prior to entry to Modes 1 or 2.

CTS Table 4.3-1, Functional Unit 2, Low Setpoint, specifies Channel Calibration, but does '

not include this exclusion, which was CTS Table Note (5). Comment: Revise the submittal to correct this discrepancy.

DEC Response: l 3.3.1-03 CTS Table 3.3-1, Action Statement 3.b for Functional Unit 4, intermediate range, neutron flux ITS 3.3.1 Required Actions F.1 and F.2 DOC L.2 I

CTS Table 3.3-1, Action 3.b for Functional Unit 4, requires an inoperable channel to be restored prior to increasing power above 10%. Actions F.1 and F.2 for corresponding ITS 3.3.1 require power to be adjusted to either below P-6, the intermediate range neutron flux interlock, or above P-10, the power range neutron flux interlock, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . DOC L.2 does not describe the proposed change's impact on safety and explain why the safety impact is acceptable. Comment: Revise the submittal (DOC L.2) to strengthen the justification for the proposed change.

DEC Response:

MC2_CR_3.301 1 April 24,1998 Enclosure

McGuire & Catawba improved TS Review Comments ITS 3.3.1, Reactor Trip System (RTS) Instrumentation 9

3.3.1-04 CTS Table 4.31, Functional Unit 5 (Catawba only] ITS Table 3.3.1-1, Function 5 JFD 7

)

CTS Table 4.3-1, Functional Unit 5 includes only one line item entry, to show which surveillances are required during each mode of operation. Corresponding ITS Table 3.3.1-1, function 5 for Catawba has 2 separate line items to show the surveillance requirements for various modes of operation. In converting from CTS to ITS line 3 referencing the RTBs has been deleted without proper justification. Comment: Revise' the ITS to include this portion of the deletion in order to correct this discrepancy.

DEC Rasponse:

3.3.1-05 STS Table 3.3.1-1, Function 5

[McGuire only] ITS Table 3.3.1-1, Function 5 CTS Table 4.3-1, Functional Unit 5 STS Table 3.3.1-1, Function 5, in the second line for Modes 3,4 and 5 applicability 1 includes footnote (f), With the RTBs open.........." This footnote has been adopted in ITS Table 3.3.1-1, Function 5, as footnote (e). Corresponding CTS Table 4.3-1, Functional Unit 5 does not include this provision. No justification for tiiis change has been provided. :

This change is a more restrictive change because the CTS did not contain this exception. I Comment: Revise the submittal to provide the appropriate justification for the proposed change.

l DEC Response:

i 3.3.1-06 ITS SR 3.3.1.12 STS SR 3.3.1.12 JFD 7 i

ITS SR 3.3.1.12 has not adopted the Note contained in STS SR 3.3.1.12. JFD 7 states that surveillance requirements have been deleted as not applicable to this station.

)

Comment: Provide specific technical justification why the Note in STS SR 3.3.1.12 is not '

applicable to either McGuire or Catawba.

DEC Response:

MC2_CR_3.301 2 April 24,1998 i

l McGuire & Catawba improved TS Review Comments ITS 3.3.1, Reactor Trip System (RTS) Instrumentation 3.3.1-08 CTS Table 4.3-1, Functional Unit 6

[ Catawba only) CTS Table 4.3-1, Functional Unit 7 ITS SR 3.3.10 Catawba CTS Table 4.3-1, Functional Unit 6 markup specifies SR 3.3.1.10 for Channel l Calibration. The Note for ITS SR 3.3.10, states, "This surveillance shall include l verification that the time constants are adjusted to the prescribed values," which is a l change relative to the CTS. No justification has been provided for this change. Comment:

Revise the submittal to provide justification for the change.

DEC Response:

l 3.3.1-09 STS Table 3.3.1-1, Function 18.b ITS Table 3.3.1-1, Function 16.b JFD 5 Surveillance requirements of the STS for Function 18.b, SR 3.3.1.11 and SR 3.3.1.13 i l have not been adopted in corresponding ITS 3.3.1, Function 16.b. JFD 5 explains that l

this change reflects current licensing basis / technical specification but offers no further technical explanation as to why this SR is not required. Comment: Explain why no surveillances are required for this function.

DEC Response:

3.3.1.10 CTS Table 4.3-1, Functional Unit 17

[ Catawba only] ITS Table 3.3.1-1, Function 16.b STS Table 3.3.1-1, Function 18.b l STS Table 3.3.1-1, Functional Unit 18.b provides requirements for the low power reactor trips block, P.7. These requirements have been adopted in corresponding ITS Table 3.3.1-1, Function 16.b. This material could not be found in the CTS markup. No justification has been provided for this change. Comment: Revise the CTS markup to correct this discrepancy and provide the appropriate justification..

l DEC Response:

I M C2_CR_3.301 3 April 24,1998 l

l

McGuire & Catawba improved TS Review Comments ITS 3.3.1, Reactor Trip System (RTS) Instrumentation i

3.3.1.11 CTS Tablo 4.3-1, Functional Unit 17

[McGuire only] ITS Table 3.3.1-1, Function 16.b STS Table 3.3.1-1, Function 18.b DOC A.1 l STS Table 3.3.1-1, Functional Unit 18.b provides requirements for the low power reactor trips block, P.7. These requirements have been adopted in corresponding ITS Table 3.3.1-1, Function 16.b. DOC A.1 does not explain why the proposed change is administrative and not more restrictive. Comment: ProGe the appropriate justification for this proposed change.

DEC Response:

3.3.1-12 CTS Table 4.3-1, Functional Unit 17.f [ Catawba only]

CTS Table 4.3-1, Functional Unit 17.d [McGuire only)

STS Table 3.3.1-1, Function 18.e ITS Table 3.3.1-1, Function 16.f [ Catawba only]

ITS Table 3.3.1-1, Function 16.e [McGuire only]

STS Table 3.3.1-1 Function 18.e has SR 3.3.1.10 as channel calibration surveillance requirement which includes a ncte that specifies the verification of time constants. ITS Table 3.3.1 1 function 16.e/f surveillance requirements have been changed to SR 3.3.1.12 with no discussion of change. This revised SR does not include note as to the verification of time constants. Comment: Provide the appropriate justification for this proposed change.

DEC Response:

3.3.1 13 CTS Table 2.2-1, Note 2

[McGuire only] ITS Table 3.3.1-1, Note 2 CTS Table 2.2-1, Note 2 specifies, "AT = As defined in Note 1." Note 1 states, "AT

= Measured AT by Loop Narrow Range RTD." STS and ITS Table 3.3.1-1, Note 2 states, "AT is measured RCS AT , 'F." Comment: No justification has been provided for not retaining the words 'by Loop Narrow Range RTD'. Revise the submittal to provide the justification for the proposed change.

l DEC Response:

l r

MC2_CR ,.3.301 4 April 24,1998 l

! McGuire & Catawba improved TS Review Comments ITS 3.3.1, Reactor Trip System (RTS) instrumentation i I' 3.3.1-14 ITS Bases Background, Page B 3.3-3 STS Bases Background, Page B 3.3-3 The title of the second paragraph in the STS Bases Background is " Signal Process Control and Protection System" which has been changed to " Process Monitoring System" in the ITS. The paragraph that follows in the ITS describes process control equipment rather ,

than process monitoring equipment. Comment: Revise the bases to correct the 1 discrepancy.

l DEC Response: -

1 3.3.1-15 Bases for ITS 3.3.1 Required Actions U.1, and U.2

[McGuire only] ITS 3.3.1 Conditions Q and R The Bases markup for ITS 3.3.1 Required Actions U.1, and U.2 states ".......the reactor trip breaker is inoperable and Condition Q is entered." Condition Q does not apply to the reactor trip breakers; Condition R applies to the reactor trip breakers. Comment: Revise the Bases to refer to Condition R.

DEC Response:

l k

i MC2_CR_3.301 5 April 24,1998 i

1

i McGuire & Cetawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, AC Sources - Operating 3.8.1-01 Not used 3.8.1-02 DOC LA.12 j CTS 3/4.8.1.1 Action c.2 l

With one DG inoperable in Modes 1, 2, or 3 with steam pressure greater than 900 psig,

{

CTS 3/4.8.1.1 Action c.2 requires verifying that the steam-driven auxiliary feedwater pump :

is Operable within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This requirement has not been retained in corresponding ITS ;

3.8.1, but instead is being placed in the Bases. Comment: This material could not be found in the Bases for ITS 3.8.1 Required Actions D.1 through B.4. Neither could it be found in the Bases for ITS 3.7.5. Revise the Bases for ITS 3.8.1 and ITS 3.7.5 to include this !

material.

l DEC Response:

3.8.1-03 Bases JFD 4 Catawba only CTS 3/4.8.1.1 Action b.2 footnote

CTS 3/4.8.1.1 Action d.2 footnote

Footnote

to CTS 3/4.8.1.1 Actions b.2 and d.2 provides exceptions to DG testing requirements. DOC LA 28 states that this material has not been retained in corresponding ITS 3.8.1, but instead has been placed in the Bases. This material could not be found in the Bases. Comment: Resolve this discrepancy by revising the Bases to include this material.

DEC Response:

l l

3.8.1 04 ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 i Bases for ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 STS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 refer to an (engine mounted tankl. This has not l been adopted in corresponding ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6. Comment: Confirm

- that the fuel system for the DGs does not include an engine mounted tank.

DEC Response:

MC2_CR_3.8 1 April 23,1998

McGuire & Cetawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-05 DOC A.11 McGuire only ITS SR 3.8.1.2 Note 3 CTS 4.8.1.1.2.a(4)

A Note has been added to CTS 4.8.1.1.2.a(4) as Note 3 to ITS SR 3.8.1.2. The Note states, "A modified DG start involving [ idling and] gradual acceleration....." The term

" idling and" is included in the CTS markup but has been deleted in the STS markup and does not appear in the " clean"ITS version. Comment: Revise the submittal to resolve this discrepancy.

DEC Response:

3.8.1-06 JFD 4 McGuire only Bases for ITS SR 3.8.1.2 and 3.8.1.7, STS Bases markup insert page B 3.8-17 An insert has been added to the Bases for STS SR 3.8.1.2 and 3.8.1.7 as the Bases for ITS SR 3.8.1.2 and 3.8.1.7. The insert states, "If the DG is otherwise fully Operable, the performance of the slow start procedure should not necessitate the performance of SR 3.8.1.1......." JFD 4 does not provide a specific technical justification for the proposed difference. Comment: Revise the submittal to provide the appropriate justification for the proposed difference or delete the proposed insert.

DEC Response: l l

1 3.8.1-07 Bases for ITS SR 3.8.1.3, STS Bases markup page B 3.8-18, second paragraph The Bases for STS SR 3.8.1.3 states, ".... the [1.0) is an operational limitation [to ensure circulating currents are minimized)." The Bases for corresponding ITS SR 3.8.1.3 has not adopted the bracketed phrase "[to ensure circulating currents are minimized)" and no additional material has been proposed to take its place. Comment: Revise the submittal to provide the basis for the 1.0 power factor.

DEC Response:

MC2_CR_3.8 2 April 23,1998 l

e McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1 08 DOC A.12 (McGuire)

DOC A.17 (Catawba) '

ITS SR 3.8.1.11 Note 1 CTS 4,8.1.1.2.e.4 (McGuire)

CTS 4.8.1.1.2.g.4 (Catawba)

Note 1 to ITS SR 3.8.1.11 states that all DG starts may be preceded by an engine prelube period. The Note represents a proposed change relative to CTS 4.8.1.1.2.e.4 for McGuire and CTS 4.8.1.1.2.g.4 for Catawba. The proposed change has been categorized as administrative. Comment: The proposed change is less restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.1-09 DOC A.1 ITS SR 3.8.1.11 item c CTS 4.8.1.1.2.e.4.b STS SR 3.8.1.11 item c requires that the DG auto-starts from standby condition. This requirement has been adopted in corresponding ITS SR 3.8.1.11 item c and is a change relative to CTS 4.8.1.1.2.e.4.b. DOC A.1 does not explain why the proposed change is administrative. Comment: Revise the submittal to provide the appropriate justification.

DEC Response:

l l 3.8.1-10 ITS SR 3.8.1.12 McGuire CTS 4.8.1.1.2.e.5)

Catawba CTS 4.8.1.1.2.g.5) l CTS require the DG to start on the auto-start signal and operate on standby.

l Corresponding ITS SR 3.8.1.12 requires each DG to auto-start from standby condition.

Comment: No justification has been provided for the proposed change. Revise the submittal to provide the appropriate justification.

j DEC Response:

i l

1 l

I MC2_CR_3.8 3 April 23,1998

l McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-11 DOC A.12 l ITS SR 3.8.1.12 Note 1 l

CTS 4.8.1.1.2.e.5 Note *: to ITS SR 3.8.1.12 states that all DG starts may be preceded by an engine prelube period. The Note represents a proposed change relative to CTS 4.8.1.1.2.e.5. The

' proposed change has been categorized as administrative. Comment: The proposed change is less restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.1-12 Bases JFD 4 Bases for ITS SR 3.8.1.11, STS Bases markup insert page B 3.8-23 An insert has been added to the Bases for STS SR 3.8.1.11 as the Bases for corresponding ITS SR 3.8.1.11. The insert states that as test instrumentation is improved, short duration spikes of voltage, of less than a second, could possibly be detected above the stated limit of 4784 volts. These momentary spikes should not invalidate this test. Comment: No

technical justification has been provided for the proposed difference. Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.1-13 Bases JFD 1 McGuire only Bases for ITS SRs 3.8'.1.12 and 3.8.1.13 The Bases for STS SRs 3.8.1.12 and 3.8.1.13 state that operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency.

Therefore the Frequency was concluded to be acceptable from a reliability standpoint. This material has not been adopted in the Bases for corresponding ITS SRs 3.8.1.12 and 3.8.1.13. Bases JFD 1 does not provide a specific justification for this proposed difference. Comment: Revise the submittal to provide the appropriate justification. If the components have not usually passed the SR when performed at the 18 month Frequency, provide additional justification for maintaining that Frequency. l I

DEC Response:

i l

MC2_CR_3.8 4 April 23,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-14 DOC A.12 (McGuire)

CTS 4.8.1.1.2.e.8 (McGuire)

DOC A.17 (Catawba)

CTS 4.8.1.1.2.g.15 (Catawba)

ITS SR 3.8.1.15 Note 2 Note 2 to ITS SR 3.8.1.15 states that all DG starts may be preceded by an engine prelube period. The Note represents a proposed change relative to CTS 4.8.1.1.2.e.8 for McGuire and CTS 4.8.1.1.2.g.15 for Catawba. The proposed change has been categorized as administrative. Comment: The proposed change is less restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.1-15 CTS 4.8.1.1.2.e.8 footnote ##

McGuire only ITS SR 3.8.1.15 Footnote ## to CTS 4.8.1.1.2.e.8 states that if the hot restart is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead, the DG may be operated at 3600 - 4000 kw for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The CTS markup indicates that this material is being retained as a Note to corresponding ITS SR 3.8.1.15. This material could not be found in the markup of STS SR 3.8.1.15 nor in the " clean version of ITS SR 3.8.1.15.

Comment: Revise the submittal to resolve this discrepancy.

DEC Response:

3.8.1-16 DOC A.12 (McGuire)

CTS 4.8.1.1.2.f (McGuire)

DOC A.17 (Catawba)

CTS 4.8.1.1.2.h (Catawba)

ITS SR 3.8.1.20 Note 1 Note 1 to ITS SR 3.8.1.20 states that all DG starts may be preceded by an engine prelube period. The Note represents a proposed change relative to CTS 4.8.1.1.2.f for McGuire and CTS 4.8.1.1.2.h for Catawba. The proposed change has been categorized as administrative. Comment: The proposed change is less restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

l M C2 ,C R,_3.8 5 April 23,1998 1

i McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-17 DOC L.20 ITS SR 3.8.1.20 CTS 4.8.1.1.2.f (McGuire)

CTS 4.8.1.1.2.h (Catawba)

CTS 4.8.1.1.2.f for McGuire and CTS 4.8.1.1.2.h for Catawba require that the simultaneous starting of both DGs be performed during shutdown. This requirement has not been retained in corresponding ITS SR 3.8.1.20. DOC L.20 states that the proposed change is acceptable because of the independence of the DGs. Comment: The purpose of the SR is to demonstrate the independent starting capability. Revise the submittal to provide additional justification for the proposed change.

DEC Response:

3.8.1-18 Not used I

3.8.1-19 DOC A.12 (McGuire)

CTS 4.8.1.1.2.e.6 (McGuire)

DOC A.17 (Catawba)

CTS 4.8.1.1.2.g.6 (Catawoa)

ITS SR 3.8.1.19 Nota 1 Note 1 to ITS SR 3.8.1.19 states that all DG starts map be preceded by an engine prelube period. The Note represents a proposed change relative to CTS 4.8.1.1.2.e.6 for McGuire and CTS 4.8.1.1.2.g.6 for Catawba. The proposed change has been categorized as administrative. Comment: The proposed change is less restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

MC 2_CR_3.8 6 April 23,1998 l

1 L

e ,

l-L McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems

! 3.8.1-20 JFD 4 McGuire only ITS SR 3.8.1.16 item c Bases for ITS SR 3.8.1.16 STS SR 3.8.1.16 item c refers to " ready to load" operation. This terminology has not been adopted in corresponding ITS SR 3.8.1.16 item c for McGuire and Catawba. For Catawba and McGuire, the words " standby status" and " standby operation," respectively, are used l

instead of " ready to load" operation. The Bases for McGuire ITS SR 3.8.1.16 refers to

" ready to load" and does not refer to " standby". (Catawba is consistent in using

" standby.") Comment: There is' an apparent discrepancy between ITS SR 3.8.1.16 and its l

' Bases discussion for McGuire Revise the submittal to resolve the apparent discrepancy, or explain why no changes are needed, in addition, the SR wording for both sites ought to be consistent. It is noted that the proposed wording is consistent with the CTS, which is inconsistent between the sites.

DEC Response:

3.8.1-21 Bases JFD 3

Catawba only Bases discussion for ITS 3.8.1 SRs, STS Bases markup l page B 3.8-16

! The introductory material at the beginning of the Bases discussion for the SRs for STS l 3.8.1 addresses the maximum steady state output voltage and lightly loaded distribution l systems. This material has not been adopted in the Bases discussion for the SRs for ITS i 3.8.1. Bases JFD 3 states that this material is not applicable to the facility. Comment:

Bases JFD 3 does not explain why this materialis not applicable. Revise the submittal to l explain why the material is not applicable to the facility.

DEC Response:

l I .

1 MC2_CR,3.8 7 April 23,1998 a

r

( McGuire & Catawba improved TS Review Comments l ITS Section 3.8, Electrical Power Systems l 3.8.1-22 DOC L.4 l Catawba only ITS SR 3.8.1.6 CT$ 4.8.1.1.2.a.3 CTS 4.8.1.1.2.a.3 requires verifying that the fuel oil transfer system operates to transfer

! fuel from the storage system to the day tank at least once per 31 days on a Staggered l Test Basis. The Frequency for corresponding ITS SR 3.8.1.6 is 92 days. DOC L.4 states that the 92 day Frequency for testing the valve corresponds to the inservice Testing program requirements. Comment: Confirm that based on operational experience at the facility, CTS 4.8.1.1.2.a.3 is typically passed. Provide a summary of the test results for the past three years.

DEC Response:

l 3.8.1-23 DOC L.1 CTS 4.8.1.1.2.a ITS SRs 3.8.1.2, 3.8.1.3, 3.8.1.4, and 3.8.1.6 The requirements associated with CTS 4.8.1.1.2.a are required to be performed at least once per 31 days on a Staggered Test Basis. The Frequency for corresponding ITS SRs 3.8.1.2, 3.8.1.3, 3.8.1.4, and 3.8.1.6 is 31 days. Comment: DOC L.1 does not describe the proposed change's impact on safety or why the safety impact is acceptable. Revise the submittal to provide the appropriate justification fr.,r the proposed change.

l DEC Response:

3.8.1-24 Catawba DOC M.21 Catawba /McGuire JFD 5 ITS SR 3.8.1.10 Catawba CTS 4.8.1.1.2.g.3)

McGuire CTS 4.8.1.1.2.e.3)

CTS do not specify a power factor limit for the full-load rejection test of an EDG. The corresponding Catawba ITS SR 3.8.1.10 adds such a limit consistent with the STS. The proposed Catawba value of 0.98, however, appears to be too high. Comment: Provide documentation to show why a power factor value at or below 0.9 is not appropriate for Catawba. Also explain why no power factor limit is proposed for McGuire.

DEC Response:

M C2_CR_3.8 8 April 23,1998 l

l

McGuire & Catawba improved TS Review Comments i

ITS Section 3.8, Electrical Power Systems 1 3.8.1 25 JFD 5 Catawba only ITS SR 3.8.1.15 j CTS 4.8.1.1.2.g.15 STS SR 3.8.1.15 ITS SR 3.8.1.15, DG hot restart test, consistent with the CTS, omits upper voltage and frequency limits; such limits, however, are included in the STS. Upper limits are also included in the McGuire ITS, but only as steady state values. Note that corresponding McGuire CTS 4.8.1.1.2.e.8 does not appear to require a steady state limit for the hot restart test. Comment: Revise Catawba ITS SR 3.8.1.15 to be consistent with the ITS for McGuire by requiring steady state upper and lower limits on voltage and frequency.

DEC Response:

3.8.1-26 DOC LA.9 Catawba CTS 4.8.1.1.2.g.12 Catawba CTS 4.8.1.1.2.g.13 McGuire CTS 4.8.1.1.2.e.13 l

l CTS Table 4.8-2 i

ITS SR 3.8.1.18 STS SR 3.8.1.18 ITS SR 3.8.1.18 differs from the STS by omitting a value for the interval tolerance for each sequencer load block. CTS specify a unique tolerance for each of the fourteen intervals for Catawba and the eleven intervals for McGuire. STS 3.8.1.18 includes the interval tolerance in brackets, which means that the ITS should contain plant specific information.

, DOC LA.9 is incorrect in stating that removal of this information from the TS is consistent with the STS. Comment: Revise ITS SR 3.8.1.18 to include the informa'. ion contained in CTS Table 4.8-2; and also for Catawba, the information contained in Catawba CTS 4.8.1.1.2.g.13.

DEC Response:

l I

MC2_CR_3.8 9 April 23,1998 l

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-27 DOC LA.10 Catawba CTS 4.8.1.1.2.h McGuire CTS 4.8.1.1.2.f ITS omit the CTS requirement for a simultaneous start test of the DGs following any modification which could affect DG interdependence. DOC LA.10 states this requirement is adequately addressed by station administrative procedures. Control of changes to such procedures, however, are not governed by a specific regulation such as 10 CFR 50.59.

Comment: Either revise DOC LA.10 with an L-type DOC to justify deletion of this test requirement, or revise DOC LA.10 to explain the requirement is moved to a document such l as the FSAR or the SLC manual, for which 10 CFR 50.59 governs changes. Response to I this comment should include a global review of all LA-type changes to ensure that any requirement being removed because it is adequately covered in plant procedures is characterized as being deleted and justified with an L-type change. Alternatively, such LA-type DOCS may be revised to state the document the requirement is moved to and the I regulation governing changes to it.

l DEC Response:

1 3.8.2. AC Sources - Shutdown 3.8.2-01 JFD 6 l

ITS SR 3.8.2.1 ITS SRs 3.8.12 and 3.8.1.19 l DOC L.21 l

CTS 4.8.1.2 j Bases JFD 5 ;

i Bases for ITS SR 3.8.2.1, STS Bases markup insert page B 3.8-40 l STS SR 3.8.2.1 requires the performance of STS SRs 3.8.1.12 and 3.8.1.19 which require verifying DG auto-starts on an actual or simulated ESF signal. These requirements have not been adopted in corresponding ITS SR 3.8.2.1. JFD 6 states that ESF signals are not l_ required to be Operable in Modes 5 and 6, and that ITS SRs 3.8.1.12 and 3.8.1.19 should not be required to be performed in those modes. Comment: ITS 3.8.2.1 is applicable in i l Modes 5 and 6, and during movement of irradiated fuel assemblies. JFD 6 does not, I however, address during movement of irradiated fuel assemblies. Revise JFD 6 to explain why DG auto-starts on an actual or simulated ESF signal are unnecessary during movement of irradiated fuel assemblies; otherwise, conform to the STS.

DEC Response:

MC2_CR_3.8 10 April 23,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.2-02 Not used l

l 3.8.2-03 Not used 3.8.2-04 DOC A.25 McGuire only CTS 3/4.8.1.2 Action ITS 3.8.10 Condition A and Required Action A.2.5 ITS 3.4.12 Required Action G.1 In the event that either an offsite circuit or a DG is inoperable, CTS 3/4.8.1.2 Action requires depressurizing and venting the RCS through a greater than or equal to 4.5 square i

inch vent. In the event that one or more electrical power distribution subsystems are inoperabie. ITS 3.8.10 Required Action A.2.5 requires declaring the affected LTOP features inoperable. ITS 3.4.12 Required Action G.1 requires establishing a 2.75 square inch vent.

The proposed change has been categorized as administrative. Comment: The proposed l change appears to be less restrictive because the specified vent size is reduced. Revise the submittal to provide the appropriate justification for the proposed change.

l DEC Response:

l 3.8.2-05 DOC A.62 CTS 3/4.8.1.2 Action iTS 3.8.2 Required Actions A.2.4 and B.4 l

, CTS 3/4.8.1.2 Action and ITS 3.8.2 Required Actions A.2.4 and B.4 all require immediately l initiating action to restore required AC sources to Operable status. The CTS 3/4.8.1.2 l Action is applicable when in Mode 5 with the reactor coolant loops not filled, or in Mode 6 with the water level less than 23 feet above the reactor vessel flange. Corresponding Required Actions A.2.4 and B.4 of ITS 3.8.2 are applicable in Modes 5 and 6, and during l

movement of irradiated fuel. The proposed change has been categorized as administrative.

Comment: The proposed change appears to be more restrictive because the Applicability of the action requirements is increased. Revise the submittal to provide the appropriate justification for the proposed change.

DEC Response:

3.8.2-06 Not used MC2_CR_3.8 11 April 23,1998 i

l McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3. Diesel Fuel Oil and Starting Air 3.8.3-01 DOC L.11 McGuire only CTS 4.8.1.1.2.e.15 footnote # 1 ITS SR 3.8.3.3 l l

McGuire CTS 4.8.1.1.2.e.15 footnote # provides an allowance for performing the surveillance during preplanned preventive maintenance. This material has not been retained in corresponding ITS SR 3.8.3.3. Comment: DOC L.11 does not specifically address the proposed change. Revise the submittal to provide the appropriate justification for the proposed change.

DEC Response:

3.8.3-02 JFD 14 McGuire only STS LCO 3.0.3 STS 3.8.3 Condition B STS SR 3.8.3.2 ITS 3.8.3 STS LCO 3.8.3, STS 3.8.3 Condition B, and STS SR 3.8.3.2 all address DG lube oil l requirements. None of these requirements have been adopted in corresponding McGuire iTS 3.8.3. JFD 14 states that the requirement is directed at DGs that consume lube oil during operation, and that no significant consumption of lube oil has been noted during required 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months testing. Comment: What is the typical lube oil inventory kept on site at McGuire? Based on past operating experience, how much lube oil would be expected to be ]

consumed by a continuous five day run of a single DG7 Compare lube oil consumption !

l between McGuire and Catawba DGs. It is noted that neither McGuire nor Catawba CTS

! contain explicit DG lube oil requirements.

DEC Response:

l I

l

)

1 MC2_CR_3.8 12 April 23,1998 L

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-03 Bases JFD 4 McGuire only Bases for ITS SR 3.8.3.2, STS Bases markup page B 3.8-46 Bases for STS SR 3.8.3.3 The Bases for STS SR 3.8.3.3 states that in no case is the time between receipt of the new fuel and conducting the tests to exceed 31 days. This has not been adopted in the Bases for corresponding ITS SR 3.8.3.2. Bases JFD 4 states that changes have been made to reflect the facility specific nomenclature, number, reference, system description, or analysis description. Corr. ment- TNr is not a justifiable plant specific difference. Revise the Bases to conform to the Sh.

DEC Response:

3.8.3-04 Bases JFD 4 McGuire only Bases for ITS SR 3.8.3.2, STS Bases markup page B 3.8-47 Material has been added to the Bases for ITS SR 3.8.3.2 that describes testing for particulate concentrations. The new material states that the test described in the standard

[ ASTM D2276 (78)] is for jet fuel, and it is therefore permissible to determine particulate concentrations using a 3 micron filter instead of the 0.8 micron required by the standard.

Bases JFD 4 states that changes have been made to reflect the facility specific nomenclature, number, reference, system description, or analysis description. Comment:

Bases JFD 4 does not explain why the proposed difference is acceptable. Revise the submittal to provide the appropriate justification for the proposed difference or conform to the STS.

l DEC Response:

)

i

, MC2_CR_3.8 13 April 23,1998 i

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McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-05 Bases JFD 1 l McGuire only Bases for ITS SR 3.8.3.3, STS Bases markup page B 3.8-48 f-The Bases for STS SR 3.8.3.4 states, "[A start cycle is defined by the DG vendor but

usually is measured in terms of time (seconds of cranking) or engine cranking speed.]" The Bases for corresponding ITS SR 3.8.3.3 states, "A start cycle is defined as the period of i time required to reach 95% speed from standby prelube condition." Bases JFD 1 states I

that the brackets have been removed and the proper plant specific information or value has been provided. Comment: Bases JFD 1 does not explain why the proposed difference is

, acceptable. Confirm that the proposed difference reflects the DG vendor's definition ~of ~a i start cycle, or provide the appropriate justification for the proposed difference. j DEC Response:

3.8.3-06 DOC L.7 l- Catawba only ITS 3.8.3 Action B i

l ITS 3.8.3 Action B addresses the Condition of one or more DGs with lube oilinventory <

j 600 gal and > 570 gal. DOC L.7 states that these are new requirements but that they are j

.less restrictive relative to the 7 day inventory requirement of the UFSAR. Comment: The proposed change is more restrictive relative to the CTS. Revise the submittal to provide the appropriate justification for the proposed changes.

DEC Response:

{

3.8.3-07 DOC L.9 Catawba only - ITS 3.8.3 Condition E and Required Action E.1 ITS 3.8.3 Action E addresses the Condition of one or more DGs with starting air receiver pressure < 210 psig and 2150 psig. DOC L.9 states that these are new requirements but i that they are less restrictive relative to the requirements of the UFSAR. Comment: The l proposed change is more restrictive relative to the CTS. Revise the submittal to provide l the appropriate justification for the proposed changes. l l

DEC Response:

3.8.3-08 Not used I

i MC2_CR_3.8 14 April 23,1998 I

h I

i I

f McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-09 ITS 3.8.3 Condition B Catawba only Bases for ITS 3.8.3 Required Action B.1 l

ITS 3.8.3 Condition B addresses one or more DGs with lube oilinventory < 600 gal and

> 570 gal. The Bases for ITS 3.8.3 Required Action B.1 states that the Condition is restricted to lube oil volume reductions that maintain at least a 6 day supply. Comment:

Provide the technical basis or reference for 570 gal supporting at least 6 days of full load operation for each DG.

l DEC Response:

3.8.3-10 ITS 3.8.3 Condition C Catawba only ITS SR 3.8.3.4 iTS 3.8.3 Condition C and ITS SR 3.8.3.4 refer to DG starting air receiver pressures of 210 and 150 psig. Comment: Provide the technical basis or reference for these values.

DEC Response:

L i

3.8.3-11 DOC A.22 McGuire cnly McGuire CTS 3.8.1.1.b.2 McGuire CTS 3.8.1.2.b.2 Catawba CTS 3.8.1.1.b.2 l Catawba CTS 3.8.1.2.b.2 ITS SR 3.8.3.1 !

1 CTS for McGuire and Catawba require an Operable DG to have its own fuel storage system containing a minimum volume of 28,000 and 77,100 gallons of fuel, respectively. i l

Corresponding requirement ITS SR 3.8.3.1 requires verifying that each fuel oil storage tank l contains 39,500 and 77,100 gallons of fuel, respectively. DOC A.22 does not specifically address the change in specified fuel oil volume for McGuire. Comment: The proposed change appears to be more restrictive. Revise the submittal to provide the appropriate justification.

DEC Response:

I i

MC2_CR_3.8 15 April 23,1998

o l

l l

McGuire & Catawba improved TS Review Comments l ITS Section 3.8, Electrical Power Systems 3.8.4, DC Sources - Operating i

3.8.4-01 DOC LA.18 CTS 3.8.2.1.a thru d i

CTS 3.8.2.1.a thru d address the required DC buses, battery banks, and full capacity j

! chargers. DOC LA.18 states that this information has been placed in the Bases for ITS j

3.8.9. The DC buses and battery banks are addressed in Bases Table 3.8.9-1. Comment

l The full capacity chargers are not addressed in this table. Revise the Bases table to include j the full capacity chargers, i DEC Response:

3.8.4-02 DOC A.45 DOC A.65 CTS 3.8.2.1.a through d footnote

CTS 3.8.3.1.g through j footnote * (see markup for ITS 3.8.7) l l Footnote

for CTS 3.8.2.1.a through d provides an allowance to disconnect a vital bus !

from its DC source. DOC A,45 states that a portion of the footnote is redundant to a

! similar footnote in CTS 3.8.3.1, which allows an inverter to be disconnected, and that only the footnote associated with the inverter is needed in the ITS. However, footnote

for CTS 3.8.3.1.g through j has not been retained in the ITS. Comment: There is a discrepancy between DOC A.45 and DOC A.65. Catawba JFD 16 states neither note is needed. This conflicts with DOC A.45. Revise DOC A.45 to resolve these discrepancies. ;

Also, see comment 3.8.7-01.

DEC Response:

3.8.4-03 DOC A.54 McGuire only CTS 3.8.2.1.a thru d footnote #

Footnote # for CTS 3.8.2.1.a thru d provides an allowance to utilize a temporary battery l_ during battery bank replacement. This allowance has not been retained in corresponding i ITS 3.8.4. The proposed change has been categorized as administrative. Comment: The proposed change is more restrictive relative to the CTS Revise the submittal to provide the appropriate justification. Also, see comment 3.8.7-02.

DEC Response:

M C2_CR_3.8 16 April 23,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.4-04 DOC A.64 McGuire only CTS 4.8.2.1.2.d.2)

CTS 4.8.2.1.2.d.2) provides an optional test method for verifying that the battery capacity is adequate. This optional test method has not been retained in corresponding ITS 3.8.4.

The proposed change has been categorized as administrative. Comment: The proposed change is more restrictive relative to the CTS. Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.4-05 Bases JFD 4 Bases Background discussion for ITS 3.8.4, STS Bases markup page B 3.8-51, second paragraph The Bases Background discussion for STS 3.8.4. provides a description of the required duty cycle for the batteries. The Bases Background discussion for corresponding ITS 3.8.4 has not adopted this, but instead merely uses the term " duty cycle". Comment: This is not a justifiable plant specific difference. Revise the Bases to provide a description of the required duty cycle.

DEC Response:

3.8.4-06 Catawba Bases JFD 3 McGuire JFD 1 McGuire Bases for ITS SR 3.8.4.3 Catawba Bases for ITS SR 3.8.4.4 The Bases for STS SR 3.8.4.3 addresses the Frequency for the SR. This material has not been adopted in the Bases for corresponding ITS SR 3.8.3 for McGuire and ITS SR 3.8.4.4 for Catawba. Use of brackets in the STS indicates that plant-specific information supporting the specified Frequency should be inserted. Comment: This is not a justifiable plant specific difference. Revise the Bases to address the Frequency for the SR.

DEC Response:

MC2_CR_3.8 17 April 2S,1998

i McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems l- 3.8.4-07 Bases JFD 5 I

l McGuire Bases for ITS SR 3.8.4.3, STS Bases markup insert

! page B 3.8-56 Catawba Bases for ITS SR 3.8.4.4, STS Bases markup insert page B 3.8-55 Material has been added to the information provided by the Bases for STS SR 3.8.4.3 in l the Bases for corresponding ITS SR 3.8.4.3 for McGuire and ITS SR 3.8.4,4 for Catawba, The insert states, The presence of physical damage or deterioration does not necessarily l represent a failure of this SR, provided an evaluation determines that the physical damage l or deterioration does not affect the Operability of the battery (its ability to perform its design function). Comment: No facility-specific technical justification has been provided for the proposed change. Revise the submittal to provide the appropriate justification.

1 DEC Response:

1 3.8.4-08 Bases JFD 1 (McGuire)

Bases for ITS SRs 3.8.4.4 and 3.8.4.5 (McGuire) ;

Bases JFD 3 (Catawba) l '

Bases for ITS SRs 3.8.4.5 and 3.8.4.6 (Catawba)

The Bases for STS SRs 3.8.4.4 and 3.8.4.5 address the Frequencies for the SRs. This material has not been adopted in the Bases for corresponding ITS SRs 3.8.4.4 and 3.8.4.5 for McGuire and ITS SRs 3.8.4.4 and 3.8.4.5 for Catawba. Comment: This is not a j justifiable plant specific difference. Revise the Bases to address the Frequencies for the SRs. '

DEC Response:

l l

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l MC2_CR_3.8 18 April 23,1998 l

i L

a ,

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.4-09 Bases JFD 3 Bases for ITS SR 3.8.4.5 (McGuire)

Bases for ITS SR 3.8.4.6 (Catawba)

Bases for ITS SR 3.8.4.3 (Catawba)

The Bases for ITS SR 3.8.4.5 states that the connection resistance limits shall be no more than 20 % above the resistance as measured during installation, or not above the ceiling value established by the manufacturer. This material has not been adopted in the Bases for corresponding ITS SR 3.8.4.5 for McGuire and ITS SR 3.8.4.6 for Catawba . This paragraph in the Bases for STS SR 3.8.4.2 is also omitted from the Catawba Bases for corresponding ITS SR 3.8.4.3. Bases JFD 3 states that this material is not applicable to the facility. Comment: Bases JFD 3 does not explain why this material is not applicable.

Revise the submittal to explain why this material is not applicable to the facility.

DEC Responce:

3.8.4 10 JFD 5 Catawba ITS SR 3.8.4.9 Frequency McGuire ITS SR 3.8.4.8 Frequency STS SR 3.8.4.8 Frequency ITS do not adopt part of the STS Frequency requirement for the performance or modified performance discharge test. JFD 5 does not explain why the omitted Frequency is not applicable. Comment: Provide a technical explanation for not adopting the omitted material.

DEC Response:

MC2_CR_3.8 19 April 23,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.4-11 JFD 10 Catawba only ITS SR 3.8.4.3 STS SR 3.8.4.2 CTS 4.8.2.1.1.b.2)

a. CTS 3.8.2.1.e and f require operability for 125 volt de busses EDE and EDF, respectively. This, however, does not mean that CTS 3.8.2.1.e and f require the associated DG batteries DGBA and DGBB (and associated chargers) to also be operable, becaurs batteries EBA and EBD (end associated chargers) are capable of maintaining busses EDE and EDF energized (i.e., operable). Thus extending the applicability of the~ CTS surveillance requirements for batteries EBA through EBD to the batteries DGBA and DGBB is a more restrictive change. Comment: Revise the submittal with an appropriate justification and update the CTS markup,

b. ITS SR 3.8.4.3 does not allow measuring battery connection resistance in lieu of checking for no visible corrosion at battery terminals and connectors for the DG batteries DGBA and DGBB. JFD 10 does not s;:ecifically explain wh, this allowance is not offered for the DG batteries. Comment: Revise the submittal with the missing explanation.

DEC Response:

3.8.4 12 Bases JFD 3 Catawba only Bases for ITS SR 3.8.4.3 The Bases for STS SR 3.8.4.2 states that the limits established for this SR shall be no more than 20 % above the resistance as measured during installation, or not above the ceiling value established by the manufacturer. This material has not been adopted in the Bases for corresponding ITS SR 3.8.4.3. Bases JFD 3 states that this materialis not applicable to the facility. Comment: Bases JFD 3 does not explain why this materialis not applicable. Revise the submittal to explain why this material is not applicable to the facility.

DEC Response:

3.8.5, DC Sources - Shutdown 3.8.5-01 Not used MC2_CR_3.8 20 April 23,1998

9 McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.5-02 DOC M.17 McGuire only CTS 3/4.8.2.2 Action CTS 3/4.8.2.2 Action requires establishing containment integrity within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This requirement has not been retained in corresponding ITS 3.8.'5, but has replaced with action requirements consistent with the STS. DOC M.17 does not explain, however, why the proposed actions are more restrictive than the CTS action requirement. Neither,does it explain why the CTS action requirement may be deleted. Comment: DOC M.17 does not specifically address the proposed change. Revise the submittal to provide the appropriate justification for the proposed change. Also address similar change in ITS 3.8.8 and 3.8.10.

DEC Response:

3.8.6. Battery Cell Parameters 3.8.6-01 DOC A.37 ITS 3.8.6, Table 3.8.6-1 Footnotes (a) and (c)

CTS Table 4.8-3 Footnote (a) to STS 3.8.6, Table 3.8.6-1 aadresses electrolyte level during equalizing charges. Footnote (c) addresses specific gravity limits when on a float charge. This material has been adopted in Table 3.8.6-1 of corresponding ITS 3.8.6. DOC A.37 states that these footnotes were formed from the requirements of ITS 3.8.6, Table 3.8.61 and that they do not significantly modify the technical nature of the current specification.

Comment: Footnotes (a) and (c) are not present in any form in CTS Table 4.8-3. They represent technical changes to the CTS. Revise the submittal to provide the appropriate justification for the proposed changes.

DEC Response:

i i

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MC2_C R_3.8 21 April 23,1998 i

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.6 02 JFD 10 Catawba only ITS LCO 3.8.6 ITS SRs 3.8.6.1, 3.8.6.2, and 3.8.6.3 ITS SRs 3.8.6.1, 3.8.6.2, and 3.8.6.3 require verifying that the electrolyte level, float voltage, and specific gravity of the channels of DC batteries are within limit. There is no requirement to monitor the float voltage and specific gravity of the Train A and Train B DG batteries. ITS LCO 3.8.6 only requires that DG battery temperature and level be within limits. Comment: Provide the technical justification for not requiring monitoring the float voltage and specific gravity of the DG batteries.

DEC Response:

3.8.6-03 DOC LA.32 l Catawba ITS SR 3.8.6.4 l

i Catawba CTS 4.8.2.1.1.b.3) and 4.8.1.1.4.b.2)

McGuire ITS 3.8.6.3 McGuire CTS 4.8.2.1.2.b.3)

CTS 4.8.2.1.1.b(3) requires verifying that the average electrolyte temperature of six connected cells is above 60 'F. Corresponding ITS SR 3.8.6.4 requires verifying that the j average electrolyte temperature of representative cells is 2 60 *F. DOC LA.32 states that "six connected cells" has been placed in the proposed Bases. Comment: This material l could not be found in the Bases for Catawba ITS SR 3.8.6.4 and McGuire iTS SR 3.8.6.3.

l Revise the Bases to implement DOC LA.32.

DEC Response:

3.8.6-04 ITS SR 3.8.6.2 Catawba only Bases for ITS SR 3.8.6.2, STS Bases markup insert page B 3.8 66 The Frequency for ITS SR 3.8.6.2 is 7 days. The Bases for ITS SR 3.8.6.2 states that the Frequency is once per month. Comment: Revise the Bases to resolve the discrepancy.

DEC Response: ,

MC2,,,CR_3.8 22 April 23,1998

1 McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.6-05 Bases for ITS SR 3.8.6.2, STS Bases markup insert l Catawba only page B 3.8-66 l ITS SR 3.8.6.2 CTS 4.8.1.1.4.a.1)

DOC A.38

)

ITS SR 3.8.6.2 requires verifying that the electrolyte level of the DG batteries is at or

above the low mark and at or below the high mark. This requirement is not addressed in corresponding STS 3.8.6. The Bases for ITS SR 3.8.6.2 does not explain why the SR is performed. Comment: Revise the Bases to explain why the SR is performed.

l DEC Response:

! 3.8.7, inverters - Operating l 3.8.7-01 DOC A.65 l Catawba JFD 16 McGuire JFD 3 ITS LCO 3.8.7 Note !

CTS 3.8.3.1.g, h, I, and j, Footnote

j l

Footnote

to CTS 3.8.3.1.g, h, l, and j provides an allowance to disconnect an inverter from its DC source for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the purpose of performing an equalizing charge on its associated battery bank. This allowance has not been retained in corresponding ITS l 3.8.7. The proposed change has been categorized as administrative. Comment: The l proposed change is more restrictive relative to the CTS. Revise the submittal to provide ,

! the appropriate justification. Also note that Catawba JFD 16 appears applicable to McGuire and that McGuire's JFD 3 is too general.

DEC Response:

l MC2_CR_3.8 23 April 23,1998 l

l McGuire & Catawba improved TS Review Comments 3

ITS Section 3.8, Electrical Power Systems 3.8.7-02 DOC A.54 ITS LCO 3.8.7 CTS 3.8.3.1.g, h, I, and J, Footnote #

Footnote # to CTS 3.8.3.1.g, h, I, and j provides an allowarca to energize two channel related inverters from the same train DC bus during periods o; in modification associated with battery, main and tie breaker replacement. Thit aowance has not been retained in corresponding ITS 3.8.7. The proposed change has been categorized as administrative. Comment: The proposed change is more restrictive relative to the CTS.

Revise the submittal to provide the appropriate justification.

DEC Response:

3.8.7-03 Bases JFD 3 Catawba only Bases Background discussion for ITS 3.8.7 Bases for ITS LCO 3.8.7 The Bases for STS LCO 3.8.7 states, " Alternatively, power supply may be from an internal 1 AC source via rectifier........." This material has not been adopted in corresponding ITS 3.8.7. Bases JFD 3 states that this materialis not applicable to the facility. However, the Bases Background discussion for ITS 3.8.7 states that the inverters can be powered from an internal AC source rectifier. Comment: There appears to be a discrepancy between the Bases Background discussion for ITS 3.8.7 and the Bases for ITS LCO 3.8.7. Revise the Bases to resolve the discrepancy.

DEC Response:

3.8.8, Inverters - Shutdown 3.8.8-01 Not used MC2_CR_3.8 24 April 23,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.8-02 DOC A.1 McGuire only ITS LCO 3.8.8 CTS 3.8.3.2.c, Footnote

CTS 3.8.3.2.c requires two 120 volt AC vital buses energized from their respective inverters connected to their respective DC channels. Footnote

states," Required for both Units 1 and 2." The footnote has not been retained in corresponding ITS 3.8.8. Comment:

DOC A.1 does not describe why the proposed change is administrative. Revise the submittal to provide the appropriate justification fnr the proposed change.

DEC Response:

3.8.8-03 JFD 2 Catawba only ITS SR 3.8.8.1 Bases for ITS SR 3.8.8.1 STS SR 3.8.8.1 requires verifying correct inverter voltage and alignments to required AC vital buses. Corresponding ITS SR 3.8.8.1 refers to "... alignment to required AC vital bus."

The Bases for ITS SR 3.8.8.1 refers to "...AC vital buses energized from the inverter."

Comment: There is an apparent discrepancy between ITS SR 3.8.8.1 and its 8ases. Revise ITS SR 3.8.8.1 to conform to the Catawba design.

DEC Response:

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l M C2_CR_3.8 25 April 23,1998 l

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9, Distribution Systems - Operating 3.8.9-01 Catawba JFD 8 McGuire JFD 17 Bases JFD 5 ITS 3.8.9 Required Actions A.1, B.1, and C.1, Completion Time (McGuire)

ITS 3.8.9 Required Actions A.1, B.1, C.1, and D.1, Completion Time (Catawba)

STS 3.8.9 Required Actions A.1, B.1, and C.1, Completion Time

- Bases for ITS 3.8.9 Required Action A.1,8.1 and C.1'(McGuire)

Bases for ITS 3.8.9 Required Action A.1, B.1, C.1, and D.1 (Catawba)

The Completion Time for Required Actions A.1, B.1, and C.1 of STS 3.8.9 is 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. The Completion Time for Required Actions A.1, B.1, and C.1 of corresponding ITS 3.8.9 is 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months (for McGuire and 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months for Catawba) from discovery of failure to meet LCO. The JFDs state the times are based on summing the

[ restoration) completion times for all of the conditions in the Actions. This is not how the times are derived in the STS. Comment: This is not a justifiable plant specific difference.

Revise the submittal to conform to the STS. The 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months is based on a second entry into Action A with an 8-hour limit, just before the first entry's 8-hour period expires. One should take the two longest completion times and add them to arrive at the LCO-cap time period. Such an allowance (also a limitation) is given in the STS to address the second inoperability of diverse systems with the longest two completion times. STS LCO 3.8.9 actually goes beyond this by doubling the time limit in Action A, instead of simply adding the 8 and the 2-hours limits of Action A and Action B (or C), respectively. A second concurrent inoperability is not addressed by the STS because it is very unlikely to occur.

DEC Response:

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i MC2_CR_3.8 26 April 23,1998 l

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l McGuire & Catawba improved TS Review Comments j ITS Section 3.8, Electrical Power Systems l 3.8.9-02 Bases JFD 3 l Bases Background discussion for STS 3.8.9 The fifth paragraph of the Bases Background discussion for STS 3.8.9 describes the independence of the DC electrical power distribution subsystems. This material has not l

been adopted in the Bases Background discussion for corresponding ITS 3.8.9. Bases JFD 3 states that these requirements are not applicable to the facility. Comment: Bases JFD 3 does not explain why this material is not applicable. Revise the submittal to explain why this material is not applicable to the facility or revise the Bases to describe the independence (or degree of dependence) of the DC electrical power distribution subsystems.

DEC Response:

3.8.9-03 Bases JFD 4 Bases Background discussion for ITS 3.8.9 l

l The first paragraph of the Bases Background discussion for STS 3.8.9 describes the l

l redundancy and independence of the AC, DC, and AC vital bus electrical power distribution subsystems. The redundancy and independence of the of the DC and AC vital bus electrical power distribution subsystems are not clearly described in the Bases Background ;

discussion for corresponding ITS 3.8.9. Comment: This is not a justifiable plant specific ;

difference. Revise the Bases to clearly describe the redundancy and independence (or !

degree of dependence) of the DC and AC vital bus electrical power distribution l subsystems.

DEC Response:

l MC2 CR_3.8 27 April 23,1998 l

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l McGuire & Catawba improved TS Review Comments '

ITS Section 3.8, Electrical Power Systems

]

3.8.9-04 Bases JFD 1 Bases for STS LCO 3.8.9, STS Bases markup page B 3.8-81 l Bases Background discussion for ITS 3.8.9, STS Bases markup page B 3.8-79 CTS 3.8.2.1 Bases for ITS 3.8.9, Required Actions B.1 and C.1 Bases for ITS 3.8.7 Required Action A.1 The Bases for STS LCO 3.8.9 states that Operable vital bus electrical power distribution j-subsystems require the associated buses to be energized to their proper voltage from the associated Class 1E constant voltage transformer. The Bases for corresponding ITS LCO 3.8.9 describes utilizing the regulated voltage transformer (constant voltage transformer for Catawba). However, the Bases Background discussion for ITS 3.8.9 states that the regulated voltage source transformer is powered from a non-Class 1E bus. Comment:

Provide the technical justification for utilizing a non-Class 1E power source for this l

application.

DEC Response:

3.8.9-05 Bases JFD 3 Bases for STS LCO 3.8.9, STS Bases markup page B 3.8-81 Bases for ITS LCO 3.8.9, STS Bases markup page B 3.8-81 The last paragraph'of the Bases for STS LCO 3.8.9 describes the use of tie breakers. This material has not been adopted in the Bases for corresponding ITS LCO 3.8.9. Bases JFD 3 states that this material is not applicable to the facility. Comment: Bases JFD 3 does not explain why this material is not applicable. Revise the submittal to explain why this material is not applicable to the facility.

DEC Response:

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MC2_CR_3.8 28 April 23,1998 l l

'u McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9-06 Bases JFD 1 McGuire only Bases for STS 3.8.9, Table B 3.8.9-1 Bases for ITS 3.8.9, Table B 3.8.91 Table B 3.8.9-1 of the Bases for STS 3.8.9 provides the identification of the buses and distribution panels for the Train A and Train B DC buses. The Train A buses have been identified as EVDA and EVDC. The Train A distribution panels have been identified as EVDA and EVDC also. The Train 3 buses have been identified as EVDB and EVDD. The Train B distribution panels have been identified as EVDB and EVDD also. Comment:

Confirm that these are the correct identifications for the DC buses and distribution panels.

DEC Response:

3.8.9-07 Bases JFD 3 Bases for STS 3.8.9, Required Action C.1, STS Bases markup page B 3.8 85 The Bases for STS 3.8.9, Required Action C.1 states that in the event that one DC electrical power distribution subsystem is inoperable, the unit is significantly more vulnerable to a complete loss of all DC power. This material has not been adopted in the Bases for corresponding ITS 3.8.9, Required Action C.1. Bases JFD 3 states that this i materialis not applicable to the facility. Comment: Bases JFD 3 does not explain why this material is not applicable. Revise the submittal to explain why this material is not applicable to the facility or conform to the STS.

DEC Response:

l MC2_CR_3.8 29 April 23,1998

. y McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.9-08 Catawba McGuire JFD 7 'JFD 7 ITS 3.8.9 Condition F ITS 3.8.9 Condition E DOC L.24 DOC L.24 ITS 3.8.9 Actions Conditions ITS 3.8.9 Actions Conditions Bases for ITS 3.8.9, Required Actions Bases for ITS 3.8.9, Required Actions

a. The wording of the listed Actions Condition is unclear. Both Catawba Condition F and McGuire Condition E say "Two trains, two or more channels or buses inoperable that result in a loss of safety function." Only Catawba has the DG 125 volt DC buses EDE and EDF.

Thus how can both Conditions read the same? The STS statement of this Condition, "Two trains with inoperable distribution subsystems that may result in a loss of safety function."

is much easier to understand. Comment: Is the following statement equivaient to the proposed Condition? "One or more electrical power distribution subsystems inoperable in Train A AND one or more electrical power distribution subsystems inoperable in Train B that result in a loss of safety function." Revise the submittal to more clearly state the listed Condition.

b. Conditions A, B, and C of STS 3.8.9 address one AC electrical power distribution subsystem, one AC vital bus, and one DC electrical power distribution subsystem, respectively, being inoperable. Conditions A,3, and C of ITS 3.8.9 each address one or more subsystems being inoperable. Condition E of STS 3.8.9 addresses two trains with inoperable distribution subsystems that result in a loss of safety function. Condition E of ITS 3.8.9 addresses two trains, two or more channels or buses inoperable that result in a loss of safety function. The justification for the proposed differences is provided by TSTF-

16. Comment: TSTF 16, Revision 1, has been rejected by the NRC. Additionally, DOC L.24 neither describes the change's impact on safety nor why the safety impact is acceptable. Revise the submittal to adopt the presentation of the Actions Conditions given in the STS. (Note, the addition of the Condition in the Catawba ITS for an inoperable DG DC subsystem is ecceptable because'it requires immediately declaring the associated DG inoperable.) Also note, it is the STS's intent that in the event of a second concurrent inoperable distribution subsystem of the same type, entry into LCO 3.0.3 is required.

Action E addresses the situation of inoperable subsystems of two different types in opposite trains (e.g., a Train A AC subsystem and a Train B AC vital bus.) that result in a loss of function.

DEC Response:

MC2_CR_3.8 30 April 23,1998

m McGuire & Catawba Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.10, Distribution Systems - Shutdown 3.8.10-01 Not used 3.8.10-02 DOC M.17 McGuire only CTS 3/4.8.2.2 Action CTS 3/4.8.3.2 Action CTS 3/4.8.2.2 Action and CTS 3/4.8.3.2 Action require establishing containment integrity within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . These requirements have not been retained in corresponding ITS 3.8.10.

Comment: DOC M.17 does not specifically address the proposed changes. Revise the submittal to provide the appropriate justification for the proposed changes. Also see comment 3.8.5-02.

DEC Response:

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MC 2_CR_3.8 31 April 23,1998

McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations General Comments 3.9-01 General Comment - Most of the M DOCS do a good job of explaining what the change is, but they do not address why the change is acceptable for the plant based on operational restrictions / plant operations, or design / licensing basis. These DOCS need to be fixed.

i DEC Response:

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l 3.9-02 JFD 3 Catawba Only STS 3.9.2, Unborated Water Source Isolation Valves Catawba has not adopted STS 3.9.2. Comment: Why is STS 3.9.2 not applicable to Catawba?

DEC Response:

3.9.1, Boron Concentration 3.9.1-01 ITS LCO 3.9.1 4 Bases discussion for ITS SR 3.9.1.1, page B 3.9-4.

1 ITS LCO 3.9.1 requires that the boron concentration of the Reactor Coolant System, the refueling canal, and the refueling cavity be maintained within the limit specified in the COLR. The following has been added to the material provided by the Bases discussion for STS SR 3.9.1.1. One sample from the refueling canal or refueling cavity is sufficient to I determine the boron concentration in that volume of water. An additional sample is taken from the RCS." Comment: No technical justification has been provided to support this 1

proposed plant specific difference. Revise the submittal to provide the justification for this difference or conform to the STS. ,

DEC Response:

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MC 2_CR_3.9 1 April 24,1998 l

, 'y McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations 3.9.1-02 DOC A.1 CTS 3/4.9.1 Applicability Note

Deletion of the footnote qualifying Mode 6 Applicability referred to as A.1. This change modifies the CTS requirement for Mode 6 applicability. This is not an Administrative change and A.1 does not address the deletion. Comment: Provide an appropriate justification and DOC.

~ DEC Response:

3.9.1-03 Bases JFD 6 '

Catawba only Bases discussion for ITS 3.9.1, Actions A.1 and A.2, insert page B 3.9-4.

I The proposed additional material states that positive reactivity additions caused by changes in coolant temperature should not be considered a positive reactivity addition. Comment:

The proposed insert material is not a justifiable plant specific or editorial difference. Revise the submittal to conform to the STS.

DEC Response:

McGuire ITS 3.9.2, Unborated Water Source Isolation Valves (new specification) 1 M.3.9.2-01 Bases JFD 4 Bases Background discussion for ITS 3.9.2, page B 3.9-5.

The following has been added to the material provided by the Bases discussion for STS 3.9.2. "One of the following groups of valves is required to be closed: 1) NV 250, or 2)

NV-131, NV 140, NV-176, NV- 468, NV-808, and either NV-132 or NV-1026 when it is necessary to makeup to the RWST during refueling operations." Comment: The modifying phrase "when it is necessary to makeup to the RWST during refueling operations" appears to conflict with the LCO and Applicability which require the unborated water sources to be i isolated at all times while in Mode 6. Revise the submittal to address this concern, f

DEC Response:

i MC2_CR_3.9 2 April 24,1998 !

I

'.o McGuire and Catawba improved TS Review Comments ITG Section 3.9, Refueling Operations M.3.9.2-02 DOC M.1 ITS 3.9.2 DOC M.1 does a good job of saying what this change is, but does not provide i justifications for why these changes are acceptable for this plant except to say that they are consistent with the STS. Comment: Provide justification for this change.

DEC Response:

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M.3.9.2 03 DOC L.2 l

1 CTS 4.9.1.3 ITS SR 3.9.2.1 The CTS Surveillance Frequency to verify that valve NV-250 is closed is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , while the ITS has 31 days. This is an extension of the allowed outage time. DOC L2 indicates j that this is a more stringent requirement. Provide additional justification for this change -i based on plant operations.

DEC Response:

1 M .3.9.2 DOC A.2 ,

ITS 3.9.2 Actions Note !

The Note allowing Separate Entry Condition is not an administrative change. The CTS does not address this issue. Provide and appropriate justification for this change.

DEC Response:

l MC2_CR_3.9 3 April 24,1998

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McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations Catawba ITS 3.9.2, Nuclear instrumentation McGuire ITS 3.9.3, Nuclear instrumentation C.3.9.2-01 DOC L.3 ITS 3.9.2 Required Action A.3.2.1 CTS 3/4.9.2.1, Action (a) (2)

Bases Background discussion for ITS 3.9.2, insert page B 3.9-8.

In the event one or both trains of the boron dilution monitoring system (BDMS) are inoperable, the CTS requires verifying that two source range neutron flux monitors are Operable, one with audible indication in the control room and cne with audible indication in the containment. DOC L.3 states that the requirements for audible indication have been deleted. Comment: This material appears in the Bases Background discussion for ITS 3.9.2. Revise DOC L.3 to be an LA type change. The justification should be revised also.

DEC Response:

C.3.9.2-02 Bases JFD 5 Bases discussion for ITS 3.9.2, Required Actions A.1, A.2, A.3.1, A.3.2.1, and A.3.2.2, insert page B 3.9-9.

The second paragraph of this section describes that verifying the Operability of t,wo source range neutron flux monitors and verifying that the combined flowrate from both reactor makeup water pumps are within limits is an option to isolating the unborated water source.

This section goes on to state that once these options are available, Core Alterations and positive reactivity changes can continue, Comment: The Bases discussion appears to be in error. There is no provision in the proposed required actions to continue Core Alterations and positive reactivity changes until after the Action Condition has been exited. Revise the submittal to delete the last sentence of this section of the Bases discussion.

DEC Response:

MC 2_CR_3.9 4 April 24,1998

T J

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McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations 1

C.3.9.2-03 DOC L.4 Catawba ITS 3.9.2 Actions '

CTS 3/4.9.2.1 Action (c) l CTS Action (c) requires that with both BDMS systems inoperable, determine the boron concentration of the 'RCS at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.9.2 Actions omit this action l requirement as discussed in DOC L.2. Comment: Since it appears that CTS requirements l are being retained, retain Action (c).

l DEC Response:

! i M.3.9.3-01 DOC L 3 CTS 3.9.2 Bases Background discussion ior ITS 3.9.3, insert page B 3.9-8.

CTS 3.9.2 establishes the req.iirements for the nuclear instrumentation (source range monitors) in Mode 6 and requires one source range monitor with audible indication in the !

containment and the control room. DOC L.3 states that this audible indication requirement has been deleted. Comment: This material is in the Bases Background discussion for ITS 3.9.3 and should remain there. Revise DOC L.3 to be an LA type change. The justification should be revised also. There is a contradiction in the justification that states that the audible alarm in not needed and that it also alerts control room personnel....

DEC Response:

1 M.3.9.3-02 Bases JFD 4 Bases discussion for ITS 3.9.3, Background, page B 3.9-8.

The Baces discussion for STS 3.9.3 describes the type of detector used and the instrument range and accuracy for the NIS source range monitors. The corresponding ITS Bases describes the NIS source range monitors and the Gamma-Metrics shutdown monitors.

However, the ITS Bases discussion has omitted a description of the type of detectors used, and the instrument range and accuracy. Comment: Revise the Bases to include a description of the type of detectors used and the instrument range and accuracy.

DEC Response:

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MC2_CR_3.9 5 April 24,1998

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McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations M.3.9.3-03 Bases JFD 4 Bases discussion of the Applicable Safety Analyses for ITS 3.9.3, page B 3.9-8.

\

The Bases discussion for STS 3.9.3 references LCO 3.9.2, "Unborated Water Source l Isolation Valves," and the need for a safety analysis for an uncontrolled boron dilution j accident. This discussion has not been adopted in the corresponding ITS Bases. Bases 1 JFD 4 does not provide a specific explanation for this omission. Comment: Revise the submittal to conform to the STS.

DEC Response:

I M.3.9.3-04 Bases discussion for ITS 3.9.3 Applicability, page B 3.9-9.

The ITS Bases discusses the Operability requirements for the NIS source range detectors for Modes 2 through 6. However, the Bases only address the Operability requirements for '

the Gamma-Metrics shutdown monitors in Mode 6. The Operability requirements in the other modes are not addressed. Comment: Revise the submittal to provide additional information about the Operability requirements for the Gamma-Metrics shutdown monitors

{

in the other modes. ;

1 '

DEC Response:

Catawba ITS 3.9.3, Containment Penetrations McGuire ITS 3.9.4, Containment Penetrations M.3.9.4-01 Bases Background discussion for ITS 3.9.4, page B 3.9-13.

C.3.9.3-01 Bases Background discussion for ITS 3.9.3, page B 3.9-13.

The Bases discussion for STS 3.9.4 states that equivalent isolation methods must be approved (as documented in reference 1). The corresponding ITS Bases discussion refers to NRC approval and deletes reference 1. Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS and include the reference to the NRC safety evaluation approving the equivalent isolation methods.

DEC Response:

, MC2_CR_3.9 6 April 24,1998 I

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- ,w McGuire and Catawba Improved TS Review Comments ITS Section 3.9, Refueling Operations M.3.9.4-02 Bases discussion for ITS 3.9.4 Required Actions A.1 and A.2, page B 3.9-14. )

C.3.9.3-02 Bases discussion for ITS 3.9.3 Required Actions A.1 and A.2, page B 3.9-14.

The Bases for STS 3.9.4 Required Actions A.1 and A.2 states, "....shall not preclude completion of movement of a component to a safe position." The corresponding ITS Bases has not adopted the phrase " completion of". Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

DEC Response:

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M .3.9.4-03 Bases JFD 3 '

Bases for ITS SR 3.9.4.1, page B 3.9-15.

C.3.9.3-03 Bases JFD 3 !

Bases for ITS SR 3.9.3.1, page B 3.9-15.

The Bases for STS SR 3.9.4.1 states that a surveillance before the start of refueling operations will provide two or three surveillance verifications during the applicable period for this LCO. This material has not been adopted in the corresponding ITS Bases.

Comment: This is not a justifiable plant specific difference. Revise the submittal to t

conform to the STS.

DEC Response:

I M.3.9.4-04 JFD 6 Bases JFD 4 Bases discussion for ITS 3.9.4, Background, page B 3.9-11.

l C.3.9.3-04 JFD 6 Bases JFD 5 Bases discussion for ITS 3.9.3, Background, page B 3.9-11.

The first paragraph of the Bases Background discussion for STS 3.9.4 states that containment closure means that all potential escape paths are closed or capable of being

! closed. The corresponding ITS Bases discussion states that all potential escape paths are closed or controlled. Comment: The term " controlled" may be misinterpreted, delete this term. Revise the Bases to more clearly describe how the filtration provided by the containment purge exhaust r,ystem contributes to " containment closure",

i DEC Response:

MC 2_C R_3.9 7 April 24,1998 l

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,g,.s McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations C.3.9.3-05 DOC A.3 CTS 3/4.9.4 Action b i

ITS 3.9.3 Condition B CTS 3/4.9.4 Action b provides requirements when a heater is inoperable. Corresponding i

ITS 3.9.3 Condition B refers to one or more CPES train (s) heater inoperable. This has been categorized as an administrative change. Comment: This appears to be a less restrictive change. Revise the submittal to provide additional justification for this proposed change. It may be appropriate to propose additional Required Actions for the Condition of both

, heaters inoperable.

l DEC Response:

Catawba ITS 3.9.4, RHR and Coolant Circulation - High Water Level McGuire ITS 3.9.4, RHR and Coolant Circulation - High Water Level 1

I No comments Catawba ITS 3.9.5, RHR and Coolant Circulation - Low Water Level McGuire ITS 3.9.6, RHR and Coolant Circulation - Low Water Level l

l M.3.9.6-01 Bases JFD 4 l Bases discussion for ITS 3.9.6, Action B.3, page B 3.9-23.

C.3.9.5-01 Bases JFD 4 i Bases discussion for ITS 3.9.5, Action B.3, page B 3.9-23.

l The Bases discussion for STS 3.9.6 states that the Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable based on the low probability of the coolant boiling in that time. This material has not been adopted in the corresponding ITS Bases discussion. Bases JFD 4 does not l provide a specific explanation for this omission. Comment: Revise the submittal to include l this information.

! DEC Response:

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MC2_CR_3.9 8 April 24,1998 i I

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el'.s McGuire and Catawba improved TS Review Comments ITS Section 3.9, Refueling Operations Catawba ITS 3.9.6, Refueling Cavity Water Level McGuire ITS 3.9.7, Refueling Cavity Water Level M.3.9.7-01 Bases JFD 2 Bases for ITS 3.9.7 Required Actions A.1 and A.2, page B 3.9-26.

C.3.9.6-01 Bases JFD 2 Bases for ITS 3.9.6 Required Actions A.1 and A.2, page B 3.9 26.

The Bases for STS 3.9.7 Required Actions A.1 and A.2 states, "....shall not preclude completion of movement of s component to a safe position." The corresponding ITS Bases discussion has not adopted the phrase " completion of". Comment: This is not a justifiable plant specific difference. Revise the submittal to conform to the STS.

DEC Response:

M.3.9.7-02 DOC M.6 CTS 3/4.9.9, Applicability C.3.9.6-02 DOC M.7 CTS 3/4.9.9, Applicability The Applicability for CTS 3/4.9.9 has been revised to include movement of irradiated fuel assemblies within containment, in order to conform to the STS. The DOC states that this change was made in order to minitrize the possibility of a fuel handling accident outside the reactor vessel. Comment: It is not clear how this Applicability change " minimizes the possibility" of a fuel handling accident. Revise the submittal to provide additional justification for this proposed change.

DEC Response:

MC2 CR 3.9 9 April 24,1998 I

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v t e Letter Sequence RAI
TAC:M95298, Implement 10 CFR 50, Appendix J, Option B, TSTF-45, TSTF-17 (Open) TAC:M95299, Implement 10 CFR 50, Appendix J, Option B, TSTF-45, TSTF-17 (Open) TAC:M98964, Implement 10 CFR 50, Appendix J, Option B, TSTF-45, TSTF-17 (Open) TAC:M98965, Implement 10 CFR 50, Appendix J, Option B, TSTF-45, TSTF-17 (Open)
Initiation Acceptance... Administration Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 30 January 1998 28 April 1998 Answers Results Approval... Other: ML20151Y172, ML20151Y235, ML20195K191, ML20199E417, ML20199J107, ML20204E179, ML20205B616, ML20205M674, ML20216B753, ML20216B957, ML20217B718, ML20217E628, ML20217E973, ML20236M023, ML20236M874, ML20248L685, ML20248L705, ML20249C577
MONTHYEAR1998-06-25 [Table View]

ML20217L049

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SUBJECT:

Dear Mr. Tuckman:

Enclosure:

SUBJECT:

Dear Mr. Tuckman:

Enclosure:

SUBJECT:

Dear Mr. Tuckman:

Enclosure:

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