Text

Forwards Suppl 7 to Improved Tech Specs,In Response to Addl Items Identified at 980617,18,0709 & 10 Meeting.Resolution of All Open Items & Addl Clarifications Are Included in Encl
	ML20236U092
Person / Time
Site:	Catawba
Issue date:	07/21/1998
From:	Tuckman M; DUKE POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	TAC-M95298, TAC-M95299, NUDOCS 9807290299
	Download: ML20236U092 (120)
	v • d • e

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Duke Power Company A thkr Envy Company

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EC0711 d '**"p

526 South Church Street PO. Box 1006 Charlotte, NC 28201 1006 M. S. Tuckman Executive Vice kident (704)382-2200 omc1 Nuclear Generation (704)382-4360 fax July 21, 1998 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Catawba Nuclear Station Docket Numbers 50-413, and -414 Improved Technical Specifications, Supplement i TAC Nos. M95298 and M95299 Duke Energy's meeting with the NRC on June 17/18 and July 9/10, 1998 resulted in open items associated with previous RAI responses on Sections 3.2, 3.3, 3.4, 3.5, 3.6, 3.8, and 5.0. Additional clarifications have been identified by DEC on Section 1.0, 3.1 and 3.8. Resolution of all open items and the additional clarifications are included as Enclosure

1. This completes our response to all RAIs.

Immediately following each staff comment or DEC identified 1 additional item are changes to the ITS submittal necessary to resolve the item and supplement the initial ITS submittal. Changes are denoted by revision bars to facilitate staff review.

The pages provided in Enclosure 1 in this response replace f l the corresponding pages in the May 27, 1997 submittal, I ;

Supplement l'provided March 9, 1998, Supplement 2 provided ,

March 20, 1998, Supplement 3 provided April 20, 1998, [ ;

Supplement 4 provided June 3, 1998, Supplement 5 dated June l 24, 1998, Supplement 6 dated July 7, 1998. All changes have been determined to be within the scope of the original PORC and NSRB reviews. /g y i

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U. S. Nuclear Regulatory Commission July 21, 1998 Page 2 Pursuant to 10 CFR 50.91(b) (1) , a copy of this amendment has l been provided to the appropriate State of South Carolina officials.

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

Keller at 704-382-5826.

l Very'truly yours, g, S' M. S. Tuckman 1.

. Enclosure xc: w/ enclosures l-Mr. L.:A. Reyes i Administrator, Region II-U. S. Nuclear Regulatory Commission Atlanta Federal Center 61'Forsyth St., SW, . Suite 23T85_

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

.U . S. Nuclear Regulatory Commission Mail'Stop'O-14 H25 Washington, DC 20555 Mr. D.'J. Roberts-Senior Resident' Inspector Catawba-Nuclear. Station i

l' Max Batavia, Chief y Bureau of Radiological Health l S..C. Department of Health & Environmental Control 2600 Bull Street Columbia,: SC 29207 1:

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ENCLOSURE 1 CATAWBA NUCLEAR STATION RESOLUTION OF OPEN ITEMS AND ADDITIONAL CLARIFICATIONS f.

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l Catawba and McGuire Improved TS Review Comments Section 1.0, Use and Application l

1.0 AdditionalItems )

1 1.0-1 DOC LA3 DOC LA3 currently indicates that the definition of process control program is relocated to procedures. DOC LA3 is revised to indicate that this definition is moved to the Selected Licensee Commitments manual (Chapter 16 of the UFSAR)

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and is controlled by 10 CFR 50.59.

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1 mc4_cr_l,0 2 July 15,1998

L Discussian of Chang:s Section 1.0 - USE AND APPLICATION TECHNICAL CHANGES - REMOVAL OF DETAILS i

l LA.1 The reactivity condition limitation for the REFUELING MODE of I operation in CTS Table 1.2 is being proposed for relocation to the COLR. Proposed TS 3.9.1 requires the boron concentrations in the RCS, refueling canal, and the refueling cavity to be maintained within the limit specified in the COLR. This change is consistent with NUREG-1431. Changes to the COLR will be subject to the administrative controls of proposed Chapter 5 and 10 CFR 50.59.

These controls will assure that any future changes to the COLR maintain the margin of safety provided by this specification.

LA.2 The CTS definitions for MEMBERS OF THE PUBLIC, PURGE-PURGING, SITE B0UNDARY, SOURCE CHECK, UNRESTRICTED AREA, VENTILATION EXHAUST TREATMENT SYSTEM, VENTING, and WASTE GAS HOLDUP SYSTEM have been deleted since specific Specifications referring to them no longer consider them a defined term, or no longer are retained in the ITS. These definitions will be relocated to Chapter 16 of the UFSAR which contains Selected Licensee Commitments (SLC),

including the Radiological Effluent Technical Specifications which utilize these terms. The removal of a definition which is not used within the TS is acceptable. This change is consistent with NUREG-1431.

LA.3 The CTS 1.23 definition for PROCESS CONTROL PROGRAM (PCP) has been moved to the SLC removed clcng with the :::ccicted progrcm dc;criptien :pecified in CTS 5.0, Administrative Ccatrcl:. The PCP implements the requirements of 10 CFR Parts 20, 61, and 71, therefore, inclusion within the TS is not necessary to ensure safe operation of the facility. The requirement cf the CFR cre implemented by plcnt procedures. Changes to the SLC will be subject to a 10 CFR 50.59 evaluation which ensures that any changes are appropriately reviewed. This change is consistent with NUREG-1431.

l Catawba Units 1 & 2 Page LA - 1 5-/20/1RSupplement 7 l

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Catawba and McGuire Improved TS Review Comments Section 1.0, Use and Application 1.0 AdditionalItems l l 1.0-2 DOC A3 l

Based on the suggestion by the NRC staff, DOC A3 has been deleted and replaced with a less restrictive change L3 to indicate the phrase "or actual" in reference to injected signals has been added to the CTS definitions for ACTUATION LOGIC TEST and CHANNEL OPERATIONAL TEST (C'Jr).

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mc4_.cr_.1.0 3 July 15,1998

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'I /f"D (KFINIT IONSI p The defined terms of t71s section appear in capitalized ty and are appitcable throughout these Technical specifications a 66 3c5 ACTION

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@ ACTION [shall be that rt of a/fartrETTabSpecification rescribes (remdtf1musefep/hquired der el**'-- d ed condition -

As W k us q <&g+*Gd*J e ACTUATION LOGIC TEST

, p An ACTUATION LOGIC TEST shall be the application of various simulatedA t combinations in conjunction with each possible interlock logic state and

@ verification of the required leale output. The ACTUATION LOGIC TEST hall include a continuity checl( as a minimumlof output devices. _ ,

M CHANNEL OPERATIONAL TEST

43MCtf6 CIWetEL OPmrf0NAL4tST) be the injection of a s into the channel as close to th 0 TRM ILITV.oflalarm, interlock and@e sensor trip as practicable to verifyThe(ANALM functions. Ci GT,3& 11 include adjustment as necessary, of the91am, inter-lock a tpoints hat the tpoints are within thelre d range a ccuracy. i <vJ A.1.

AXIAL FLUX DIFFERENCEhAFON

"" (K4 h IFetween the top anG Det

- hall be the difference in normalized flux signals alves Of a two section excore neutron detector.

CHANNEL CALIBRATION

[EL CALIBRATION shall be the adjustment, as necessary, of the

@( ann Dthat it responds within the required range and accuracy to known in . The CHANNEL CALIBRATION shall encospass the entire channel including th senso alam, inter an @ t p function y be A,t reed b ny ser seguential lapping r total channe s ,

( that t attre channel is calibra _

q i,@,) wt/

CHANNEL CHECK . .

@. ACHANNELCHFrfthallbethe[qualitativeassessmen of channel behavior A.I during operatio@y observatianT This detemina on sha 1 lude, where pos-sible arison of the channel indication a status ther indica-tions r status derived from independent instament channels measuring the same parameter.

6 CATAWBA - UNIT 1 1-1 Amendment No. 148 L

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! 6tX AND DEFM W U -

f M 11FINITION$l NET [.

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' ined tenas of this section a ar in capitalfred type and are applicable throughout these Technica Specification ACTION f ACTIC shall be that part of a GM"al Specification cribes emagteD/4quiredyunder designated condition . A 9Q ,

$CTUATION LOGIC TEST

( An ACTUATION LOGIC TEST shall be the appilcation of various simulatedl ~~

l J t combinations in conjunction with each possible interlock logic state and l

(g i fication of the required logic output. The ACTUATION LOGIC TES hall include a continuity checlg as a minimunn of output devices.

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MCHAfstEL OPERATIONAL TEST (Cet) pg

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1.3 An mintui= uuuuan OPERAThmaar my stenal inho the channel as close to I be the injection of a simu edd sensor as practicable to verif f OPERABILI T ofdalarm, interlock a trip functions. The GNAN_""M uwers ar wso shall include adjustments, as necessary, of theglatz, inter-lock'a atthefetpointsarewithinthe} required range pa,7'ripfetpoints accuracy.

AXIAL FLUX DIFFERENCE (AFD) -

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@ artMujurFFEREhc be the difference in nonna1{ zed flux signals between the top and bottom halves of a two section excore neutron detector.

l CHANNEL CALIBRATION

[ (gLe a A CHAfflEl. CALIBRATION shall be the adjustment, as necessary, of the that it responds within the required range and accuracy to known C nput. The CHANNEL CALIBRATION shall encompass the entire channel

; neluding thersensov@ diB alarm, interl ~ an@ trip function say be !

!" a ny serlYs of se vent a erlippineswer total channe isteps

' @performeea that en channel s ai g l CHANNEL CHECK

@ A CHANNEL CHE_CK shall be{the qualitative assessmenQpf channel behavior

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during operation (by ooservauong This determination shall include, where pos-4, J'-

sible, rison of the chanrFel indication an statu other indica-( tiens r status derived from independent i@nstrument nnels measuring the same parameter.

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i CATAWBA - UNIT 2 1-1 Amendment No. 142 I . .

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Discussicn cf Chang:s Section 1.0 - USE AND APPLICATION ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering are in accordance with NUREG-1431. As a result, the Technical Specifications (TS) should be more readily readable, and therefore understandable, by plant operators as well as other users. The reformatting, renumbering, and rewording process involves no technical changes to existing Technical Specifications.

Editorial rewording (either adding or deleting) is made consistent -

with NUREG-1431. During Improved Technical Specification (ITS) )

development certain wording preferences or English language !

conventions were adopted which resulted in no technical changes (either actual or interpretational) to the Technical l Specifications. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1431. Since the design is already approved by the NRC, adding more detail does not result in a technical change.

A.2 Current Technical Specification (CTS) 1.3,1.5, and 1.37 have been revised to add the word " required" to the alarm and sensor l functions. As a requirement for OPERABILITY of a Technical Specification channel, not all channels will have a " required" sensor or alarm. The revised wording in ITS Specification 1.1 more accurately reflects this intent. This change is consistent with NUREG-1431.

A.3 Not Used. The phra',c "cr actual," in reference tc the injected signal, has been added to CTS Specification 1.0 definition; for AGTUATION LOCIC TEST and CHANNEL OPERATIONAL TEST (C0T), ;; an explicit option to the currently required ";imulated" signah-Scmc test; are performed by insertion of the actual signal into the logic. For other;, there i; no reason .;hy an actual signal would preclude satisfactory performance of the tc;t. Use of an actual signal instead of a simulated signal in the ITS 1.1 definition: ..ill not affect the performance of the channel.

OPERABILITY can bc Odequately demonstrated in cither ca:c since the channel it:cif can not discriminate between " actual" cr

" simul ated. " This-change i: consi; tent ,ith NUREC 1431.

A.4 Specific CHANNEL CALIBRATION requirements in CTS 1.5 for

thermocouple or RTDs have been revised. The intent of a CHANNEL CALIBRATION is to adjust the channel output so that the channel l

Catawba Units 1 & 2 Page A-N Supplement 73l

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Discussien of Chang 2s

! Section 1.0 - USE AND APPLICATION l i

TECHNICAL CHANGES - LESS RESTRICTIVE i

L.1 CTS 1.9 definition has been revised to remove the " manipulation of l any component within the reactor pressure vessel" from consideration as a CORE ALTERATION. This change maintains CORE ALTERATIONS as movement of only those components which can affect core reactivity. The basis for this is evident in that the Specifications applicable during CORE ALTERATIONS are those that protect from or mitigate a reactivity excursion event. In keeping ,

, with this, ITS Specification 1.1 provides that movement of l equipment other than fuel, sources, or reactivity control components, are not considered CORE ALTERATIONS. Since other equipment (e.g. cameras, thimble plugs, upper internals) will have i negligible (if any) effect on core reactivity, any movement has essentially no impact on core reactivity. Therefore, the revised definition places no restrictions on movement of equipment other than fuel, sources., and reactivity control components. ' Source range instrumentation is available for monitoring core reactivity and boron concentration is maintained within COLR limita during H0DE 6. This change is less restrictive and is consistent with NUREG-1431.

L.2 Not used.

L.3 The phrase "or actual," in reference to the injected signal, has been added to CTS Specification 1.0 definitions for ACTUATION LOGIC TEST and CHANNEL OPERATIONAL TEST (C0T), as on explicit option to the currently required " simulated" signal. 'Some tests are performed by insertion of the actual signal into the logic.

For others, there is no reason why an actual signal would preclude satisfactory performance of the test. Use of an actual signal

! instead of a simulated signal in the ITS 1.1' definitions will not affect the performance of the channel. This change permits credit to be taken for unplanned events (actual signals) which provide the necessary data to satify the test. The actual signal is what is credited within the safety analysis and is sufficient for l demonstrating compliance with the test. In addition, this change is consistent with NUREG-1431.

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l Catawba Units 1 & 2 Page L - 11 Supplement 73 l l

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ND Significant Hazards Ccnsid;rstien Section 1.0 - Use and Application LESS RESTRICTIVE CHANGE L.3 The Catawba Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431.

The phrase "or actual," in reference to the injected signal, has been added to CTS Specification 1.0 definitions for ACTUATION LOGIC TEST and CHANNEL OPERATIONAL TEST (C0T), as an explicit option to the currently required " simulated" signal. Some tests are performed by insertion of the actual signal into the logic.

For others, there is no reason why an actual signal would preclude satisfactory performance of the test. Use of an actual signal instead of a simulated signal in the ITS 1.1 definitions will not affect the performance of the channel. This change permits credit to be taken for unpIanned events (actual signals) which provide the necessary data to satify the test. The actual signal is what is credited within the safety analysis and is sufficient for demonstrating compliance with the test. In addition, this change is consistent with NUREG-1431.

In accordance with the criteria set forth in 10 CFR 50.92, the Catawba Nuclear Station has evaluated this proposed Technical Specifications ~

change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed changes permits the use of unplanned events in addition to simulated signals to be credited in the performance of the test. The initiation signals associated with testing are not considered initiators of any analyzed event. Therefore, the probability of an accident previously evaluated is not significantly increased. The proposed change does not reduce the performance requirements or acceptance criteria for the systems or components, therefore, the consequences of analyzed events are not offected.

Catawba Units 1 and 2 Page 867 of 1249 % Supplement 735l20/97l

N2 Significant Hazards Crnsidsratien Section 1.0 - Use and Application

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not permit operation in a new or different mode, or permit the installation of a new or different type of equipment. The proposed changes provides the allowance to use an unplanned actuation signal in addition to simulated signals in the performance tests. The affected systems and components remain capable of performing their design safety functions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from those previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change continues to require the same performance and acceptance criteria assumed within the safety analysis for these systems and components. The ability to credit unplanned events in l the performance of tests does not affect these assumptions.

Therefore, this change does not involve a significcat reduce a margin of safety.

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Catawba Units 1 and 2 Page 967 of 12MM Supplement 735/20/07l L__.____________ __ _ _ _ _ . . _ _ .__ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _._______..____._.__________._____._.____m

I McGuire & Catawba improved TS Review Comments ITS Section 3.1, Reactivity Control Systems 3.1 Additionalitems 3.1-02 DOC LA9 in review comments for several sections, the NRC has identified that the deletion of requirements which are redundant to regulation should be classified as less restrictive changes rather than removal of detail changes. Therefore, DOC LA9 is deleted and replaced by DOC L14 to be consistent with other changes made to other sections and to eliminate the relocation of a requirement to a procedure.

mc5_cr_3.1 3.1-12 July 15,1998 L 1

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.3.lREACTIVITYCONTROLSYSTEMS 586C 8 Af4Tsen 3.l.3 MODERATOR TEMPERATURE COEFFICIENT C L I M I T uni CON 0 l T I Qikf 0R OPERA T I GID

( C.0 3.1.j p The moderator temperature coefficient (MTC) shall be within the lini

.s specified in the "- "" -- > =i utrunujCOLR)? The maximum upper limit shall be less than or equal to that shown in Figure 3.lt3ft _

Ad v.. ,u . b

,,a.w u A, APPLICABILITY: &ic uree. a-u an- =u r u um . r e mite - MODES 1 and '*

(Enc oT C3cTe Life (Effli Liatt3 MODES 1, 2, and 3gg ACTI .i &ene W6.

wwSJ% wppv]

MmA a. ciarin. MTC r. e .iei . - <n. iinittsp ttrefwyr, comrat-p "N! =do nav nroyenrnvidj,. i op Q l A.1.

Control red withdrawai limits are established and maintained sufficient to restore the MTC to less positive than the Itall l

Aem8 J unec3riet in usure 1 ortne wyvwithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be infW A,a AR Assess)f thin the next 6 hourt/ Inese wit awal I tat ts s y

. [h e in acasuen to tne inseJoeion limits 'of ification 3.Y.3.6; 487

<o Lz. ~The control are maintained hin the withdrawal imi 7 established we until a subse ent calculation ve les that Ai the MTC ha been restored to w' hin its limit for ylthdra condition; and all rods 3 A Special Repo s prepared and baitted to the C ssi pursuant to S ification 6.9.2 thin 10 days, des ibing the

g value of the limits, and asured MTC, the terim control rod ithdrawal e predicted ave ge core burnup nec ssary for restoring e positive MTC t within its limit f r the all rodsj withdrawn ondition. _ .

w ws er) l h t nrw Q Ot.~ Metn me, MTC mori Aruative r*8K the EUD' limit s!Fecif ted irThe CODb -

be in HQI swivuwigwithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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@th K greater than or equal to 1

b M ' 77 CF5ee Special/fest Exceptigspecificaticp(3.10.32 CATAWBA - UNIT 1 3/4 1 4 Amendment No. 148

l f MI&WW 3 ,i REACTIVITY CONTROL SYSTEMS *

Lt.3M00ERATOR TEMPERATURE COEFFICIENT ((mrch CUMIIING Court a lon tor 39tfATIon }

. LCO 3.1.Q3 The moderator temperature coefficient (MTC) shall be within the limits spectfled in the p or _ __ ._ _

uj COLR V The maximum .

upper limit shall be less than or equal to that shown in Figure 3.1 i Wm m-.o ,11. k,tt?],, ,

OA,l APPLICABILITY: iour#3.1-0 and COLR petJure ! L1 mets 3M00E51 and l nd of Cycle M re stuu Limif_->nuu n I, 2, and 3, w,m tw. ,

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/}cen A dtFEWEh MT_ _invoositive *=z +% limitjpectyed the,rutu. ooeration sivuts a sna mw procesti provid in ti re i st' l l'

A ,1. Control rod withdrawal limits are established and maintained A'i sufficient to restore the MTC to less positive than the 11 ,q g,m 4.c v an in nmrre i of r-tutowithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in

.J e t.m tenr7within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .E ese wit wel limits s

"'7 *%e ~n aani.seen to tne inser:s<wn 14=4+e af acificatian .3. . A,7

. The control r ds are maintaine within the wi wal limits 7

. established bove untti a sub quent calcula n verifles that to , the MTC h been restored t within its lim for the all rods 9 iwithdra conotti- : and e

3. A Special Rep is prepared an submitted to the ' amtssi pursuant to specification 6.9. within 10 days, d cribing the value of t measured MTC, t interim control r d withdrawal :

limits, d the predicted a rage core burnup cessary for I restori the positive MTC o within ite timi for the all rodC ,

d udthdr condition.1- 9 2,., q Acyvn C 6 pfh th3 MTCag re neoefive thaefh? EUDllimit EUecified Wthe LULO 4,(

be in aun sHOICOWrowithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . i

@$*4

D

- b C Fith K g areater than or equal to (ffee Special)'est ExceDtiOffs Specificati4n 3.10.g/1,II) _

CATAWBA - UNIT 2 3/4 1-4 Amendment No. 142 f9 5Y

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Discussign of Chang 2s l Sscticn 3.1 - Rsactivity C:ntrol Systems )

t LESS RESTRICTIVE CHANGES head removal. Requirements for post modification or post maintenance testing are controlled by procedures and the requirement to verify operability prior to returning equipment to service. Specific requirements are not necessary for inclusion within the TS and are inconsistently applied within the CTS. The 18-month frequency is somewhat redundant to the head removal frequency and is not necessary. The normal refueling cycle is 18 months at which time the head is removed and the surveillance would be required to be per'ormed. Should an extended mid-cycle outage occur, the 18 month frequency could be reached first, however, in the absence of any head removal, there would be no physical reason to reverify these times. This change is consistent with NUREG-1431.

L.13 CTS SR 4.1.3.3 requires verifying digital rod position agreement with the group demand counters every 18 months. ITS SR 3.1.7.1 only requires this verification following head removal. The normal refueling cycle is 18 months at which time the head is removed and the surveillance would be required to be performed.

Should an extended mid-cycle outage occur which did not involve a head removal, it is possible that the 18 month frequency, plus the extensions allowed by SR 3.0.2, could be reached first. However,

'in the absence of any head removal, there would be no physical reason to believe that the position indicators and demand counters would not be in agreement. Mid-cycle outages involving head removal would require this surveillance be performed more frequently than the existing 18 month frequency. This change is consistent with NRC approved TSTF-89 to NUREG-1431.

L.14 The CTS 3.1.1.3 Action a.3 requirement to submit a special report to the NRC in the event that MTC exceeds the upper limit is deleted. The 10 CFR 50.72 and 10 CFR 50.73 requirements clearly identify notifications and reports to be made to the NRC. If a condition were discovered that met the criteria within these regulations, such as on unanalyzed condition or condition outside the design basis, a report would be required. The deleting of the special report in this specification does not change the requirement within the regulations for reporting significant issues to the NRC as defined by the regulation. This change is consistent with NUREG-1431.

I Catawba Units 1 and 2 Page L - 5 Supplement 75/20/97l

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Discussien of Chcnges Secticn 3.1 - R2 activity Central Systems TECHNICAL CHANGES - REMOVAL OF DETAIL are evaluated under the 10 CFR 50.59 criteria. Any change using this criteria will be appropriately reviewed. This change is consistent with NUREG-1431.

LA.7 Not used.

LA.8 Not used.

LA.9 Not used.The CTS 3.1.1.3 fction 2.3 requirement tc : bmit a special report to the NRC in the ever,t that MTC exceed; th^ upper 3, 4,4. .- . 4... . s_,._._;

. .. r. . u. - i.n....r en. .e n. . ,,o . - _. .;. e

.. n r en,. . .. e n. . , .,,___.4._.__..__., . y. . . . . . .

clearly identify notification; and report; te bc made to the NRC.

If a conditicn werc di;eevered that =ct the criteria within the:c r^gulations, ; report would be required. The deleting cf the special report in thi; specificaticr, dce; not change the requir ment within the regulation; fer reporting to the N"C Report; to the NRC are controlled by plar,t pr ccdure: chich implemer,t the regulaticas. Thi; change 1: consistcr,t with NUREC 44 h LA.10 CTS 3.1.3.1 action c allows power operation to continue with one rod not within alignment limits provided the misaligned rod is restored to limits in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (action c.1) or the other rods in the group are moved within the alignment limits (c.2). ITS 3.1.4 only requires that the alignment limit be restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternatives of how the limit is restored are not necessary for inclusion within the TS and are relocated to the Bases for ITS 3.1.4. The Bases are subject to the controls specified in ITS 1

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1 Catawba Units 1 and 2 Page LA - 3 Supplement 47l i

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i N3 Significant Hazards C:nsid2ratien SIctien 3.1 - Reactivity Control Systems LESS RESTRICTIVE CHANGE L.14 The McGuire Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse P.lants." The proposed change involves making the current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431.

The CTS 3.1.1.3 Action a.3 requirement to submit a special report to the NRC in the event that MTC exceeds the upper limit is deleted. The 10 CFR 50.72 and 10 CFR 50.73 requirements clearly identify notifications and reports to be made to the NRC. If a condition were discovered that met the criteria within these regulations, such as an unanalyzed condition or condition outside the design basis, a report would be required. The deleting of the special report in this specification does not change the requirement within the regulations for reporting significant issues to the NRC as defined by the regulation. This change is consistent with NUREG-1431.

In accordance with the criteria set forth in 10 CFR 50.92, the McGuire Nuclear Station has evaluated this proposed Technical Specifications change and determined if does not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change deletes a special report from Technical Specifications which is already adequately bounded by reporting requirements in the CFR. Reporting requirements are not an initiator of any analyzed event, therefore, the proposed change does not offect the probability of any analyzed accident. The safety analysis assumptions associated with analyzed events are not affected by the source Iocation of regulatory reporting l requirements, therefore, the consequences of analyzed events are not changed.

I Catawba Units 1 and 2 Page 30 of 30 M Supplement 75/20/7 l L

C_.__-___________ - _ . - _ - . - . - -

N3 Signific::nt HIzards C:nsidercticn S:ction 3.1 - Reactivity Control Systems

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The change will not physicolly alter the plant (no new or different type of equipment wilI be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed changes delete requirements from Technical Specifications which are already adequately bounded by reporting requirements in the CFR. The changes do not reduce the margin of safety since the requirements to maintain the required limits are not changed.

)

i l

l Catawba Units 1 and 2 Page 31 of 31M Supplement 75/20/97l L _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _

1 McGuire & Catawba improved TS Review Comments i ITS Section 3.2, Power Distribution Limits 3.2.4-10 (Catawba only) DOC M.7 CTS 4.2.4.1.c ITS SR 4.2.4.1 Note 3 i

CTS 4.2.4.1.c states that the provisions of Specification 4.0.4 are not applicable. Note 3 of corresponding ITS SR 4.2.4.1 states that the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after exceeding 50 % RTP. DOC M.7 does not provide a specific justification for the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ;

allowance. The change is not more restrictive since the note does not place any restriction at all on plant operation. How is the proposed change consistent with the STS? Comment:

Revise the submittal to provide the justification for the proposed change or revise the subrnittal to conform with the STS. '

DEC Response (REVISED):

The Mode of Applicability of CTS 3.2.4 is Mode 1 above 50% RTP. The 4.0.4 exception in the CTS would allow power to be increased above the mode of applicability prior to performing CTS 4.2.4.1. The CTS would allow power to be increased to RTP and the surveillance would not have to be performed until the first scheduled frequency, i.e.,7 days. .

The proposed note in ITS 3.2.4.1 maintains the current 4.0.4 allowance to increase power I above the mode of applicability without performing the SR, however, it places a limit on how long the unit may operate before the SR must be met (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). This requirement is much j more restrictive than the current non-specific 4.0.4 allowance. The time limit of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months was i selected based on the time required for radial power distributions to dampen out after 50%

! l power is reached. DOC M.7 has been revised to provide a justification for the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to remove the statement that the change is consistent with the NUREG.

mc4_cr_3.2 3.2-20 July 15,1998 l

______________________L._._______ ___;

l Discussien of Changes l Section 3.2 - Power Distribution Limits TECHNICAL CHANGES - MORE RESTRICTIVE M.1 If the actions of CTS 3.2.2 could not be completed in the required I time, on entry into LC0 3.0.3 would be required and a shutdown to {

MODE 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months would become applicable. ITS 3.2.1 provides a j specific action for this condition which requires placing the unit in MODE 2 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This addition is more restrictive because ]

i it requires the plant to be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , whereas CTS LC0 3.0.3 would allow an additional hour before starting to shutdown to MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This change is consistent with NUREG-1431.

M.2 CTS 4.2.2.2.b.2 and 4.2.3.2.b.1 require verification of hot channel factors after reaching equilibrium conditions following power changes greater than 10% from when these factors were last determined. ITS SR 3.2.1.1, 3.2.1.2, 3.2.1.3, 3.2.2.1, and 3.2.2.2 require this verification within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reaching equilibrium conditions. This addition is more restrictive since the CTS does not currently address how long the unit may operate at equilibrium conditions before the SR is completed. This change l is consistent with NUREG-1431. ,

i M.3 Not used.

M.4 Not used.

M.5 The QPTR limit of 1.09 in CTS 3.2.4 action a has been deleted.

ITS 3.2.4 bases all required actions on QPTR in excess of 1.02, rather providing increased actions at increasing intervals of QPTR. Therefore, this change is considered slightly more restrictive. This change is consistent with NUREG-1431. Other less restrictive changes are discussed in these Discussion of Changes.

M.6 Not used.

M.7 The CTS 4.2.4.1.c exception to Specification 4.0.4 has been replaced. ITS SR 3.2.4.1 includes a note which allows up to 17.

hours to perform the surveillance after exceeding 50% RTP. This change is considered more restrictive since the CTS would allow up ;

to 7 days prior to performing the SR. The proposed note in ITS ;

3.2.4.1 maintains the current 4.0.4 allowance to increase power '

l Catawba Units 1 and 2 Page M - 1 Supplement 47l 1

Discussicn cf Ching s Section 3.2 - Power Distribution Limits )

TECHNICAL CHANGES - MORE RESTRICTIVE i i

1 above the mode of applicability without performing the SR, d however, it places a limit on how long the unit may operate before j the SR must be met (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ). The time limit of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months was j selected based on the time required for radial power distributions to dampen out after 50% power is reached and is a reasonable time to perform the required surveillance. Radial powcr distribution:

at 50': RTP are considerably different than radial powcr at 100':

RTP. A minimum cf S hcur; i; required at typical leading rate:

(10': per Scur between 50*: and 90*: RTP and le;; than 3*: per hour abcvc 00' RTP) to increase pcwcr frc= 50*: tc 100*: RTP, leaving i heur; tc perfc n the required surveillance. i M.8 The CTS 4.2.4.1.b frequency of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months has been revised to once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This I change, retained in ITS SR 3.2.4.1, is slightly more restrictive since~the 25% frequency extension does not apply to "once within" ;

frequencies whereas the extension would apply to the CTS. This l change is consistent with NUREG-1431. '

l l

I Catawba Units 1 and 2 Page M - 2 Supplement 17l L

1

! McGuire & Catawba improved TS Review Comments ITS 3.3.2, Engineered Safety Features Actuation System (ESFAS) Instrumentation l

3.3.2-05 ITS Table 3.3.2-1, Function 4.a. b, c, & d, Applicability, footnote (b)

STS Table 3.3.2-1, Function 4, a, b, c, & d, Applicability, footnote (b)

DOC A.29 CTS Table 3.3-3, Functional Unit 4.a. b, c & d ITS Table 3.3.2-1, Note (b) provides an exception to the applicability of the requirements to Modes 2 and 3 when all MSIVs are closed and de-activated, consistent with STS. DOC A.29 says this is consistent with CTS, However, the CTS did not originally contain this exception.

Comment: Revise the submittal to justify this less restrictive change.

DEC Response: '

The CTS does contain this exception but in a different form. The plant Systems Section of the CTS contains the system level requirements for the MSIVs. As stated in DOC A.29, the CTS 3.7.1.4 Actions contain an explicit allowance for operation to continue in Modes 2 and 3 provided the inoperable MSIV is closed. The addition of the ITS Note providing a similar I allowance to the applicability of the associated instrumentation for the MSIVs is considered a clarification of the existing Plant System Action requirements for the MSIVs. If continued )

operation in Modes 2 and 3 is permitted when an inoperable MSIV is closed, the supporting !

instrumentation which automatically closes the affected MSIV is also no longer required. This I change makes the CTS requirements internally consistent between the system level and i supporting instrumentation for the MSIVs. This type of clarification / consistency issue is considered administrative. No further justification or change is required.

REVISED RESPONSE:

DOC A29 is deleted and replaced by DOC L33 to identify this change as less restrictive.

i l

l' l

mc5_cr_3.3 yg July 14,1998 )

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ . _ - - _0

McGuire & Catawba improved TS Review Comments ITS 3.3.2, Engineered Safety Features Actuation System (ESFAS) Instrumentation l 3.3.2-06 ITS Table 3.3-3, Function 5 i: CTS Table 3.3-3, Functional Unit 5 STS Table 3.3.2-1. Function 5 DOC A.32 I

Tha Applicable Modes for ITS Table 3.3.2-1, Function 5 contains a footnote (e), that was not in the corresponding CTS Table 3.3-3, Functional Unit 5. This added footnote was adopted from STS Table 3.3.2-1, Functions 5. The footnote states, "Except when all MFIVs, MFRVs and associated bypass valves are closed and de-activated or isolated by a closed manual valve." DOC A.32 provides an explanation about why this change is acceptable. DOC A.32 states, "...this change is administrative in nature ...." This change is a less restrictive change

- because the CTS did not contain this exception. Comment : Revise the submittal to provide the appropriate justification for the proposed change.

DEC Response:

The ESFAS Main Feedwater isolation instrumentation provides an automatic close signal to the Main Feedwater system valves to isolate the feedwater system. The change addressed in DOC A.32, discussed above, provides a clarification which is consistent with the manner in

. which most isolation valves are treated in the CTS and ITS. That is, if the system can be adequately isolated (safety function of isolation valve performed), continued operation is permitted. Once the Sedwater system is isolated, the ESFAS isolation instrumentation is no longer required. This type of change is considered an administrative clarification of existing requirements consistent with the requirements for other isolation valves in the TS. No additional justification or change is required.

REVISED RESPONSE: I DOC A32 is deleted and replaced by DOC L34 to identify this change as less restrictive.

)

i i

mc5. cr._3.3 20_ July 14,1998

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--+m A A.29 Not used..a. . . . . . 4. e.

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A.30 The Turbine Trip and Feedwater isolation functions in CTS Table 3.3-3, 3.3-4, and 4.3-2 have been combined in ITS 3.3.2. The Bases for ITS 3.3.2 identifies which actuation signals are unique and which are common to both the turbine trip and feedwater isolation signals. This change is considered administrative and is consistent with NUREG-1431.

A.31 CTS Table 3.3-2, Action 21, has been split to accommodate the difference in applicability for the associated functions. The CTS action requires the plant to shutdown to mode 4 when actions are not met, however, some of the functions which refer to this action are only applicable in modes 1 and 2. ITS 3.3.2 maintains the existing requirements but only requires the plant to shutdown below *he mode of applicability for the associated inoperable function. This change is administrative in nature and is consistent with NUREG-1431.

+-

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l. e. ..AAaA. . m. +.. u. ,a.r_ r 3 4.. ,., . u s i, a .u.nn e. e, a t, + . u. . a Feedwater Isclation Fur.cticr,s of CTS Table 3.3-3 ,;hich exempts

+

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. m. . .A,.a.. - , 4. e. + a .. m. +. o. 4. + L,. . , M.f.f n_rP 1 .A,, S,1 .

i f

l Catawba Units 1 and 2 Page A - 9 Supplement 76 l j

Discussicn of Chang;s Section 3.3 - Instrumentation TECHNICAL CHANGES - LESS RESTRICTIVE L.33 CTS Table 3.3-3 function 4, " Steam Line Isolation," requires the function to be operable in MODES 1, 2, and 3. ITS Table 3.3.2-1 exempts this function in MODES 2 and 3 when all MSIVs and associated bypass valves are closed and deactivated. When these valves are all closed and deactivated, the safety function is being performed and the automatic isolation function is no longer necessary. This change is less restrictive with respect to instrumentation requirements however, it is consistent with the existing actions of CTS 3.7.1.4, for the MSIVs. Therefore, this change is also considered acceptable because it maintains consistency between existing requirements. This change is consistent with NUREG-1431.

L.34 CTS Table 3.3-3 function 5 requires the feedwater isolation functions operable in MODES 1 and 2. ITS Table 3.3.2-1 exempts these functions in MODE 2 when all MFIVs, MFCVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve. When these valves are closed, the safety function is being performed and the automatic isolation function is no longer necessary. This change is less restrictive with respect to instrumentation requirements however, it maintains consistency with proposed ITS 3.7.3 for the valves which contains similar wording in its Applicability. This change is consistent with NUREG-1431.

l Catawba Units 1 and 2 Page L - 13 Supplement 76l l'

w _-_ -_ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ . - _ _ _ _ _ - - _ . _ _ _ _ _ __ _. _ __ ______ _- -

i ND Significant Hazcrds C nsidsration Section 3.3 - Instrumentation l

l LESS RESTRICTIVE CHANGE L.33

\

i, The Catawba Nuclear Station is converting to the Improved Technical l Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves l

making the' current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431.

CTS Table 3.3-3 function 4, " Steam Line Isolation," requires the function to be operable in MODES 1, 2, and 3. ITS Table 3.3.2-1

! exempts this function in MODES 2 and 3 when all MSIVs and associated bypass valves are closed and deactivated. When these volves are all closed and deactivated, the safety function is being performed and the automatic isolation function is no longer necessary. This change is less restrictive with respect to instrumentation requirements however, it is consistent with the existing actions of CTS 3.7.1.4, for the MSIVs. Therefore, this change is also considered acceptable because it maintains consistency between existing requirements. This change is consistent with NUREG-1431.

In accordance with the criteria set forth in 10 CFR 50.92, the Catawba Nuclear Station has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change removes the requirement for automatic actuation when the associated valves are closed and deactivated.

This change will not offect the probability of an accident. The change continues to require the specific plant equipment to remain operable unless the valves are closed and deactivated. When the valves are closed and deactivated, they are performing the assumed safety functton. Therefore, this change will not involve a significant increase in the probability or consequence of an accident previously evaluated.

Catawba Units 1 and 2 Page 66 of 66M Supplement 76 l

I N3 Significant Htzards Ccnsidsratien

!- ~

Section 3.3 - Instrumentation I

2.. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change ipvolve a significant reduction in a margin of safety?

l The margin 'of safety is not offected by this change. The proposed 1 change does not alter the TS requirement for this instrumentation to be operable to close on open valve. The change only removes the operability requirement for automatic actuation when ali of the associated valves are closed and deactivated. The applicable safety analysis assumptions continue to be maintained in a similar manner as before, therefore, the change does not involve a l significant reduction in a margin of safety.

(

l l

l'

. Catawba Units 1 and 2- Page 67 of 6773 Supplement 76 l.

- _ _ _-___-____=___-_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ - _ - _ _ _ _ - _ _ _ _ - .

N3 Significant Hazards C:nsid::ratien Section 3.3 - Instrumentation LESS RESTRICTIVE CHANGE L.34 The Catawba Nuclear Station is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed change involves making the current Technical Specifications (CTS) less restrictive.

Below is the description of this less restrictive change and the No Significant Hazards Consideration for conversion to NUREG-1431.

CTS Table 3.3-3 function 5 requires the feedwater isolation functions operable in MODES 1 and 2. ITS Table 3.3.2-1 exempts these functions in MODE 2 when all MFIVs, MFCVs, and associated bypass vilves cre closed and de-activated or isolated by a closed manual volve. hhen these valves are closed, the safety function is being performed and the automatic isolation function is no longer necessary. This change is less restrictive with respect to instrumentation requirements however, it maintains consistency with proposed ITS 3.7.3 for the valves which contains similar wording in its Applicability. This change is consistent with NUREG-1431.

In accordance with the criteria set forth in 10 CFR 50.92, the Catawba Nuclear Statton has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

The proposed change removes the requirement for automatic actuation when the associated volves are closed and deactivated.

This change will not offect the probability of an accident. The change continues to require the specific plant equipment to remain operable unless the volves are closed and deactivated. When the valves are closed and deactivated, they are performing the assumed safety function. Therefore, this change will not involye a significant increase in the probability or consequence of an accident previously evaluated.

r Catawba Units 1 and 2 Page 68 of 6BM Supplement 76l

_ _ . _ _ _ _ - _ _ _ _ _ _ - . - . _ _ _ _ __ .- _]

No Significant Hazards C:nsid;ratien

, Section 3.3 - Instrumentation l 2. Does the change create the possibility of a new or different kind i

of accident from any accident previously evaluated?

This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does l not create the possibility of a new or different kind of accident i from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The margin of safety is not affected by this change. The proposed change does not alter the TS requirement for this instrumentation to be operable to close an open valve. The change only removes the operability requirement for automatic actuation when all of the associated valves are closed and deactivated. The applicable safety analysis assumptions continue to be maintained in a similar

manner as before, therefore, the change does not involve a significant reduction in a margin of safety.

l I

i l

l Catawba Units 1 and 2 Page 69 of 6973 Supplement 76l i_

I McGuire & Catawba improved TS Review Comments ITS Section 3.4, Reactor Coolant Systems 3.4.1, RCS Prer,sure Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits 3.4.1-01 DOC A.7 CTS ' 4.2.5.3 l JFD 6 STS SR 3.4.1.1 and associated Bases The requirement to conduct an 18 month surveillance to determine total RCS flow rate, CTS 4.2.5.3, has not been retained in the ITS 3.4.1 SRs. DOC A.7 states that this was a "left-over" requirement from a previously deleted requirement to perform a precision heat balance to determine RCS total flow. Justification is not clear why is this requirement should not be retained in the Technical Specifications. Comment: This is a change to both the CTS and STS, and is therefore beyond the scope of the STS Conversion effort; a technical review is necessary. Provide sufficient justification for a review, or retain the SR.

DEC Response:

Amendments 128 to Facility Operating License NPF-35 and 122 to Facility Operating License NPF-52 dated February 17,1995 changed this surveillance requirement to eliminate the reference to " precision heat balance" when referring to the measurement of the total flow rate l each 18 months. The remaining surveillance required the Reactor Coolant System total flow rate to be determined by measurement at least once per 18 months. This " measurement" is accomplished using the installed flow indicators. The total flow rate is " measured" and confirmed to be within the limits specified in Figure 3.4.1-1 every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in SR 3.4.1.3.

Since the measurement of the total flow rate every 18 months is performed the same way that the flow rate is determined for the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months surveillance, the 18 month surveillance is redundant and is deemed unnecessary.

REVISED RESPONSE: l l

The applicable CTS amendments associated with this change for McGuire are Amendments l 153 to Facility Operating License NPF-9 and 135 to Facility Operating License NPF-17 dated l January 12,1995. This information was inadvertently omitted from the previous response. l l

I t

mc4_cr_3.4 1 July 14,1998 I

i McGuire & Catawba improved TS Review Comments ITS Section 3.5, Emergency Core Cooling Systems l 3.5.1-03 DOC L.1 -

CTS 3.5.1.e .

CTS 4.5.1.1.2 CTS 3.5.1.e requires that a water level and pressure channel be' Operable for each '

accumulator. CTS 4.5.1.1.2 provides the Surveillance Requirements for these instrument channels. These requirements have not been adopted in corresponding ITS 3.5.1 in conformance with the STS and are being deleted from the CTS. Comment: These requirements are important enough to be maintained in a licensee controlled document.

Revise the submittal to move these requirements to a location with appropriate change control, for example, the SLC.

DEC Response:

DEC disagrees that additional control of these instruments is required outside of the technical specifications. The requirement of concem is the quantity of water and nitrogen pressure l within each accumulator. There are a number of ways of determining compliance with this requirement. This may include using the installed instrumentation, or it may include me use of L portable test equipment. Existing controls already ensure that equipment used to determine

surveillance limits are appropriately calibrated. It would be an uneccessary administrative

j. burden to add an additional layer of control for these specific instruments when they are not required nor may not even be used to determine compliance with the TS limit. There are large numbers of instrumentation used throughout the plant to determine that various limits

'are within acceptance criteria. These instruments are adequately controlled without being included within the SLC.

- REVISED RESPONSE:

l. The staff indicated during the comment resolution meeting that the proposed response was not acceptable and that the instruments must be relocated to the SLC. DEC disagrees. The proposed instruments do not perform a safety function and are provided for indication. These

~

l indicators are also not required as category 1 or type A post accident monitoring variables.

p Therefore, these instruments do not meet any of the criteria established in 10 CFR 50.36.

14 . The staff position that the instruments be maintained in a licensee controlled document is already met by their. inclusion within plant calibration procedures. The addition of these t

instruments to the SLC does not establish any additional control because no actions would be required when the instruments were inoperable. The addition of these instruments would

!, create an additional administrative burden on the plant staff by adding an unecessary-

. additional control document. A statement is added to the Bases for the volume and pressure l 4 surveillance to indicate that these SRs are typically performed using these installed control l room indicators. This change was discussed with the NRC during the second comment l resolution' meeting July 9,1998.- l

- mc5 cri3.5 - 3 July 14,1998

Accumulators B 3.5.1 BASES ACTIONS 'mil and C.2 (continued) 12 L9urs. T1e allowed Completion Times are reasonable, based on ope 6 ting experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

L1 If more than one ac:umulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator valve should be verified to be fully open every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than fully open. If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a motor operated valve position should not change with power removed, a closed valve could result in not meeting accident analyses assumptions.

This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely.

SR 3.5.1.2 and SR 3.5.1.3 Every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , b9 rated water volume and nitrogen cover pressure are verified for each accumulator. This is typically performed using the installed control room indication. This Frequency is sufficient to ensure adequate injection during a LOCA. Because of the static design of the accumulator, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency usually allows the operator to identify changes before limits are reached. Operating experience has shown this Frequency to be appropriate for early detection and correction of off normal trends.

l (continued)

Catawba Unit 1 B 3.5-7 Supplement 7 l

{

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_ _ _ _- -_ _ _ _ _ = . . _ _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _

Accumulators B 3.5.1 BASES ACTIONS C.1 and C.2 (continued) l 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions'from full power conditions in an orderly ma'iner and without challenging plant systems. j lb.1 If more than one accumulator is inoperable, the plant is in a condition outside the accident analyses; therefore, LC0 3.0.3 )

must be entered.immediately. 1 SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator valve should be verified to be fully open ,

every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This verification ensures that the :

accumulators are available for injection and ensures timely '

discovery if a valve should be less than fully open. If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a motor operated valve l position should not change with power removed, a closed valve could result in not meeting accident analyses assumptions.

This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation ;

valve is unlikely. <

SR 3.5.1.2 and SR 3.5.1.3 Every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , borated water volume and nitrogen cover pressure are verified for each accumulator. This is typically performed using the installed control room indication. .This. )

Frequency is sufficient to ensure adequate injection during a

, LOCA. Because of the static design of the accumulator, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency usually allows the operator to identify changes before limits are reached. Operating experience has shown this Frequency to be appropriate for early detection and 4 l

correction of off normal trends.

(continued)-

Catawba. Unit 2 B 3.5-7 Supplement 7 l l

l ._ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

Accumulators l B 3.5.1 l

BASES ACTIONS C.1 and C.2 (continued)

s;1000 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the l

' required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

L1

' If more than one accumulator is inoperable the plant is in a condition outside the accident analyses: therefore. LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator valve should be verified to be fully open every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than fully open. If an isolation valve is not fully open. the rate of injection to the RCS would be reduced. Although a motor operated +alve position should not change with power removed, a closed valve could result in not meeting accident analyses asstaptions.

This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely.

SR 3.5.1.2 and SR 3.5.1.3 b c ,

Every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , borated water volume and nitrogen' cover J (# a pressure are verified for each accumulator.YThis Frequency is N. A . h'.

P %g us, h.

sufficient to ensure adequate injection during a LOCA.

Because of the static design of the accumulator, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

~

i f y " y( "A*t !

i d-'"p"- i Frequency usually allows the operator to identify changes j before limits are reached. Operating experience has shown '

this frequency to be appropriate for early detection and correction of off normal trends.

(continued) l % B 3.5 7 ,

Rev 1. 04/07/95 64(*2&bd

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L______________----_--._---_-----------

i McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.1 -2 DOC A.3 DOC LA.1 JFD 6 JFD Bases 6 CTS 4.6.1.1.c CTS 3.6.1.2.a. b, and c CTS 4.6.1.2.d '

CTS 4.6.1.2.d. 3)

CTS 4.6.1.2.e, h, and i CTS 4.6.1.6 STS SR 3.6.1.1 -

ITS SR 3.6.1.1 ITS B3.6.1 Bases CTS 4.6.1.1.c, 3.6.1.2, 3.6.1.2 ACTIONS,4.6.1.2 and 4.6.1.2c, d, e, f, g, h and i specify various leak rate testing requirements and criteria for containment. CTS 4.6.1.6 specifies visual examinations to be performed on the containment vessel. STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to TSTF 52. The STS is based on 10 CFR 50 Appendix J Option A while the ITS is based on 10 CFR 50 Appendix J Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher 1. Grimes to Mr. David J.

Modeen, NEl dated 11/2/95 and TSTF 52 as modified by staff comments. The ITS changes are not in conformance with the letter and TSTF 52 as modified by staff comments. In particular, Amendments 173 and 155 for McGuire Units 1 and 2 respectively and Amendments '

144 and 138 for Catawba Units 1 and 2 respectively only approved 10 CFR 50 Appendix J Option for the Type A tests only. The Type B and C tests must still be done in accordance with Option A. Thus, only those leakage tests associated with Option B Type A test may be relocated to the Containment Leakage Rate Testing Program. This includes CTS 3.6.1.2.a,

. CTS 3.6.1.2 ACTION a, 4.6.1.2,4.6.1.2.c and 4.6.1.2.i with regards to Type A tests only. All other CTS requirements specified above including CTS 4.6.1.2.1 must be retained in the ITS as SRs or Notes to the SRs. Comment: Licensee to update submittal with regards to 11/2/95 ;

letter, TSTF 52 as modified by staff comments and the above comments or provide additional justification for deviations.

DEC Response: l CTS 4.6.1.1.c is redundant to the requirements in 10 CFR 50, Appendix J, Option A, Ill.D.2.

DOC L.33 is added to justify the deletion of this detail. ITS SR 3.6.1.1 is revised to address Type A testing and inspections and new ITS SR 3.6.1.2 is added to capture the Type B and C testing consistent with CTS 3.6.1.2.b,4.6.1.2.d,4.6.1.2.d.2 (McGuire),4.6.1.2.d.3 (Catawba),

4.6.1.2.d.4 (McGuire), 4.6.1.2.h,4.6.1.2.1 (Catawba), and 4.6.1.2.] (McGuire). CTS 4.6.1.2.1 for McGuire is relocated to the Bases. CTS 4.6.1.2,4.6.1.2.c, and 4.6.1.6 are part of the scope of the Type A testing performed pursuant to Option B and are not changed. Discussion of Changes A.3 and LA.1 have been revised accordingly. ITS 5.5.2 is also revised to match.

mc5,cr_3.6 3.6-2 July 14, 1998 t

McGuire & Catawba Improved TS Review Comunents ITS Section 3.6, Containment Systems REVISED RESPONSE:

During the comment resolution meeting with NRC June 17,1998, a number of consistency issues were identified which are discussed below.

1. (McGuire Only) The CTS markup and STS markup for SR 3.6.1.2 were not consistent with the typed ITS, Note 2 was missing from the STS markup and the second paragraph of the surveillance was missing from the CTS markup. These markups have been corrected.

2. . (McGuire Only) The CTS markup for CTS 4.6.1.2.d.4 and 4.6.1.2.1 are relocated moved to the Bases and the changes justified by LA1. DOC LA1 only describes changes moved to the Containment Leakage Rate Testing Program, not the Bases. New DOC LA28 has been added to justify the movement of this detail to the Bases and LA1 has been revised accordingly.

3. References to airlock testing and exemptions not being required in TS should be deleted from DOC LA1. DOC LA1 has been revised to delete these discussions.

4. (McGuire Only) The STS markup and CTS markup for SR 3.6.1.1 are inconsistent.

The reference to airlock testing has been deleted from the STS markup.

5. Bases references to 10 CFR 50, Appendix J, on pages B 3.6-1 does not specify the applicable Appendix J option. This statement is revised to include option B for SR 3.6.1.1 and add option A for SR 3.6.1.2.

6. - Bases references in SR 3.6.1.1 to Type A acceptance criteria includes a phrase "following an outage or shutdown that included Type A testing." The quoted phrase has been deleted consistent with NRC comments on TSTF-52. Also the "and/or" in the -

Bases for SR 3.6.1.1 and 3.6.1.2 are replaced with "and" consistent with the STS.

(The previous response inadvertently omitted the changed pages for removing the referenced phrase. These pages have been revised.)

1 l

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mc5_cr_3.6 3.6 July 14, 1998

Containment B 3.6.1 l

l BASES l

l ACTIONS Ad i

In the event containment is inoperable, containment must be

, restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal.

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and Type A leakage rate test requirements of the Containment Leakage Rate Testing Program.

Failure to meet specific leakage limits for air lock, secondary containment bypass leakage path, and purge valve with resilient. seals (as specified in LC0 3.6.2 and LC0 3.6.3) does not . invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to Type A, B, and C leakage causes one of these overall leakage limits to be exceeded. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be j < 0.75 L, for overall Type A leakage. At all other times between required leakage rate L

I (continued)

L l Catawba Unie 1 B 3.6-4 Supplement 7

=_ _ _ _ _ _ _ i

\

Containment B 3.6.1 BASES (continued)

ACTIONS 8.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance of reintaining containment OPERABLE during MODES 1, 2, 3, and 4. This time period also ensures that the probability 9' an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is mininal.

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE-in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and.to MODE.5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.~6.1.1 REQUIREMENTS

, Maintaining the containment OPERABLE requires compliance with the visual examinations and Type A leakage rate test requirements of the Containment Leakage Rate Testing Program. Failure to meet specific leakage limits for air lock, secondary containment bypass leakage path, and purge valve with resilient seals (as specified in LCO 3.6.2 and LC0 3.6.3) does not invalidate the acceptability of the overall containment leakage determinations unless the specific leakage contribution to Type A, B, and C leakage causes one of these overall leakage limits to be exceeded.

As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage l l test is required to be < 0.75 L for overall Type A leakage.

l At all other times between requ, ired leakage rate I

(continued) l l Catawba Unit 2 B 3.6-4 Supplement 7 l

Containment ucerondenwr?

B 3.6.1 @

BASES (continued)

ACTIONS Al In the event containment is inoperable, containmer.t must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment OPERABLE during MODES 1. 2, 3, and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. ,

8.1 and 8.2 If containment cannot be restored to CPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least,H00E 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in arf orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERAB r requires compliance -

with the visual examinations and ea age rate tess ' T'M A j (p r_ requirements oflj0 CpK

Annanou J ikau ii == moolisem -

- ov anorov- m em t46ns J failure to meetvair lock >t. r

'3 cc

~ .

(TAe CMhmmaSM secon'ary d containment b ass leakage path, and purge valve ;

l (c,&E R,/c. with resilient sea. ea i= unspecified in LCO 3 6.2 b7l'"1 p,,#F#"tL;pn I

/

th48 overallyl)eakage determinations unless thGland LN n;;h f.,

h (as LCO 3.6.3} does'n 2

(, contr% tion todggE[> Type A. B, ang to the firstleakage cause(

6ii eremar limin. As left leakage pr Sgtotay, 2 '{

Cy, b u d startuo after performing a requirgd_dtruw Mr Ax>endw A

Ag P.dc.,i 11eakage test is required to Deleo o mor armh c% ,c

-n gs/,"4 P,cc, ano meas,aaW. GDi@0.75 L, for overall Type A ' nea eaka isoet m _%g '

all other times between required leakage rate tests. A acceptance criteria is based on an overall Type A leakage o i

a v) a e c. limit of s 1.0 L,. At s 1.0 L ,o /a e 1

p )a / consequences are bounded ebyassumptions th, the offsite dose of the safety ;5 hat me d7 B, analysis. SR Frequencies are as required bygermx ury w? /s. J<d

\

' ,/e y 2 b Oc Grsk mod'4'k*1 N

4/e. res/m h Baghe et (continued) '#'f t

B 3.6-4 Rev 1, 04/07/95

( . ~~.W.OG STS .-

/

% [~ ~ '**%...,- -

1 E__________..__

t i-l McGuire & Catawba Improved TS Review Comments ITS Section 3.6 Containment Systems i

3.6.13-6 JFD Bases 11 -

l STS B3.6.16 Bases - RA B.1 and 8.2 and RA C.1

'- ITS B3.6.16 Bases - RA B.1 and B.2 and RA C.1

, The last sentence in STS B3.6.16 Bases - RA B.1 and B.2 states the following: "If this l ' verification is not made Required Actions D.1 and D.2 not Required Action C.1 must be

!' taken." la addition, the last sentence in STS B3.6.16 Bases RA C.1 states the following:

l

Condition C is entered from Condition B only when the Completion Time of Required Action

. B.2 is not met or when the ice bed temperature has not been verified at the required frequency." Both of these statements have been deleted from ITS B3.6.16 Bases - RA B.1 and B.2 and RA C.1 respectively. The justification for this deletion (JFD Bases 11) states that the Bases discussions are not consistent with the specification nor with the rules of

. Completion Times as defined in NUREG Section 1.3. The staff believes that the two statements are correct and need to remain. The staff's interpretation of the statements is that if the ice bed temperature is not surveilled in accordance with the frequency limitation specified in ITS SR 3.0.2 due to forgetfulness or inattention to ACTION requirements, rather than inability to perform surveillance, a shutdown is required, rather than allowing an

- additional 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the ice condenser door to OPERABLE status. In addition, the staff considers the change to be generic and beyond the scope of review for this conversion.

Comment: Delete this generic change.

DEC Response:

The staff's interpretation is neither consistent with the current technical specification requirements, STS 3.6.16 as written, STS LCO 3.0.2, nor with the rules of Completion Times as described in STS 1.3. The proposed interpretation is also inconsistent with the actions for the ice bed temperature LCO 3.6.12. The stated action in STS 3.6.16, required action B.1, is to verify ice bed temperature is within limits on a periodic frequency of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and required

. action B.2 requires the inoperable doors be restored in 14 days. If at any time during the 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months , the temperature is not within limits, then required action C.1 becomes applicable and ,

requires the ice condenser be restored in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This is exactly the same action as required by STS 3.6.15, Required Action A.1. This action is also applicable (and intentionally

' identical) because with the temperature limit not met, the LCO is not met and the actions of a

- STS 3.6.15 become applicable. In both STS 3.6.16 and 3.6.15, a completion time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . l ls allowed with the ice bed temperature not within limits. If the temperture limit is not checked, !

the STS Bases provide conflicting statements which also do not agree with the actions as written. The Bases for required action B.1 and B.2 state that if the verification is not made, l condition D applies. The Bases for required action C.1 states that it applies when the !

temperature has not been verified at the required frequency. Condition D, however, clearly indicates in'the Specification that it is only applicable to Conditions A and C.

CTS 3.6.5.3 allows operation for up to 14 days provided the ice bed temperature is monitored j every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and is within limits; otherwise, the doors must be restored in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The mc5_cr_3.6 3.6-52 July 14, 1998

I McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems l STS Bases cannot establish new rules for the usage of completion times which are not consistent with those already established by STS 1.3, nor can the Bases direct actions which are in direct conflict with the actions of the LCO as written. The STS Bases is incorrect on both counts and is a more restrictive change on the current license. Duke Energy does not accept this more restrictive change for inclusion in the ITS, nor is this change from the STS Bases considered generic because it maintains the current licensing basis.

REVISED RESPONSE:

JFD 11 is revised to justify this change on current licensing basis and CTS.

mc5_cr_3.6 3.6-53 July 14, 1998

i l

I Justification fer Dsviatiens Section 3.6 - Containment Systems BASES t

11. The discussions in the STS 3.6.16 Bases for Actions B.1, B.2, C.1 and C.2 are not consistent with the current licensing basis and technical specifications and have been deleted. The stated action in CTS 3.6.5.3, l

required action a, is to verify ice bed temperature is within limits on a periodic frequency of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and requires the inoperable doors be restored in 14 days. If at any time during the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the temperature is not monitored or not within limits, then the action requires the ice condenser be restored in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or a unit shutdown is required. These actions are retained in ITS 3.6.13, Required Actions B.1, B.2 and C.1.

The STS Bases provide conflicting statements which do not agree with the ,

CTS actions as written and therefore cannot be adopted.

12. The changes are consistent with generic change TSTF-30 to NUREG-1431 provided to NRC by the industry owners groups.

l l

L Catawba Units 1 and 2 2 Supplement 76 l

> 1 McGuire & Catawba Improved TS Review Comments l ITS Section 3.6, Containment Systems !

1 i

3.6 Additionalitems 3.6-03 CTS 4.6.5.6.2 (McGuire only) ITS SR 3.6.11.7 DOC A22 The CTS requires that the operation of the air return fans function within the setpoints for the containment pressure control system. The ITS provides the expicit functional requirements for -

the air return system in response to the CPCS setpoints, similar to the CTS requirements for Catawba. ITS SR 3.6.11.7 requires the air return fan dampers to close upon receipt of a terminate signal. This signal will prevent the damper from opening, but does not cause the damper to close. The ITS SR is revised accordingly to delete any reference that the terminate l signal will close the valve.

REVISED RESPONSE: I This change is applicable only to McGuire as a result of a previous modification to the McGuire facility only. The previous response inadvertently omitted the McGuire CTS markup inserts. These pages are provided for closure of this item.

l 1

mc5_cr_3.6 3.6-73 July 14, 1998 l-I

7 McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1-26 DOC LA.9 Catawba CTS 4.8.1.1.2.g.12 l Catawba CTS 4.8.1.1.2.g.13 McGuire CTS 4.8.1.1.2.e.13 CTS Table 4.8-2 ITS SR 3.8.1.18 STS SR 3.8.1.18 l ITS SR 3.8.1.18 differs from the STS by omitting a value for the interval tolerance for each l 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 I brackets, which means that the ITS should contain plant-specific information. DOC LA.9 is

! Incorred 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 information contained in CTS Table 4.8-2;

and also for Catawba, the information contained in Catawba CTS 4.8.1.1.2.g.13.

l DEC Response:

DEC disagrees. The STS does not require the inclusion of specific block interval times and only specifies the tolerance associated with the design intervals. The intent of the STS is that the block interval values may be adequately controlled in licensee controlled documents. In most all of the cases (except T1 and T8 for McGuire and T1 for Catawba), the specified block l Interval tolerance is well belcw the 10% example value provided in the STS. DEC does not believe that there is any beneh; in incorporating both the tolerance values and the load interval times within the ITS and .t will be difficult to include only the tolerance values since they are different for each load block. This information can be adequately controlled within the UFSAR similar to the RTS and ESFAS response times which are relocated to the UFSAR in section 3.3.

- REVISED RESPONSE:

The Bases for SR 3.8.1.18 are revised to reference the applicable UFSAR table where the i load sequencer and interval times are located.

l l

I mc4_cr_3.8 24 July 14,1998 I

1 l

l

7-AC Sources-Operating B 3.8.1 l l

BASES SURVEILLANCE SR 3.8.1.17 (continued)

REQUIREMENTS This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

i The 18 month Frequency is consistent with the >

l reconnendations of Regulatory Guide 1.108 (Ref.10),

paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. l This SR is modified by a Note. The reason for the Note is )

that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical .

] distribution system, and challenge safety systems. l l

SR 3.8.1.18 l Under accident and loss of offsite power conditions loads !

l are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of i the DGs due to high motor starting currents. The load l l l sequence time interval tolerance in Table 8-6 of Reference 2 i ensures that sufficient time exists for the DG to restore

. frequency and voltage prior to applying the next load and ;

l that safety analysis assumptions regarding ESF equipment ;

t l time delays are not violated. Table 8-6 of Reference 2 '

provides a summary of the automatic loading of ESF buses. ;

l ,

The Frequency of 18 months is consistent with the i

! recommendations of Regulatory Guide 1.108-(Ref.10),

paragraph 2.a.(2), takes into consideration unit conditions i

required to perform the Surveillance, and is intended to be '

consistent with expected fuel cycle lengths.

I I SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite j- . power, the DGs are required to supply the necessary power to l ESF systems so that the fuel, RCS, and containment design i . limits are not exceeded. ,

I (continued) l . Catawba Unit 1- B 3.8-28 Supplement 7 l

AC Sources-0perating B 3.8.1 BASES SURVEILLANCE' SR 3.8.1.17 (continued)

REQUIREMENTS This- testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref.10),

paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillo. ice would remove a required offsite, circuit from service, perturb the' electrical

' distribution system, and challenge safety systems.

SR 3.8.1.18 Under accident and loss of offsite. power conditions loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and' starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The load l sequence time interval tolerance in Table 8-6 of Reference 2 ensures that sufficient time exists for the DG to restore frequency and voltage prior to applyi_ng the next load-and that safety analysis assumptions regarding ESF equipment l- time delays are not violated. Table 8-6 of Reference 2 provides a summary of the automatic loading of ESF buses.

l The' Frequency of 18 months is consistent with the recommendations' of Regulatory Guide 1.108 (Ref.10),

paragraph 2.a.(2),. takes into considerat.on unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

L

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite r . power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits'are not exceeded.

(continued)

l. Catawba' Unit-2 B 3.8-28 Supplement 7 O .

n-

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.17 (continued) ~

ACQUIREMENTS This testing may include any series of sequential, overlapping. or total steps so that the entire connection and loading sequence is verified.

The 18monthdrequene is consistent with the recommendations of Regufatory Guide 1.108 (Ref. /

paragraph 2.a.(8), takes into a)nsideration uni conditions A I

t

,)-- required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service perturb the electrical distribution svsta and cha11ence safety systems.JC (may be teefi for unplannerevents that sattps SR 3.8.1.18 .

Under accidentiand loss of offsite [ conditions loads are sequentially connected to the bu theXautomatic load sequencer}9 The sequencing logic controls the peruf'ssive and starting signals to motor breakers to prevent overl i of the DGs due to high motor starting currents.

The # \

oed sequence time interval tolerance (ensures that L MdA<eu. 2J sufficient time exists for the DG to restors frequency and '

voltage prior to applying the next load and that safety /

analysis asstaptions regarding ESF equipment time delays are not violated.vBeference 2 provides a sumu.ry of the TaWN automatic loading of ta buses. -

The Frequency ofi18 monthsN consistent with reci%tions of Regulatory Guide 1.108 (Ref. ,

paragra,$ 2.a.(2), takes into consideration uni conditions required to :erform the Surveillance, and is intended to be' consistent with expected fuel cycle lengths.

'This SR is ified by a Note. reason for the te is that perf og the Surve111 offsite rcuit from servi . perturb the electr cal ired would remove a distri ion system, and 11enge safety sys . Credit

[ may tr.ien for unola events that satis this.M.

J (continued) 8 3.8 30 Rev 1. 04/07/95 au 1

l

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.3-08 Not used 3.8.3-09 ITS 3.8.3 Condition B Catawba only Bases for ITS 3.8.3 Required Action B.1 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.

DEC Response:

UFSAR Section 9.5.7 states that the normal operating volume of 600 gallons with a 700 gallon capacity. The operability limit is selected at the normal operating volume. This section also indicates that the lube oil consumption rate is 1.2 gallons per hour. For a 7 day run, this would consume approximately 200 gallons of lube oil. The minimum operating level is approximately 400 gallons, therefore, the 600 gallon operability limit is appropriate. ITS Condition B addresses the case where lube oil inventory is less than a 7 day supply, but greater than 6 days. This is equivalent to a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months reduction in lube oilinventory. Based on the consumption rate of 1.2 gal /hr, this would be 28.8 gallons, or approximately 30 gallons.

The 6 day limit is therefore established at 600 - 30 = 570 gallons.

REVISED RESPONSE:

I The lower limit is revised to 575 gallons to allow a roundoff in the conservative direction, {

rather than 570 gallons. j 1

j mc4_cr_3.8 36 July 14,1998 l

l L ___ ___ _ _ _ _ _ _

j

Diesel' Fuel Oil, Lubs 011, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 - Diesel Fuel Oil, Lube Oil, 'and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air

. subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY:- When associated DG is required to be OPERABLE.

ACTIONS-

NOTE-------------------------------------

Separate Condition entry is allowed for each

____ .... ____________._____________ ___________ DG.'_____________________________

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel oil inventory, level to within

< 77,100 gal and' limits.

> 66,100 gal.

B.. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory inventory to within

< 600 gal and limits.

> 575 gal. l

'C.. One or more DGs with C.1 Restore fuel oil 7 days stored fuel oil total- total particulate l . particulate _not within limit.

within limit.

l (continued) .;

L

-Catawba Unit 1 3.8-19 Supplement 7 l l' -

. - - - - - - - _ - ---_-_.---_--__---__ _ -- _ _ o

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8. ELECTRICAL POWER SYSTEMS' 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LC0 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel oil inventory level to within

< 77,100 gal and limits.

> 66,100 gal.

B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory inventory to within

< 600 gal and limits. 4

> 575 gal. l )

C. One or more DGs with C.1 Restore fuel oil 7 days stored fuel oil total total particulate particulate not within limit.

within limit.

(continued) 1 I

Catawba Unit 2 3.8-19 Supplement 7 l l l

l Specification 3.8.3 INSERT 1 l A% :

l 3.8 ELECTRICAL POWER SYSTEMS j 3.8.3 Diesel Fue1011, Lube Oil, and Starting Air i LCO 3.8.3 The stored diese1 fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

l i

APPLICABILITY: When associated'DG is required to be OPERABLE.

INSERT 2 j

$ .7.,7 '

l

, .._..............___________.------ -NOTE--------.- ----.-------------.-----_-

)

Separate Condition entry is allowed for each DG. j i

INSERT 3 I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with A.1 Restore fuel oil level 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ;

fuel oil inventory to within limits. L.b i

< 77,100 gal and- l

> 66,100 gal. s !

l f B. One or more DGs with B.1 Restore Tube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ;

! lube oil inventory inventory to within !

L < 600. gal and > 575 limits. l l L

ga1. J l i

l l

- t ' ..

Catawbaf .Page2 oft

.y

i Specification '

3.8.3 INSERT 1 As 3.8 ELECTRICAL POWER SYSTEMS {

3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air ,

1 i

LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem l shall be within limits for each required diesel generator (DG).

l l

APPLICABILITY: When associated DG is required to be OPERABLE.

INSERT 2

.D

.------------------------------------NOTE-------------_--------------__-------

Separate Condition entry is allowed for each DG.

l l

INSERT 3 CONDITION REQUIRED ACTION COMPLETION TIME l

A. One or more DGs with A.1 Restore fuel oil level 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel oil inventory to within limits.

< 77,100 gal and O

> 66.100 gal .

B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory inventory to within AIII

< 600 gal and > 575 limits. l

, gal. )

I Catawba 7-- Pagelof8 L_____-___

)

Dizsel Fuel 011. Lube 011 and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS i 3

3.8.3 Diesel Fuel 011. Lube 011. and Starting Air LCO 3.8.3 The stored diesel fuel oil. lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY: When assNiated DG is required to be OPERABLE.

ACTIONS l

..................................... M ......,...............................

Separate Condition entry is allowed for each DG. ,

COWITION REQUIRED ACTION CaiPLETION TIME A. One or more nne wit 6 A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel a m @ri mwg level to within 7,t < yga

.j g limits. "

cu,,a _

8. One or more DGs with 8.1 Restore lube oil lube oil inventory 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months g inventory to within

( M gal and limits. .

>4 gal.

64

~ ~

C. One or more DGs with C.1 Restore'fuelitl' 7 days stored fuel oil total total particulate particulate not within limit.

within 1imit.

(continued) l WJF5TS 3.8 21 Rev 1. 64/07/95 (

dde

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

3.8 Additionalitems l 3.8-01 STS SR 3.8.1.11, 3.8.1.12, and 3.8.1.19 STS Bases Background, SR 3.8.1.11 and 3.8.1.12 ITS SR 3.8.1.11, 3.8.1.12, and 3.8.1.19

, ITS Bases Background, SR 3.8.1.11 and 3.8.1.12 CTS 4.8.1.1.2.e.4.b, 4.8.1.1.2.e.5 (McGuire)

CTS 4.8.1.1.2.g.4.b, 4.8.1.1.2.g.5 (Catawba)

DOC M4, MS During subsequent reviews of the ITS, it was discovered that the addition of SR 3.8.1.12.e related to load sequencing and associated Note 2 are significantly more restrictive than the CTS. This test is currently performed with the unit at power. With the STS note 2, and item e, this could no longer be done. Therefore, these items are deleted from the ITS and the CTS requirements are maintained. The STS SR 3.8.1.12 is bracketed to reflect the intent to incorporate the CTS requirements. Proper operation of the load sequencer is verified during '

testing for ITS SR 3.8.1.19 for a combined loss of offsite power and Si and in SR 3.8.1.11 for

a loss of offsite power.

Additionally, STS SR 3.8.1.11.c.1 and c.5, SR 3.8.1.19.c.1 and c.5, and STS 3.8.1.12.d and .

applicable Bases sections are also revised to delete statements relative to permanently I connected loads. The design is such that allloads are stripped from the emergency buses.

These items are revised to indicate that the emergency bus is enorgized or remains ,

energized, as applicable.

REVISED RESPONSE:

i' The previous response inadvertently retained Note 2 for SR 3.8.1.12 in the McGuire ITS. The Note was deleted in the ITS Bases and in the CTS and STS Markups. The error has been corrected and new pages are provided. Additionally, on STS Bases page B 3.8-2, the statement referring to load strips is awkward and the ITS Bases for Catawba and McGuire is revised based on discussions with NRC in the July 9,1998 comment resolution meeting.

l l

! I l i i

mc4_cr_3.8 71 July 14,1998 i

____ ______-_-__-_____ a

AC Sources-Operating B 3.8.1 BASES BACKGROUND safety injection (SI) signal (i.e., low pressurizer pressure (continued) or high containment pressure signals) or on an ESF bus degraded voltage or undervoltage signal (refer to LC0 3.3.5,

" Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation"). After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SI signal. With no SI signal, there is a 10 minute delay between degraded voltage signal and the DG start signal.

The DGs will also start and operate in the standby mode without tying to the ESF bus on an SI signal alone.

l Following the trip of offsite power, a sequencer strips loads from the ESF bus. When the DG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application.

In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient tirre to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Approximately 1 minute after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service.

Ratings for Train A and Train B DGs satisfy the requirements of Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG is 7000 kW with 10% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The ESF loads that are powered from the 4.!6 kV ESF buses are listed in Reference 2.

APPLICABLE The initial conditions of DBA and transient analyses in the SAFETY ANALYSES UFSAR, Chapter d (Ref. 4) and Chapter 15 (Ref. 5), assume ESF systems are OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, (continued) l Catawba Unit 1 B 3.8-2 Supplement 7 l

AC Sources -Operating B 3.8.1 BASES BACKGROUND safety injection (SI) signal (i.e., low pressurizer pressure '

(continued) or high containment pressure signals) or on an ESF bus degraded voltage or undervoltage signal (refer to LC0 3.3.5,

"!.oss of Power (LOP) Diesel Generator (DG) Start Instrumentation"). After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SI signal. With no-SI signal, there is a 10 minute delay between degraded voltage signal and the DG start signal.

The DGs will also start and operate in the standby mode without tying to the ESF bus on an SI signal alone.

l Following the trip of offsite power, a sequencer strips loads from the ESF bus. When the DG is tied to the ESF bus, loads are then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and startino cignals to motor breakers to prevent overloading tL: 0; by automatic load application.

In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a los.s of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Approximately 1 minute after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service.

Ratings for Train A and Train B DGs satisfy the requirements of Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG is 7000 kW with 10% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

APPLICABLE The initial conditions of DBA and transient analyses in the SAFETY ANALYSES UFSAR, Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume ESF systems are OPERABLE. The AC electrical power sources are designed to ' provide sufficient capacity, capability,

}

(continued) l Catawba Unit 2 8 3.8-2 Supplement 7 i l,

AC Sources-0paratt. g B 3.8.1

{

BASES BACKGROUND (continued) automatically on a safety injection (SI) signal (i.e., low pressurizer pressure or high containment pressure signals)

or on angESF bus de

- (refer to LCO 3.3.5, graded voltage or undervoltage signal}e I

!

Loss of Power (LOP) Diesel Generator Q ! w(DG)

~

After the DG has started, it Start Instrumentation").

ill automatically tie to its respective bus after offsite power is tripped as a ph ss\.g, ) degraded volt sianalvTheg.1 of ESF bus undervoltage or g u a i o,,,,,,a will of or coincident with an SI W

g kW g mode without tying to the ESF bus on an SI signal alone,1so sta Followino the tri_p of offsite SW W M aower bc-

~

4. Na.l. ) 'miaervoltis?smnaDXstripscnnm.){a bus. aent loads sequence from t @he ESF h When connected sequentially ".he DG is to tied to me ex bus, loads are then automatic load sequencer. its respective ESF bus by the The sequencing logic contro7s the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application.

In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Desi such as a loss of coolant acciden: gn Basis Accident (DBA)

(LOCA). .,

Certain required unit Uread*.A h

, predetermined sequence in orderoaos are returned.to service in a DG in the process. prevent overloading the

signalisreceived,$ at 1 minute after the initiating i loads needed to recover the unit or' maintain it in a safe condition are returned to service.

Ratings for Train A and Train B DGs satisfy the requirements of Regulatory Guide 1.9 (ReL. 3).

The continuous service Ol rating of each DG Q47000TRW witly 10Koverload pemissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any{24 hour period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

APPLICABLE SAFELY ANALYSES

The initial conditions of DBA and transiengt nalyses in the

, Chapter.s[6PTRef. 4) and Chapterp{15J (Ref. 5), assume u ESF systems are OPERABLE.

The AC electrical power sources i

,Q j are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not W()PdS '

B 3.8 2 cakJ,- Rev 1. 04/07/95 1

I l

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8 Additionalitems 3.8-12 STS LCO 3.8.1 ITS LCO 3.8.1 The language of the STS LCO statement implies that there are three AC sources - the offsite circuit, the DG, and the sequencer. There are only two sources - the circuit and DG. The {

sequencer is required for both of the AC sources. The ITS LCO statement is revised to delete i the "c" label designation from the sequencer and shift the requirement to the left and require the sequencer operable independent of the sources. This does not change any requirement for the equipment operability, but corrects a misleading presentation format. This change was discussed with the staff during the July 10,1998 comment resolution meeting. ;

1 I

J l

I J

l mc4_cr_3.8 82 July 14,1998 I

f >

t

AC Sources-Operating 3.8.1

'3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LC0- 3.8.1 The'following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the Onsite Essential Auxiliary Power System; and

b. Two diesel generators (DGs) capable of supplying the 4 Onsite Essential Auxiliary Power Systems; a l The automatic load sequencers for Train A and Train B shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

'A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. '

for OPERABLE offsite circuit. m Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter M

A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature (s) with no discovery of no offsite power- .

offsite power to

.available inoperable one train when its redundant concurrent with required-feature (s) inoperability of is inoperable. redundant ,

required-l feature (s) m (continued) 1

..: Catawba Unit 1 3.8 Supplement 7 l p

I -- 1 E -_ . J

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS

-3.8.1 AC Sources-0perating

'LC0 3.8.1 _ The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission -

network and the Onsite Essential Auxiliary Power System; and b.- Two diesel generators (DGs) capable of supplying the Onsite Essential Auxiliary Power Systems; a l The automatic load sequencers for Train A and Train B shall be OPERABLE.

1 APPLICABILITY: MODES 1.-2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME i.

I A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months L inoperable. for OPERABLE offsite circuit. m 1

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months i

! thereafter L

m A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature (s) with no discovery of no-l- offsite power offsite power to available inoperable one train i

when its redundant concurrent with required feature (s) inoperability of.

is inoperable. redundant 4 required feature (s)-

(continued) -i

[ Catawba Unit 2 3.8-1 Supplement 7 l l

QaA4 3.s.1 \

M8 ELECTRICAL POWER SYSTEMS l

- 3018.1 A.C. SOURCES -

1

~

(OPERATING)

LWUII10540R OPERAIJdii) l Lco 3.8.15D GLs_.a'minindim)[he following A.C. electrical @ sources shall be OPERABLE:

a.

Two (phy11cally independe3 circuits between the offsite transmission network and the Onsite~ Essential Auxilf ary Powe es, -

T

\

b. Two feparate ano. indefsendent diesel generators Qactuwt WY g l

3Ng),.; ) A separate day tank containing a ufnimum volume of 470 gallonP

_gf fue1, r T' M S.3 AseparateFuelStorageSystemcontainingaminimumvolumeo]f 77.100 aallons of fuel, rr'sigIC.: 3) A separ$te fuel transfer valve, anD

/g*/gg..I. Aseparate125VDCbatteryandchargerconnectedtothedieM

{

N enerator control loads y APPLICABILITY: MODES 1, 2, 3, and 4. Ahhc load sejumed [*'ba Q 4-4 %l. 6 v i -

ACTION:

hl k OW)

Mc/dr1A' @ offsite circuit Fe,Above reauteeG A.C. electrJ6a] powef)L (sou ves] inoperable:

[

g @ rDe,moye(rate thegERABitITY ofdha miniMi rootfived rifnig"f"

h *~

<ctxult hi rform Specification.8.1. withina 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months seg.g and at le'a t once p@er 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; gpy 'A.3 @ Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months {

U 'G1 cor be in atSHUTDOWN 2 C0tD least HOT STANDBY within 30 within the following thehours. next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in '

e nse$tD n.t %-

l CATAWBA - UNIT I 3/4 8-1 Amendment No.155 t

U P9 1.C 2l L_____________

Sp w k % 3 g.]

3/A8 ELECTRICAL POWER SYSTEMS 3 @ ,8.1 A.C. MRCES --

(DPERATI@

CLIMITINGdam! TION FORAPERATIOh 7

L.co 3.8.1@ M mia@b OPERABLE: following A.C. electrical @ sources shall be

%s;t.'.J)

I' a.

Two network envelcallv indaaaadaab and the Onsite Essential Auxiliary ctreuits between the offsite transatsste Power stem, @ c94

b. Two sEliargand 1ada6 diesel generato -

h ege.%

h.uuss f ag b

,7 17, [I s irac.nwith(j"*gpe r a ate day tank containing a minimum volume of 470 gaTTo3 y*j33 )

A separate 77,100 Fuel of gallons Storage fuel,r System containing a minimum volume 2)

(TI'd's.t. A separate fuel transfer valve, andl '

'Mb. 4 A separate generator 125loads.f control VDC battery and charger co'nnected to --

J APPLICABILITY: MODES 1, 2, 3, and 4. ~

A AJ' lod seput fw Tre.% A)

. 1 -r,4% sy _

ACTION:

fM gg A g (vWaib offsite circuit dfthad ==frad M *1actrimar rM tSiBER inoperable:

, ")

p.3 A.! @ A=--TrattAffe OPmri.II)ve..th- A4 te__4=.::5da;--JA. ----. - - - - -

id sM I offfuit.Yperfors(Ep Specificattoil%.8.1.1Sh within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months i and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; ant AC7/gg A."3 @or(Restore

s. i , c,,2 the offsite circuit to OPERABLE status be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in 1

(COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

fusear l

CATAWBA - UNIT 2 3/4 8-1 Amendment No.147 Q l rf 2l

! i AC Sources-Operating 1 3.8.1 3.8 ELECTRICAL POWER SYSTEMS I I

3.8.1 AC Sources-Operating l

{

LCO 3.8.1 l The following AC electrical sources shall be OPERABLE:

a. Two qualified ci network and the its between ite Cin* 1F the offsite transatssion m s e m Power 411straouuorn System:fandk Q!!Feec 4Dw

b. wo diesel generators (OGs) capable of h,3.0, ite ass a ocarmstrioution.aonsvs the I wnn a u m r.~ . wo and

\

omatic load sequencers for Train A and Train 8 .

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

ACTIONS COWITION REQUIRED ACTION COMPLETION TIME A. One ( k A.1 circu[reauke51)offsite it inoperable, Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for([reautrean OPERABLE ofTsite- 8llQ circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AlfQ A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from.

feature (s) with no discovery of no offsite power .

offsite power to available in, operable one train when its redundant concurrent with required feature (s) inoperability of is inoperable. redundant required feature (s)

A!!Q (continued)

- sia . '

3.8 1 SMhA Rev 1. 04/07/95

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8 Additionalitems 3.8-13 STS LCO 3.8.5, LCO 3.8.8 STS Bases 3.8.5, Bases 3.8.8 l ITS LCO 3.8.5, LCO 3.8.8 iTS Bases 3.8.5, Bases 3.8.8 CTS 3.8.2.2, 3.8.1.2 (Catawba only), 3.8.3.2 CTS 3.8.3.2.c requires a single train (two channels) of AC vital busses connected to their associated inverters and respective DC sources in MODES 5 and 6. STS 3.8.5, for DC sources, and STS 3.8.8, for inverters, requires that DC sources and inverters be OPERABLE to support the distribution systems required OPERABLE by STS 3.8.10 in MODES 5 and 6.

In certain instances, two trains of a plant system, e.g. control room filtration, is required OPERABLE and requires an OPERABLE power supply. CTS 3.8.3.2.c, however, does not require that the distribution system for the second filtration train be provided with an inverter or battery and charger pair. The only requirement is that the required filtration train be OPERABLE. The definition of OPERABILITY only requires the normal or emergency power source be OPERABLE. The 4160 V bus powering either filtranon train could be powered from either an offsite circuit or a DG. Likewise, the AC vital bus distribution systems could be powered from either a battery or charger backed inverter or the regulated transformer and would be considered OPERABLE. This is consistent with the operability descriptions in the STS 3.8.10 Bases for distribution systems, that is, the distribution systems must be energized to be OPERABLE. However, the STS 3.8.7 and 3.8.8 Bases for inverters requires them to be connected to their associated AC vital buses for the inverters to be considered OPERABLE.

The STS 3.8.4 and 3.8.5 Bases for DC sources requires both a battery and charger to be OPERABLE to have an OPERABLE DC source. Since STS 3.8.10 sometimes requires portions of both electrical power distribution trains to be OPERABLE (i.e., energized), the STS LCO 3.8.5 and 3.8.8 statements, as written, would require a second complete train of OPERABLE inverters and DC sources. This is significantly more restrictive than the CTS requirement which only requires one complete train of normal and emergency power supplies in these MODES. Therefore, the ITS LCO 3.8.5 and 3.8.8 are revised, consistent with the current licensing basis, to only require one train of DC sources and inverters OPERABLE and clarifies that the second distribution system train, if required OPERABLE by 3.8.10, only be energized from an appropriate source. An appropriate source would be either the battery or charger for the DC vital bus, and the inverter or regulated voltage transformer for the AC vital bus.. JFD 19 is added to justify this exception to the STS.

1 l

I mc4_cr_.3.8 E3 July 14,1998

'1 I

1 E.._________________________________

_ l

l DC Sources-Shutdown 3.8.5 i 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LC0 3.8.5 The following shall be OPERABLE:

a. Two channels of DC electrical power subsystems and a train of DG DC electrical power rubsystem capable of j supplying one train of the DC electrical power j distribution subsystem (s) required by LC0 3.8.10, '

" Distribution Systems-Shutdown," and

b. One source of DC electrical power, other than that i required by LC0 3.8.5.a. capable of supplying the remaining train of the DC electrical power distribution subsystem (s) when required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

j

-ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I i

A. One or more required A.1.1 Declare affected Immediately channel (s) of DC- required feature (s) electrical power inoperable. j subsystems or required DG DC electrical power M i subsystem inoperable.

A.2.1 Suspend CORE Immediately ALTERATIONS.

M A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

M (continued) l-Catawba Unit 1 3.8-27 Supplement 7 l

DC Sources-Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

8_ND A.2.4 Initiate action to Innediately restore required DC electrical power subsystems to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 -------------------NOTE--------------------

The following SRs are not required to be performed: SR 3.8.4.7,.SR 3.8.4.8, and SR 3.8.4.9. ;

....__________________________ .._________. j J

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8 SR 3.8.4.3 SR 3.8.4.6 SR 3.8.4.9 1

1 l

I l . Catawba Unit 1 3.8-28 Supplement 7 {

l

.. 1

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 ' Inverters - Shutdown LC0 3.8.8 The following shall be OPERABLE:

a. Two inverters capable of supplying one train of the onsite Class IE AC vital bus electrical power distribution subsystem (s) required by LC0 3.8.10,

" Distribution Systems-Shutdown," and

b. One source of. AC vital bus power, other than that i required by LCO 3.8.8.a. capable of supplying the remaining onsite Class IE AC vital' bus electrical power distribution subsystem (s) when required by LCO 3.8.10.

' APPLICABILITY: MODES.5 and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION I REQUIRED ACTION COMPLETION TIME I One or more required Declare affected Inynediately

. A. A.1 AC vital bus power required feature (s)

- sources inoperable. inoperable'.

08 A.2.1 Suspend CORE Immediately ALTERATIONS.

L AliQ -

i A.2.2 Suspend movement of Immediately l irradiated fuel ;

. assemblies.

l 6fiQ ,

s .l' l -(continued) l l

l I

l s .

Catawba' Unit 'l 3.8-35 Supplement 7 l m

_ _ _ _ . _ .__ ._________________i

L l

l Inverters-Shutdown 3.8.8 l

l ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Imediately suspend operations involving positive reactivity additions.

Al@

A.2.4 . Initiate action to Imediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.8.8.1 Verify correct voltage and alignment to 7 days required AC vital bus.

L l ' Catawba Unit 1. 3.8-36 Supplement 7 E----------_ - - - - - - - - - _ - - - - . - - . . _ - - - _ - - - - - - - --

DC Sources-Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS l 3.8.5 DC Sources-Shutdown i

r LC0 3.8.5 The following shall be OPERABLE: 1

a. Two channels of DC electrical power subsystems and a l- train of DG DC electrical power subsystem capable of supplying one train of the DC electrical power distribution subsystem (s) required by LC0 3.8.10,

" Distribution Systems-Shutdown," and

b. One source of DC electrical power, other than that ;

required by LC0 3.8.5.a. capable of supplying the remaining train of the DC electrical power distribution '

subsystem (s) when required by LC0 3.8.10.

APPLICABILITY: MODES 5 and 6 During movement of irradiated fuel assemblies.

ACTIONS

-CONDITION REQUIRED ACTION COMPLETION TIME l l 'A. One or more required A.1.1 Declare affected Immediately channel (s) of DC required feature (s) electrical power inoperable.

subsystems or required DG DC electrical power QR

subsystem inoperable.

A.2.1 Suspend CORE Immediately ALTERATIONS.

l ARE A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

ARQ

! (continued) l Catawba Unit 2 3.8-27 Supplement 7 l

DC Sources-Shutdown 3.8.5 ACTIONS' CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)' A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to Immediately restore required DC electrical power subsystems to .l OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 -------------------NOTE--------------------

The following SRs are not required to be performed: SR 3.8.4.7, SR 3.8.4'8, and .

SR 3.8.4.9.

l For DC sources required to be OPERABLE,the In accordance following SRs are applicable: with applicable i SRs l SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 L SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8 SR 3.8.4.3 SR 3.8.4.6 SR 3.8.4.9 L

l Catawba Unit 2 3.8-28 Supplement 7

l Inverters - Shutdown 3.8.8

' 3.8 ELECTRICAL POWER SYSTEMS j' 3.8.8 Inverters -Shutdown LCO 3.8.8 The .following shall be OPERABLE:

a.- Two inverters capable of supplying one train of the onsite Class IE AC vital bus electrical power distribution subsystem (s) required by LCO 3.8.10,

! " Distribution Systems-Shutdown," and

! b. One source of AC vital bus power, other than that L required by LC0 3.8.8.a. capable of supplying the remaining onsite Class IE AC vital bus electrical power distribution subsystem (s) when required by LC0 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement.of irradiated fuel assemblies.

ACTIONS' CONDITION REQUIRED' ACTION COMPLETION TIME

.A.._One or more' required A.1 Declare affected Immediately AC vital bus power required feature (s)

, sources inoperable. inoperable.

DR A.2.1 Suspend CORE Immediately l ALTERATIONS.

m A.2.2 Suspend movement of Immediately

' irradiated fuel assemblies.

.M (continued) u Catawba Unit 2 3.8-35 Supplement 7 l w----_.- - - - . - -- - - - , - - - - - . - - - - - - . - - - . . - _ _

Inverters - Shutdown l 3.8.8 I

ACTIONS CONDITION ' REQUIRED ACTION COMPLETION TIME

(' . A. (continued) A.2.3 Initiate action to Immediately l suspend operations l: involving positive L reactivity additions.

AliQ A.2.4 Initiate action to Inunediately

, restore required i

inverters to OPERABLE status.

. SURVEILLANCE REQUIREMENTS j ., SURVEILLANCE FREQUENCY l

l SR 3.8.8.1 Verify correct voltage and alignment to 7 days required AC vital bus.

1 l

i t-i l . l Catawba Unit 2 3.8-36 Supplement 7 l

i l 1

! j

DC Sources-Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS i

B 3.8.5 DC Sources-Shutdown l

1 BASES l BACKGROUND A description of the DC sources is provided in the Bases'for LC0 3.8.4, "DC Sources-0perating."

1 APPLICABLE The initiM conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the )

diesel generators, emergency auxiliaries, and control and j switching during all MODES of operation. l 1

The OPERABILITY of the DC subsystems is consistent with the )

initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources !

during MODES 5 and 6 and during movement of irradiated fuel assemblies ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is I available for monitoring and maintaining the unit i status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident. l i

The DC sources satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LC0 The DC electrical power subsystems, with 1) at least one l ;

subsystem consisting of two batteries, one battery charger per battery; and 2) when the redundant train of DC electrical power distribution subsystem is required by LC0 3.8.10, the other subsystem consisting of either a battery (continued)

Catawba Unit 1 B 3.8-57 Supplement 7 l l

C______..__.____________. _ _ . _ . _

DC Sources-Shutdown ;

8 3.8.5 4 BASES ,

i l LCO- or a charger, and 3) the corres)onding control equipment ,,

(continued) and interconnecting cabling wit 11n the train, are required l to be OPERABLE to support recuired trains of the ;

distribution systems requirec OPERABLE by LC0 3.8.10, j

" Distribution Systems-Shutdown." This ensures the i l availability of sufficient DC electrical power sources to '

operate the unit in a safe manner and to mitigate the l consequences of postulated events during shutdown (e.g.,

fuel handling accidents).

l

-l APPLICABILITY The DC electrical power sources required to be OPERABLE in i MODES 5 and 6, and during movement of irradiated fuel !

i assemblies, provide assurance that:

l

a. Required features to provide adequate coolant ;

. inventory makeu) are available for the irradiated fuel '

l assemblies in t1e core; I

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of ;

events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A.1. A.2.1. A.2.2. A.2.3. and A.2.4 If two trains are required by LCO 3.8.10, the remaining train with DC power available may be capable of su) porting

! sufficient systems to allow continuation of CORE A_TERATIONS E and fuel movement. By allowing the option to declare required features inoperable with the associated DC power source (s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO' ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the (continued) l . Catawba Unit 1 8 3.8-58 Supplement 7

Inverters - Shutdoen B 3.8.8 BASES (continued) l LC0 The inverters ensure the availability of electrical power i for the instrumentation for systems required to shut down l

the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. At least two AC vital buses on one train energized by their associated battery powered inverters _ provide uninterruptible supply of AC electrical power to associated loads even if the 4.16 kV safety buses are de-energized. OPERABILITY of the inverters requires that the AC vital bus be powered by

,the inverter. When the redundant train of class IE AC vital bus electrical power distribution subsystem is required by LCO 3.8.10, the power source for these AC vital buses may consist of 1) the associated inverter powered by its associated battery; or 2) the constant voltage source transformer. This ensures the availability of sufficient power sources to operate the unit in a safe manner and to mitigate the consequences of postulated eveats during shutdown (e.g., fuel handling accidents).

APPLICABILITY The. inverters required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup 1 are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

' Inverter requirements for MODES 1, 2, 3, and 4 are covered in LC0 3.8.7.

i i !

(continued) l

. l Catawba Unit 1 B 3.8 Supplement 7

Inverters - Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1. A.2.1. A.2.2. A.2.3. and A.2.4 If two trains are required by LC0 3.8.10. " Distribution Systems-Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive reactivity additions. By the allowance of the option to declare required features inoperable with the associated inverter (s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions). The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

I Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of !

postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in

< order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the I required times for actions requiring prompt attention. The restoration of the required inverters should be completed as

- quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a i

constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS i This Surveillance verifies that the power sources are l functioning properly with all required circuit breakers closed and AC vital bus energized from the required power

, source. The verification of proper voltage ensures that the

. (continued) I r

Catawba Unit 1 B 3.8-75 Supplement 7 l h

Inverters - Shutdown B 3.8.8 BASES SURVEILLANCE SR 3.8.8.1 (continued)

REQUIREMENTS required power is readily available for the instrumentation connected to the AC vital bus. The 7 day Frequency takes l into account the redundant capability of the power sources and other indications available in the control room that alert the operator to inverter malfunctions.

. REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

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

I l Catawba Unit B 3.8-76 Supplement 7 i

i )

J DC Sources-Shutdown B 3.8.5 i

B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources-Shutdown I BASES i i

BACKGROUND A description of the DC sources is provided in the Bases for I LC0 3.8.4, "DC Sources-0perating."

APPLICABLE' The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature systems are OPERABLE. The DC electrical 90wer system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the q requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES S and 6 and during movement of irradiated fuel assemblies ensures that: {

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

'c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The DC sources satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LC0 The DC electrical power subsystems, with 1) at least one l subsystem consisting of two batteries, one battery charger per battery; and 2) when the redundant train of DC )

electrical power distribution subsystem is required by LC0 3.8.10, the other subsystem consisting of either a battery (continued) l Catawba Unit 2 B 3.8-57 Supplement 7 l l

L - - . _ - - - . - _ _ - _ _ _ - - _ - - _ . - - _ _ _ _ _ - _ _ _ _ _a

DC Sources-Shutdown B 3.8.5 BASES-l LC0 or a charger, and 3) the corres)onding control equipment (continued) and interconnecting cabling wit 11n the train, are required to be OPERABLE to support recuired trains of the distribution systems requirec OPERABLE by LC0 3.8.10,

" Distribution Systems-Shutdown." This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown -(e.g.,

fuel handling accidents).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instroentation and control capability is available for monitoring and maintaining-the unit in a cold shutdown condition or refueling. condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are: covered in LC0 3.8.4.

ACTIONS A.1. A.2.1. A.2.2. A.2.3. and A.2.4 i

If two trains are required by LC0 3.8.10, the remaining train with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare l required features ino source (s) inoperable,perable withrestrictions appropriate the associated DC power will be implemented in accordance with the affected required features LC0 ACTIONS. In many instances, this option may e involve undesired administrative efforts. - Therefore, the L

(continued) l.CatawbaUnit.2 B 3.8-58 Supplement 7

Inverters -Shutdown B 3.8.8 BASES (continued)

LCO The inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. At least two AC. Vital buses on one train energized by their associated battery powered inverters provide uninterruptible supply of AC electrical power to associated loads even if the 4.16 kV safety buses are de-energized. OPERABILITY of the inverters requires that the AC vital bus be powered by-the inverter. When the redundant train of class IE AC vital bus electrical power distribution _ subsystem is required by LCO 3.8.10, the power source for these AC vital buses may

.' consist of 1) the associated inverter powered by its associated battery; or 2) the constant voltage source transformer. This ensures the availability of sufficient power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident.

are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown.are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LC0 3.8.7.

l L

(continued) l , . l Catawba Unit 2 B 3.8-74 Supplement 7

Inverters - Shutdown B 3.8.8 I BASES (continued)

ACTIONS A.1. A.2.1. A.2.2. A.2.3. and A.2.4 If two trains are required by LC0 3.8.10, " Distribution l Systems-Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive reactivity l

additions. By the allowance of the option to declare required features inoperable with the associated inverter (s) l inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs'

(

Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions). The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to estabi ih a safe conservative condition.

These actions minimize the probability of the occurrence of l postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the power sources are l functioning properly with all required circuit breakers closed and AC vital bus energized from the required power source. The verification of proper voltage ensures that the (continued)

Catawba Unit 2 B 3.8-75 Supplement 7 l i

Inverters - Shutdown B 3.8.8 BASES 3

i l

SURVEILLANCE SR 3.8.8.1 (continued) I REQUIREMENTS required power is readily available for the instrumentation j connected to the AC vital bus. The 7 day Frequency takes '1 l into account the redundant capability of the power sources and other indications available in the control room that alert the operator to inverter malfunctions. '

l-REFERENCES 1.- UFSAR, Chapter 6.

. 2. UFSAR, Chapter 15,

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

l l

4 I

l. l; Catawba Unit 2 B 3.8-76 Supplement 7

_J

Specification 3.8.5 INSERT 1 The following shall be OPERABLE: 4.33 l

a. Two channels of DC electrical. power subsystems and a train of DG DC electrical power subsystem capable of supplying one train of the DC electrical power distribution subsystem (s)' required by LC0 3.8.10

" Distribution Systems Shutdown," and

b. One source of DC electrical power, other than that required by LCO 3.8.5.a, capable of supplying the remaining train of the DC electrical power distribution subsystem (s) when required by LCO 3.8.10.

INSERT 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1.1 Declare affected Immediately channels of DC required feature (s) electrical power inoperable.

subsystems or required DG DC electrical power OR subsystem inoperable.

i INSERT 3 SURVEILLANCE REQUIREMENTS ( 22

, SURVEILLANCE -FREQUENCY l

l L

SR 3 . 8 . 5 .1 - - - - - - - - - - - - - - - - - - NOT E - - - - - - - - - - - - - - - - - - - -

The following SRs are not required to be

performed: SR 3.8.4.7; SR 3.8.4.8, and SR 3.8.4.9.

For DC sources. required to be OPERABLE, the following SRs are applicable: In accordance with applicable SRs SR 3.8.4.1- SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5- 'SR 3.8.4.8 SR 3.8.4.3 SR 3.8.4.6 SR 3.8.4.9 l.

Catawba / Page.A of 3 L

o __ - - -- - _ . - - - - - - - - - - - - - ----_-- - - -

a 3,& ELECTRICAL POWER SYSTENS 9tssctmenv $

3. 8, 6 )

3,f.8 ONSlWPOWEIVDISTRIBerTIOO@EtTE6)-

CSHuY @

O.IMIIJNG CONOPTDN FOR ODEfDLTION)

Q t_c0 3.8. Con ~mtaqu.a> >

a minim e,,the fol1 ~ ia; ac aiaetriemi be OPERABLE ndenergizedg ho<ces andNinverters shall sdsecr M l / I.Ta One .4160-volt essenttai cu g o

b. Two - 600-volt essential busses in a single train, and

. Lco. ' c.

3,f.10

% inverters connected to their respective O.C. channels.Two - 120-volt A.

APPLICABILITY 5 an g i f, gM ACTION:

1 Mith any of the above reautred A.C. busses not eneraired in the reautre3 LaannerJ immediately suspend all operations involvin

, reactivity'. changes, or movement of irradiated fuel,g CORE initiateALTERATIONS, positive C.ory.envb action to ergizeanc . yviria A.c. Dusses in tne specirted manner >as %rirr ar>

'"W in 6 .ivo ,g

ghe+0TeXand[Tria4.5squ[s.

through at le symnuriz[a inch vent vent treactor cooMnt System )

l

, 41 0

. SURVEILLANCE REQUIREMENTS 5A3,T,8,1 March 44 % p.a.3.2 The specified A.C. busses shall be determined energized in the -

' Leo 7

(]uired manner indicated at least voltage on theonce per 7 days by verifying correct breaker alignment busses.

y

'?

I CATAWBA - UNIT 1 3/4 8-2'1 Amendment No. 148 fY.

f L_.-_________-._

Specification 3.8.8

~

INSERT 1

. (19

)

The following shalI be OPERABLE:

a. Two inverters' capable of supplying one train of the onsite Class 1E AC- ,

vital bus electrical power distribution subsystem (s)' required by l LCO 3.8.10, " Distribution Systems-Shutdown," and

b. One' source of AC vital bus power, other than that required by LCO l 3.8.8.a, capable of supplying the remaining onsite Class 1E AC vital bus electrical power distribution subsystem (s) when required by LCO 3.8.10.

INSERT 2 4 43 CONDITION REQUIRED ACTION COMPLETION TIME A. A.1 Declare affected Innediately required feature (s) inoperable.

INSERT 3 44 SURVEILLANCE FREQUENCY-

.SR 3.8.8.1 Verify correct ir.verter voltage and 7 days l alignment to required AC vital bus, i

Catawba { Page A of R

Specification 3.8.5

. INSERT 1 g,yy l The foilowing shall be OPERABLE:

l t

l a. Two channels of DC electrical power subsystems and a train of DG DC i electrical power subsystem capable of supplying one train of the DC electrical power distribution subsystem (s) required by LC0 3.8.10,

" Distribution Systems Shutdown." and

b. One source of DC electrical power, other than that required by LCO 3.8.5.a, capable of supplying the remaining train of the DC electrical power distribution subsystem (s) when required by LCO 3.8.10.

I INSERT 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more required A.1.1 Declare affected Immediately l channels of DC required featuro(s)

, electrical power inoperable.

subsystems or required DG DC electrical power 0_R

subsystem inoperable.

INSERT 3 SURVEILLANCE REQUIREMENTS kM SURVEILLANCE FREQUENCY SR 3 . 8 . 5 .1 - - - - - - - - - - - - - - - - - - - N OT E - - - - - - - - - - - - - - - - - - - -

The following SRs are not required to be performed: SR 3.8.4.7, SR 3.8.4.8, and SR 3.8.4.9.

For DC sources required to be OPERABLE, the following SRs are applicable: In accordance with applicable SRs SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8 i SR 3.8.4.3 SR 3.8.4.6 SR 3.8.4.9 Catawba A PageA of.3

$pM.f FicATiew 3.T fl.ECTRICAL POWER SYSTEMS 3, g,g 3.9.T OBHffTE POWif DISTRIDtfTI0lO @vCRTm] i (SHUTDOW}N Al (TIMITINGJ,8llDIT10N FORAPERAfTh t Co 3.8

~

fo nt o r nors rv4=tiv.4) 4 minimum, the f ollowing A.C. electrical busses an& inverters ~shall g be 0 _ BL and enercizedy i

/ a. One-4160-voltessentialbus,( 3 gg(

f b. Two - 600-volt essential busses in a single train, and Ace 3 #' # / c. Two - 120-volt A.C. vital busses energized from their respective t inverters connected to their respective D.C. channels. I

, APPLICABILITY MODES S and 6.

ACTION: b * *' ' # ""

4 / ~

With a'ny of the above reautred A.C. bustes not enercized in the reautred3

-manner.fiammediately suspend all operations involving CORE ALTERATIONS, positive

}

reactivity changes, or movement of irradiated fuel, initiatectorreswveaction tze sne required A.C. Dusses in the enac171ed mana&as agm en _.

[p- GoM r.a (throu in o uvuia a st a 4.5 s wnurize annnent tn- weac W coolant Sys % j inchvent.f a swd AN SURVEILLANCE REOUIRENENTS 8N8 54 3.7.7.I gg n\ .8.3.2 The specified A.C. busses shall be determined energized in the

. 7 required manner at least once per 7 days by verifying correct breaker alignment J . i~p,,,g nd indicated voltaae on the busses.

l l

l CATAWBA - Uti!T 2 3/4 8-21 Amendment No. 142 rv/42

Specification 3.8.8 INSERT 1 A.fr8 The following shall be OPERABLE: i

a. Two inverters capable of supplying one train of the onsite Class 1E AC vital bus electrical power distribution subsy tem (s) required by LCO 3.8.10, " Distribution Systems-Shutdown," end '

b. One source of AC vital bus power, other than that required by LCO 3.8.8.a, capable of supplying the remaining onsite Class 1E AC vital bus electrical power distribution subsystem (s) 'when required by LCO 3.8.10.

INSERT 2 M3 CONDITION REQUIRED ACTION COMPLETION TIME A. A.1 Declare affected Imediately

, required feature (s) inoperable.

INSERT 3 gg SURVEILLANCE FREQUENCY l SR 3.8.8.1 Verify correct i=crter voltage and 7 days l alignment to required AC vital bus, i

l l

. Catawba M Page R of A t - _

Discussion of Changas Sscticn 3.8 - Electrical Power Systems ADMINISTRATIVE CHANGES A.31 CTS LC0 3.8.2.1 is combined with the requirements of CTS 3.8.1.1 for diesel generator's battery and charger and converted to the ITS LC0 3.8.4 for the DC sources required for Modes 1 through 4.

With the incorporation of the requirements into tLe proposed LCO, no technical requirements are modified and the change is considered administrative. This change is consistent with the format of NUREG-1431.

A.32 Not used.

A.33 CTS LC0 3.8.2.2 is converted to ITS LC0 3.8.5 for the requirements of DC source during shutdown. The design of the DC channels and trains requires the addition of the DG DC subsystem from CTS LC0 3.8.1.2 to be included in the specificatf on to ensure the power supply is maintained for the breaker control power for a train.

The LCO statement is also clarified to indicate that only a single DC source (battery' or charger) is required to support a second operable distribution train whenever a second distribution train is required. This is consistent with the definition of operability that either the normal or emergency power source is necessary for equipment operability. The technical requirements sre maintained with these additions. Therefore, wording, clarification, and format changes are considered administrative in nature and the change is consistent with the format of NUREG-1431.

A.34/A.35 Not used.

A.36 Constructed from CTS LC0 3.8.2.1 and CTS LC0 3.8.1.1 is ITS LC0 3.8.6, " Battery Cell Parameters". The new LC0 requires the DG and the Class IE batteries to be OPERABLE when the associated equipment is required to be supported. The Actions of the LC0 are modified by a Note which allows separate conditional entry for each battery. ' The technical requirements of the CTS are maintained and only format changes are made, therefore, the change is' classified as an administrative. The change is consistent with the format of NUREG-1431.

l A.37 CTS Table 4.8-3 Table Notations (1) and (2) are used as the basis to construct the ITS 3.8.6 Actions A.1 and A.2. Action A.1 requires the verification of pilot cell parameters of electrolyte level and float voltage. A time period of one hour is discussed Catawba Units 1 and 2 Page A - 7 Supplement 67l I

L.

Discussicn of Chingas Section 3.8 - Electrical Power Systems ADMINISTRATIVE CHANGES in a more restrictive change, M.14, later in these discussion of changes. Action A.2 calls for the verification of all Category C limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a verification every 7 days thereafter.

Currently, only 7 days is allowed for the parameter to exceed the listed value, .but this is extended to 31 days in a less restrictive allowance L.16, which is discussed later in these changes. With the noted exceptions, this change is administrative in nature and consistent with NUREG-1431.

A.38 CTS 4.8.1.1.4 a. and b. for the DG batteries are changed to the ITS format and form ITS 3.8.6 Action C. This requires a DG battery to be declared inoperable whenever electrolyte level or representative cell temperature exceed specified limits. The number "six" has been replaced with the . term " representative" for quantity of cells to be sampled, and addressed in a removal of detail change, LA.32, later in these discussion of changes. ITS SR 3.8.6.4 is also formed from 4.8.1.1.4 b. 2) and also incorporates these changes. This is not considered a significant technical change and only reflects the recommendations of the standard by which the requirement was originally derived. This maintains the technical requirements of the CTS and the change is considered administrative in nature. This change is consistent with the format of NUREG-1431.

A.39 ITS SR 3.8.6.4 is created from CTS 4.8.1.1.4.b.2 and 4.8.2.1.1.b.3 for the DG and Class .1E batteries. .These require the battery electrolyte temperature of connected ' cells to be > 60 F. ITS SR l- 3.8.6.4 requires the Class IE and DG batteries for representative-cells to be 2: 60 F. No significant technical requirements are made with this change and it is considered administrative. The change is consistent with the format of NUREG-1431.

.A.40 Item (b) to ITS Table 3.8.6-1 is created by combining CTS Table

! 4.8-3 notations (4) and (5). These state, " corrected for electrolyte temperature and level, or battery charging current is less than 2 amps when on charge." The two notes are tied together

- with ,the phrase, " Level correction is not required, however". _

This change maintains the intent of the CTS and does not modify the technical requirements of the two notes. The change is considered administrative and is consistent with NUREG-1431.

Catawba Units 1 and 2 Page A - 8 Supplement 57 l

Discussicn of Changes Section 3.8 - Electrical Power Systems ADMINISTRATIVE CHANGES A.65 Not Used.

A.66 Not used.

A.67 Added to the requirements of CTS LCOs 3.8.3.1 and 3.8.2.1 is an action which requires if two or more of the required buses or channels are inoperable that results in a loss of safety function, LC0 3.0.3 must be entered immediately. This action is necessary because the ITS requires that all applicable conditions be entered within the actions table. This could result in a case where distribution systems were inoperable on opposite trains such that a loss of safety function exists. The clarification in ITS 3.8.9 will ensure that with a loss of any electrical power distribution system, no loss of function will occur without the appropriate action being taken. Therefore, this change is administrative and is consistent with NUREG-1431.

A.68 CTS LCO 3.8.3.2 is converted to ITS LCO 3.8.8 for the requirements of inverters during shutdown. The LCO and SR statemknt is also clarified to indicate that only a single AC vital bus power source (inverter or regulated voltage transformer) is required to support a second operable AC vital bus distribution subsystem whenever a

^second distribution subsystem is required. This is consistent with the definition of operability that either the normal or emergency power source is necessary for equipment operability.

The technical requirements are maintained with only changes in wording and ,%rmat and clarification of existing requirements.

Therefore these changes are considered administrative in nature and the change is consistent with format of NUREG-1431.

l Catawba Units 1 and 2 .Page A - 13 Supplement 7 l l- I w _- _ _ _ _ _-__ 1

Justification far Deviaticns l Section 3.8 - Electrical Power Systems l

l l

TECHNICAL SPECIFICATIONS l entering these actions. The CTS approach moved the required actions l for LTOP into the electrical distribution actions. The NUREG approach directs the operator to enter the actions for the affected LTOP feature. This approach maintains the intent of the existing requirements, however, it allows the operator to evaluate the loss of electrical support equipment and take appropriate actions. If the loss of electrical equipment does not affect the LTOP features (bus is l inoperable, but energized), then unnecessarily restrictive actions may be averted.

l 14. Not used.

15. The proposed change is consistent with generic change TSTF-38 submitted to the NRC by the industry Technical Specifications Task Force.

< 16. Not Used.

17. Not used.

18. A note to CTS LC0 3.8.2.1 provides allowance for a vital bus to be disconnected from its DC source for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other vital buses are OPERABLE and energized. A similar note in CTS LC0 3.8.3.1 provides this allowance for a inverter during a battery equalizing charge provided the associated AC vital bus is OPERABLE and energized and the three other AC vital busses are OPERABLE and energized. The deletion of the bracketed Note in NUREG-1431 is acceptable because the inverter, being source of power for the vital bus, remains connected to the required DC Source, with a qualified battery and battery charger. Therefore, the allowance is not needed and is deleted.

19. CTS 3.8.3.2.c requires a single train (two channels) of AC vital busses connected to their associated inverters and respective DC sources in MODES S and 6. STS 3.8.5, for DC sources, and STS 3.8.8, for inverters, requires that DC sources and inverters be OPERABLE to support the distribution systems required OPERABLE by STS 3.8.10 in l MODES 5 and 6. In certain instances, two trains of a plant system, i e.g. control room filtration, is required OPERABLE and requires an OPERABLE power supply. The CTS, however, does not require that the distribution system for the second filtration train be provided with an inverter or battery and charger pair. The only requirement is l

. Catawba Units 1 and 2 3 Supplement 57 l l

l

l Justification for Divistions Section 3.8 - Electrical Power Systems TECHNICAL SPECIFICATIONS that the required filtration train be OPERABLE. The definition of OPERABILITY only requires the normal or emergency power source be OPERABLE. The 4160 V bus powering either filtration train could be powered from either an offsite circuit or a DG. Likewise, the DC l

vital bus and AC vital bus distribution systems could be powered from either a battery or charger backed inverter or the regulated transformer and would be considered OPERABLE. This is consistent with the operability descriptions in the STS 3.8.10 Bases for distribution systems, that is, the distribution systems must be !

energized to be OPERABLE. However, the STS 3.8.4 and 3.8.5 Bases for inverters requires them to be connected to their associated AC j vital buses for the inverters to be considered OPERABLE. The STS 3.8.7 and 3.8.8 Bases for DC sources requires both a battery and charger to be OPERABLE to have an OPERABLE DC source. Since STS 3.8.10 sometimes requires portions of both electrical power distribution trains to be OPERABLE (i.e., energized), the STS LCO 3.8.5 and 3.8.8 statements, as written, would require a second complete train of OPERABLE inverters and DC sources. This is 1 significantly more restrictive than the CTS requirement which only l requires one complete train of normal and emergency power supplles in these MODES. Therefore, the ITS LCO 3.8.5 and 3.8.8 are revised, consistent with the current licensing basis, to only require one train of DC sources and inverters OPERABLE and clarifies that the second distribution system train, if required OPERABLE by 3.8.10, only be energized from an appropriate source. An appropriate source would be either the battery or charger for the DC vital bus, and the inverter or regulated voltage transformer for the AC vital bus.

i

(

l Catawba Units 1 and 2 4 Supplement 67l l

DC Sources-Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutthm C g s; disn'm af )(esei Mw (M)DCel=t uuJ s,6re.D LCO 3.8.5 electrical r subsystem shall'be the DC el to support cal power distribution system (s) required by LCO 3. O.

Distribution Syst Shutdown."

APPLICABILITY: H0 DES S and 6 During movement of irradiated fuel assemblies.

ACTIONS C0f0lTION REQUIRED ACTION COMPLETION TIE i A. One or' more required A.1.1 Ecw=hWDC electrical power Declare affected Immediately required feature (s) g subsy, stems noperable. inoperable.

.. .a u x tad aup*aar fHsys'V x

A.2.1 g Immediately A.2.2 Suspend movement of Immediately irradiated fuel .

assemblies.

, j A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

(continued) 3,8 28 Rev 1. 04/07/95 akk ,

\

l j i

INSERT 1 The foilowing shall be OPERABLE:

a. Two channels of DC electrical power subsystems and a train of DG DC electrical power subsystem capable of supplying one train of the DC i electrical power distribution subsystem (s) required by LCO 3.8.10, b

" Distribution Systems Shutdown," and

b. One source of DC electrical power, other than that required by LCO 1 3.8.5.a, capable of supplying the remaining train of the DC electrical power distribution subsystem (s) when required by LCO 3.8.10.

l i

INSERT PAGE 3.8-23 Catawba

l Inverters-Shutdown

, 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters-Shutdown l

LCO 3.8.8 iTriveners sna Deuruve w support the on ' e Class 1E T AC vital electrical r distribution system (s) gequir y LCO 3.8.10 Distribution S i

s-Shutdown. " j APPLICABILITY: H0 DES 5 and 6 During movement of irradiated fuel assemblies.

ACTIONS CONDITION -

~ '~

REQUIRED ACTION COMPLETION TIE A. One or more required [A.1 Declare affected Opvprter4 inoperable. Immediately required feature (s) inoperable, f-n AC wiel $st (Lv Mes~n a A.2.1 Suspend CORE Immediatel'y ALTERATIONS.

E A.2.2 Suspend movement of Immediately irradiated fuel -

assemblies.

M i

A.2.3 Initiate action to Immediately suspend operations "

involving positive .

reactivity additions. j M

(continued)

WOP 51S '

3.8 36 Rev 1. 04/07/95 gJ~

i l

i The following shall be OPERABLE:

a. Two inverters capable of supplying one train of the onsite Class 1E AC vital bus electrical power distribution subsystem (s) required by LCO 3.8.10, " Distribution Systems-Shutdown," and 1

b. One source of AC vital bus power, other than that required by LCO 3.8.8.a, capable of supplying the remaining onsite Class 1E AC vital bus electrical power distribution subsystem (s) when required by LCO 3.8.10.

l 8

i i

INSERT PAGE 3.8-36 Catawba

inverters-Shutdown 3.8.8 l ACTIONS CONDITION REQUIRED ACTION l COMPLETION TIME l

A. (continued) A.2.4 Initiate action to Immediately

. restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE

, FREQUENCY.

SR 3.8.8.1 Verify corrb voltage / 7 days I f a /f

, I vita nt$torequiredAC I y ,

J.

e I

i I

3.8 37 Rev 1. 04/07/95 ca6A l i

l DC Sources-Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources-Shutdown BASES i I

BACKGROUM)

A description of the DC sources is provided in the Bases for LCO 3.8.4. "DC Sources-Operating."

u APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the FSAR Cha rX6P(Ref.1) and [

. ChapterX15)*(Ref. 2), assume that systems are OPERABLE. The DC electri al ineered power Safety system Feature j i

provides normal and emergency DC electrical power for the diesel generators m.ganicy auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of irradiated fuel assemblies ensures that:

a.

The unit can be maintained in the shutdown or refueling condition for extended periods:

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident. l The DC sources satisfy Criterion 3 of fhe muronen N-lo cca.So.34. N f.iT) a LCO The DC electrical power subsystems. LM 8 b ef lensh D subsystem inh consisting of two batteries, one battery charger per '

batter the corresponding control equipment and kd*T) \

(continued)

WOJ4fS B 3.8-60 Rev 1. 04/07/95

'Coth M l

a _ _ - _ - _ _ _ _ _ - - - _ _ -

l INSERT

2) when the redundant train of DC electrical power distribution subsystem is required by LCO 3.8.10, the other subsystem consisting of either a battery or a charger, and 3) i i

i l

I l

l l-5 INSERT Page B 3.8-60 l Catawba l

u__-___------_------- - _ - - . - - - _ - _ - _ - - - - - - - - - - - _ - - - - - - - - - - - - _ - - --

Inverters-Shutdown B 3.8.8 BASES (continued)

LCO The inverters ensure the availability of electrical power Af least huo AC for reactor the instrumentation and maintain it in afor safesystems required tow%)

shut g m m) down [ i Q the condition after battery powered inverters provide uninterruptible supply ofantici an g' . I

{ quod. eb bh> AC electrical power toAB CYIERT~lii!Rs even if the >

4.16 kV safety buses are de. energized.

OPERABILITY of the g"Md6 inverters requires that the AC vital bus be powered by the inverter QMh,; m.eo. VThis ensures the availability of sufficient power sources to operate the unit in a safe manner o ano to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents). l APPLICABILITY TheinvertersrequiredtobeOPEEABLEinH00ES5and6and during movement of irradiated fuel assemblies provide i assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling acciilent are available:

j

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for H00ES 1. 2. 3. and 4 are covered in LC0 3.8.7.

ACTIONS A.1. A.2.1. A.2.2. A.2.3. and A.2.4 If two trains are required by LCO 3.8.10.

Distribution Systems-Shutdown." the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow i l

continuation of CORE AL1ERATIONS, fuel movement, and operations with a potential for positive reactivity additions. By the allowance of the option to declare (continued) l#]Gr$TS '

B 3.8 76 Rev 1. 04/07/95 CA i

INSERT @

When the redundant train of class 1E AC vital bus electrical power l

distribution subsystem is required by LCO 3.8.10, the power source for these AC vital buses may consist of 1) the associated inverter powered by its associated battery; or 2) the constant voltage source transformer.

INSERT Page B 3.8-76 Catawba

McGuire & Catawba improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8 Additionalitems 3.8-14 CTS 3.8.1 -l DOC LA12 {

DOC LA12.adicates that the CTS detail related to CTS 3.8.1 action c for the turbine driven AFW pump operability verification is moved to the Bases for 3.7.5. The correct location is 3.8.1. The DOC has been corrected.

l i

f mc4_cr_3.8 84 July 14.1998 I

Discussign cf Ching2s Section 3.8 - Sectrical Power Systems TECHNICAL CRANGES - REMOVAL OF DETAILS LA.10 Not used. f

-LA.11 CTS SR 4.8.1.1.2.1.2 and 4.8.1.1.2.1.3 requires tests or measurements on the diesel fuel oil system tanks. These requirements have been moved from the TS to the Selected Licensee Commitments (SLC)(UFSAR Chapter 16) consistent with NUREG-1431.

This level of detail is not necessary for inclusion within the TS.

Changes to the SLC are reviewed and controlled in accordance with the requirements of.10 CFR 50.59. These controls are adequate to assure any change is properly reviewed.

LA.12 CTS 3.8.1.1 Action c requires an evaluation of the steam driven auxiliary feedwater pump to determine OPERABILITY when the plant is in Modes 1, 2, or.3 with steam pressure greater than 600 psig.

This rc:;;ir= ,t ITS 3.8.1 octions require o verificotton that redundant required features are operable. The steam driven pump is a redundant required feature, therefore, the CTS detail has been moved from the TS to the Bases of ITS ITS 3r7763.8.1. This.

level of detail is not necessary for inclusion within the TS and more appropriate to the cases. This is consistent with NUREG-1431. Changes to tne Bases are reviewed and controlled in accordance with the requirements of 10 CFR 50.59 and the Bases control program as defined in Chapter 5, " Administrative Controls" of the ITS. These controls are adequate to assure any change is properly reviewed.

LA.13/LA.14 Not used.

LA.~15 CTS 3.8.1.2 Action provides detailed instructions for operations of loads over fuel storage pool. These requirements have been moved from the TS to the Selected Licensee Commitments (SLC)

(UFSAR-Chapter'16) consistent with NUREG-1431. This level of detail is not necessary for inclusion within the TS. Changes to the SLC are reviewed and controlled in accordance with the j i

I Catawba Units 1 and 2 Page LA - 3 Supplement 67l l

t

McGuire & Catawba Improven TS Review Comments Section 5.0, Administrative Controls 5.3, Unit Staff Qualifications 5.3.1 Regulatory Guide (RG) 1.8, Revision 2, was released concurrent with the 1987 change to 10 CFR Part 55 and describe:: an acceptable means of meeting the rule. The Statement of Consideration for the Part 55 rule change states, "Those facility licenses that have made a commitment that is less than that required by the new rules must conform to the new rule automatically." The Statement of Consideration for the Part 55 rule change further states,

" Details regarding other training and qualification will not be required to be supplied on Form NRC-398, if thess requirement are contained in an NRC-approved training program that uses a simulation facility acceptable to the NRC under 9 55.45(b). Subject to cucinued Commission endorsement of the industry's accreditation process under the Final Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147; March 20,1985), a facility licensee's training program would be approved by being accredited by the National Nuclear Accrediting Board."

Comment: When the NRC endorsed the industry's accreditation process as an acceptable alternative to providing specific information on the license application, the eligibility guidance in the accredited training programs was considered to be equivalent to the NRC criteria in RG 1.8, Revision 2. Your proposed requirement, on the other hand, references Rev. O of RG 1.8, dated September 1975. Please describe how your proposed requirement which is different from RG 1.8, Revision 2 meets the intent of the Statements of Consideration for 10 CFR Part !

55. Alternatively, you may consider revising your proposed requirement.

DEC Response:

The staff comment does not appar to be related to the actual TS content. CTS 6.3.1 and ITS 5.3.1 make reference to RG 1.8. Rev. O only with regards to the Radiation Protection Manager and makes no reference to operator licensing and training programs.10 CFR 55 is i related to the requirements for licensed operators and does not relate to the Radiation l Protection Manager position or other staff positions. Requirements for operator training and accreditation are not addressed by ITS 5.3.1 nor by the STS 5.3.1. CTS 6.4.1 does discuss the operator training and replacement programs and explicitly states that it complies with 10 CFR 55. However, this section is deleted from the ITS consistent with NUREG 1431 on the basis that the requirements of the regulation are directly implemented and enforceable. DEC i does not believe that the proposed requirements for the Radiation Protection Manager and I reference to RG 1.8, Rev. O for that position are in any way related to 10 CFR 55 and believes that the proposed ITS 5.3.1 for personnel qualifications is consistent with current !

licensing basis.

REVISED RESPONSE:

DEC will review RG 1.8, R2, and consider an appropriate TS change for operator qualification, if necessary, however, this will be dono separate from the ITS conve.sion effort.

l mc5_cr_5.0 .21 July 14,1998 l

f McGuire & Catawba Improved TS Review Comments )

Section 5.0, Administrative Controls I l

5.0, Additional items j 5.0-1 STS 5.5.11

!TS 5.5.11 CTS 3.9.4 Tho CTS requirements for containment purge filter package testing specify the flow rate in terms of both exhaust fans rather than for a single train. The ITS and STS markups are corrected to identify that this flow rate is a two fan flow rate. Additionally, the STS language uses the term " system flowrate" when describing the required testing. This is misleading since for some systems, the flowrates are for individual trains, rather than for the " system."

l To avoid confusion, the word " system" is deleted. This is an administrative clarification and does not affect the specific flow rate requirements, since where two fans are required, it is stated in the requirement.

For McGuire, the Fuel Building Ventilation Exhaust system is a non-ESF system. There is only one filter package per unit and there is no redundancy. The term non-ESF is added to the system name since the STS headings generically refer to the fitratica packages as ESF systems.

I l

I i

I l

l l

mc5_cr_5.0 22 July 14,1998 l

j Progrc:c and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.10 Secondarv Water Chemistry Proaram This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical l variables and control points for these variables;

b. Identification of the procedures used to measure the values of the critical variables;

c. Identification of process sampling points, which shall l include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d. Procedures for the recording and management of data;

e. Procedures defining corrective actions for all off control point chemistry conditions; and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.11 Ventilation Filter Testina Proaram (VFTP1 A program shall be established to imphat the following required testing of Engineered Safety Feature RSF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ANSI H510-1980, with exceptions as noted in the UFSAR.

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI l N510-1980 at the flowrate specified below

10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 1% 9000 cfm Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust < 1% 30,000 cfm Containment Purge (non-ESF) (2 fans) < 1% 25,000 cfm Fuel Bldg. Ventilation < 1% 16,565 cfm (continued) l l Catawba Unit 1 5.0-20 Supplement 7 l

l

Programs and Manuals j 5.5 <

l 5.5 Programs 3nd Manuals

)

5.5.11 ventilation Filter Testina Proaram (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test i of the charcoal adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate l specified below i 10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 1% 9000 cfm 1 Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust < 1% 30,000 cfm i Containment Purge (non-ESF) (2 fans) < 1% 25,000 cfm i Fuel Bldg. Ventilation < 1% 16,565 cfm

)

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of s 30*C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration Rll Annulus Ventilation < 4% 95%

Control Room Area Ventilation < 0.95% 95%

Aux. Bldg. Filtered Exhaust < 4% 95%

Containment Purge (non-ESF) < 6% 95%

Fuel Bldg. Ventilation < 4% 95% l l

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified l below i 10%.

ESF Ventilation System Delta P Flowrate Annulus Ventilation 8.0 in wg 9000 cfm i Control Room Area Ventilation 8.0 in wg 6000 cfm Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm Containment Purge (non-ESF) (2 fans) 8.0 in wg 25,000 cfm i Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm ,

I (continued) l Catawba Unit 1 5.0-21 Supplement 7 l

Programs and Manual.c 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testina Proaram (VFTP) (continued)

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage 0 600 vac Annulus ventilation 45 1 6.7 kW Control Room Area Ventilation 25 1 2.5 kW Aux. Bldg. Filtered Exhaust 40 1 4.0 kW Containment Purge (non-ESF) 120 1 12.0 kW i l Fuel Bldg. Ventilation 80+8/-17.3kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

4 5.5.12 Exolosive Gas and Storaae Tank Radioactivity Monitorina Proaram i

This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity contained in unprotected out6yar liquid storage tanks. The gaseous radioactivity quantit1G dull be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5,

" Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, " Postulated i Radioactive Release due to Tank Failures". 1 The program shall include: I

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);

b. A surveillance program to ensure that the quantity of radioactivity contained in each gas storage tank or connected gas storage tanks and fed into the offgas treatment system is less than the amount that would result in a Deep Dose Equivalent of > 0.5 rem to any individual in l an unrestricted area, in the event of an uncontrolled release of the tanks' contents; and (continued) l l Catawba Unit 1 5.0-22 Supplement 7 l

P mgrams and Mar.uals 5.5 5.5 Programs and Manuals (continued) 5.5.10 Secondary Water Chemistry Proaram This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables;

b. Identification of the procedures used to measure the values of the critical variables;

c. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d. Procedures for the recording and management of data;

e. Procedures defining corrective actions for all off control point chemistry conditions; and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.11 Ventilation Filter Testina Proaram (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980, with exceptions as noted in the UFSAR.

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI i l N510-1980 at the flowrate specified below i 10%. !

ESF Ventilation System Penetration Flowrate !

Annulus Ventilation < 0.05% 9000 cfm Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust < 0.05t 30,000 cfm Containment Purge (non-ESF) (2 fans) < 14 25,000 cfm Fuel Bldg. Ventilation < 0.05% 16,565 cfm i

(continued) l Catawba Unit 2 5.0-20 Supplement 7 l

E--_ _--_ _ _ _ _ _ _ _ - _ _ _ - - - _ _.

Programs and Manuals 5.5 5.5_ Programs and Manuals

~

5.'5.11 Ventilation Filter'Testino Prooram (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate l specified below

10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation' < 0.05% 9000 cfm Control Room Area Ventilation < 0.05% 6000 cfm l Aux. Bldg. Filtered Exhaust < 0.05% 30,000 cfm Containment Purge (non-ESF) (2 fans) < 1% 25,000 cfm Fuel Bldg.-Ventilation < 0.05% 16,565 cfm

-c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less' than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of s 30*C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH Annulus Ventilation < 4% 95% i Control Room Area Ventilation < 0.95% 95%

Aux. Bldg. Filtered Exhaust < 4% 95%

Containment Purge (non-ESF) < 6% 95%

Fuel Bldg. Ventilation < 4% 95's l J

d. . Demonstrate for each of the ISF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52,

Revision 2, and ANSI N510-1980 at the flowrate specified l below

10%.

ESF Ventilation System Delta P Flowrate Annulus Ventilation 8.0 in wg 9000_cfm !

- Control Room Area Ventilation 8.0 in wg 6000 cfm

' Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm

. Containment Purge _ (non-ESF) (2 fans) 8.0 in wg 25,000 cfm Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm i (continued)

I Catawba ~ Unit 2- 5.0-21 Supplement 7 l

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testina Proaram (VFTP) (continued)

e. Demonstrate that the heaters for each of the ESF systems ,

-dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage 9 600 vac Annulus Ventilation 45 1 6.7 kW Control Room Area Ventilation 25 1 2.5 kW Aux. Bldg. Filtered Exhaust 40 1 4.0-kW Containment Purge (non-ESF) 120 1 12.0 kW l Fuel Bldg. Ventilation 80+8/-17.3kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test-frequencies.

5.5.12 Exolosive Gas and Storace Tank Radioactivity Monitorina Proaram This program provides controis for potentially explosive gas mixtures contained in the Waste Gas Holdup' System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity <

contained 'in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, .

" Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, " Postulated Radioactiv ' Release due to Tank Failures". j The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether er not the system is designed to withstand a_ hydrogen explosion);

b. A surveillance program to ensure that.the quantity of radioactivity contained in each gas storage. tank or connected gas storage tanks and fed into the offgas treatment system is less than the amount that would result i in a Deep Dose Equivalent of 2 0.5 rem to-any individual in an unrestricted area, in the event of an uncontrolled l release of the tanks' contents; and

( ;

l: (continued) l

. l Catawba Unit 2 - 5.0-22 Supplement 7 l i __ ____-_ __ _ _ . - - - - _ _ _ _ _

_ _ - - - . - - - _ _ ___--_---------_--_-__________--___-j

Specification 5.0 INSERT 5 (Unit 1) 5.5.11 Ventilation Filter Testing Program (VFTP)

%/V A program shall be established to implerut the following required testing of Engineered Safety Feature (ESP) filter ventilation systems in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980, with exceptions as noted in the UFSAR.

a. Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below

10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation <1% 9000 cfm Control Room Area Ventilation < 0.05% 6000cfm Aux. Bldg. Filtered Exhaust <1% 30,000 cfm Containment Purge (non-ESF)(2fcms) <1% 25,000 cfm l Fuel Bldg. Ventilation <1% 16,555 cfm

b. Demonstrate for each of the ESF systems that an inplace test of (be charcoal adsorber shows the following penetration and system bypa:s when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below

10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation <1% 9000 cfm Control Room Area Ventilation < 0.05% 6000 cfm Aux, Bldg. Filtered Exhaust <1% 30,000 cfm Containment Purge (non-ESF)(2 fans) <1% 25,000 cfm l Fuel Bldg. Ventilation <1% 16,565 cfm

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in ,

Regulatory Guide 1.52, Revision 2, shows the methyl iodide

penetration less than the value specified below when tested in L accordance with ASTM D3803-1989 at a temperature of 30 C and greater than or equal to the relative humidity specified below.

Catawba ./ Page33of 4(e L__ _ _ _ _ _ _ _ _ _ __- = __- _ _ _ _ _ __. __ -

Sp:cification 5.0 INSERT S (continued) (Unit 7,

A.M ESF Ventilation System' Penetration RH Annulus Ventilation <4% 95 %

Control Room Area Ventilation < 0.95% 95 %

Aux. Bldg. Filtered Exhaust <4% 95 %

Containment Purge (non-ESF) <6% 95 %

Fuel Bldg. Ventilation <4% 95 %

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified belowi 10%.

ESF Ventilation System Delta P Flowrate Annulus Ventilation 8.0 in wg 9000 cfm Control Room Area Ventilation 8.0 in wg 6000 cfm Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm Containment Purge (non-ESF)(2 fans) 8.0 in wg 25,000 cfm l Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage @ 600 vac Annulus Ventilation 45 6.7kW Control Room Area Ventilation 25 2.5kW Aux. Bldg. Filtered Exhaust 40 4.0kW Containment Purge (non-ESF) 120 12.0 kW Fuel Bldg. Ventilation 80 + 8/-17.3 kW The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

l Catawba - 1 PageNof (g(s

Specification 5.0 INSERT 5 (Unit 2) k./Y 5.5.11 Ventilation Filter Testine Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems in accordmce with kegulatory Guide 1.52, Revision 2, and ANSI N510-1980, with exceptions as noted in the UFSAR.

a. Demonstrate for each of the ESF . systems that an inplace test of the high efficiency particulate air (HEPA) filters shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below

10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 0.05% 9000 cfm Control Room Area Ventilation -< 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust < 0.05% 30,000 cfm Containment Purge (non-ESF) (2 fans) <1% 25,000 cfm l Fuel Bldg. Ventilation < 0.05% 16,565 cfm

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below 10%.

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 0.05% 9000 cfm Control Room Area Ventilation - < 0.05% 6000 cfm

- Aux. Bldg. Filtered Exhaust < 0.05% 30,000 cfm Containment Purge (non-ESF) (2 fans) <1% 25,000 cfnj Fuel Bldg. Ventilation < 0.05% 16,565 cfm

c. Demonstrate for each of the ESJ sstems that a laboratory test of a sample of, the charcoal- adsorber, when obtained as desc.ied in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than tl# value specified below when tested in accordance with ASTM D.Q3-1989 at a temperature of$ ; 30 C and greater than or equal to the relative humidity specified below.

[ Catawba A Page Sof Ir 4 l

L

Specification 5.0 INSERT 5 (continued) (Unit 2)

A. N ESF Ventilation System Penetration RH Annulus Ventilation <4% 95 % l Control Room Area Ventilation < 0.95% 95 % l Aux. Bldg. Filtered Exhaust <4% 95 % !

Containment Purge (non-ESF) <6% 95 %

Fuel Bldg. Ventilation <4% 95 %

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is ,

less than the value specified below when tested in accordance with i Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below

10%.

ESF Ventiladon System Delta P Flowrate Anmilus Ventilation 8.0 in wg 9000 cfm Control Room Area Ventilation 8.0 in wg 6000 cfm Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm Containment Purge (non-ESF) (2 fans) 8.0 in wg 25,000 cfm l Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage @ 600 vac Am>ulus Ventilation 45 6.7kW Control Room Area Ventilation 25 2.5kW Aux Bldg. Filtered Exhaust 40 4.0kW Containment Purge (non-ESF) 120 12.0 kW Fuel Bldg. Ventilation 80 + 8/-17.3 kW The provisiori of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

Catawba A Page 9f'of /p/p r

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.10 Secondary Water Chemistry Prooran This progras provides controls for monitorino secondary water .

chemistry to inhibit SG tube degradation 4nd Mw or*<<ure turpm 37Ff ytreps cortpsion crpcKirp. The program shall include: l I a. Identification of a sampling schedule for the critical-variables and control points for these variables:

b. Identification of the procedures used to measure the values of the critical variables;

c. PJentification of process sampling points, which shall include monitoring the discharge of the condensate ptmps for evidence of condenser in leakage:

d. Procedures for the recording and management of data:

e. Procedures defining corrective sctions for all off control point chemistry conditions: and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action. .,

5.5.11 Ventilation Filter Testino Procram (VFfP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems /5E cne rpeguencieur= cme < vin sxeuuisory GuiW ],A@

in accordance wit?pfR M N510 1 latory Guide 1.52. Revision z. g 1gg g, g Q3 % ,,

a. Demonstrate for each of the ESF systems that an inplace test ttt.

of the high efficiency particulate air JHEPA) filters shows penetrationtndsystembypassl<JKOR@vhentestedin MM. '

) N510 1accordance withp(Regulatory Guide 1.bz. Revision 2. andM g- "

at the@owrate specified belyi 10g?. l S

fiksEST 1a tw Ven ~1ation Systef

~ %r ow

~ -

(continued) .

[STS 5.0 12 Revi.04/07/95 Y

t

INSERT 7a (Unit 1)

ESF Ventilation System Penetration Flowrate Annulus Ventilation <1% 9000 cfm Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust <1% 30,000 cfm Containment Purge (non-ESF) (2 fans) <1% 25,000 cfm l Fuel Bldg. Ventilation <1% 16,565 cfm i

i

(

Catawba Unit 1 INSERl' Page 5.0-12

'f E _ _- _- - -- - _- .

Programs and Manucis I 5.5 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testino Prooras (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test of the cha dsorber shows@ penetration and system _@ Qllo#i bypass when test roarice wit latory Guide 1.bz. Revision 2. and flowrate specified belopt 10%

10 1 g

t

g "

g ut ventilation tem lowrat

[ lNSERT % %

= / _ _

c. Demonstrate for each of the ESF systems that a laboratory test of a s le of the charcoal adsorber, when gb ained as described i Regulatory Guide 1.52. Revision 21.)shows the methyl iodi penetration less than the value specift i

below when tested in accordance withp[ASTN 03803 1989 ta j temerature of _<J30*C3"lind greater than or equal to the relative humiditf specified below.

@ IESF Ve n io ystem Penetrat

[/uss.r7t/

~ - ~

[~

[

efficiency for Q,

ewer's Note:

lowable penetration ecoal credited in sta

[560%

-)

metnyi 1 safety evaluations /

)

(safety factor .

.m Safety fa r = [5] for systems th heaters.

= [7] for syst without heaters. :,

d. ~

Demonstrate for each of the ESF systems that the pressure dr across the combined HEPA filters, the prefilters and t

charcoal adsorbers is less than the value specified below when tested in accordance witt Regulatory Guide 1.52.

(continued)

M 5.0 13 Rrc 1. 04/07/95 i

e

INSERT 7b (Unit 1) 0 ESF Ventilation System Penetration Flowrate Annulus Ventilation <1% 9000cfm Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust <1% 30,000 cfm Containment Purge (non-ESF) (2 fans) <1% 25,000 cfm l Fuel Bldg. Ventilation <1% 16,565 cfm INSERT 7c (Unit 1)

ESF Ventilation System -Penetration RH Annulus Ventilation <4% 95 %

Control Room Area Ventilation < 0.95% 95 %

Auxiliary Bldg. Filtered Exhaust <4% 95 %

Containment Purge (non-ESF) ' <6% 95 %

Fuel Bldg. Ventilation <4% 95 %

l I

l i

i l

Catawba Unit i INSERT Page 5.0-13

!5

Programs and Manuala l

I 5.5 5.5 Programs and Hanuals '

5.5.11 Ventilation Filter Testino Prooram (VFTP) (continued) 10 19 at the @flowrate specified g ESF Ventilation System Delta P _ ___ _

ate fin $etT ~\Ef /

c n a /a ai

e. Demonstrate that the heaters for each ESF systems

' dissipate the value fled belowf A I in accordance with when tested ESF Ventilation System 5101T. -

c Wattage r--

._3_

ImEAT1tf The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Exolosive Gas and Storaoe Tank Radioactivity Monitorina Prooram This program provides controls for potentially exp sive gas mixtures contained in thef(Waste Gas Holdup Syst the quantity of radioactivity contained in gas storage tanks or into tha i.

i offgas treatment system, and the quantity of radioactivity etntained in unprotected outdoor 11guld storage tanksW The ,

(;

' gaseous radioactivity quantities shall be determined following the methodology inC(Branch Technical Position (BTP) ETSB 115

Ptstulat Failure *}g Radioactive The liquid radwaste Releasequantities due to Waste shall be Gas System Leak determined in or t

f accordance wit Standard Review Plan. 5. tion 15.7.3 " Postulated Radioactive Re ease due to Tank failurer .

j The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the f(Waste Gas Holdup System 3%nd a surveillance program to

! ensure the limits are maintained. Such limits shall be (continued) 1 l jped 5.0-14 Rev 1. 04/07/95 h NM

INSERT 7d (Unit 1)

ESF Ventilation System Delta P Flowrate

' Annulus Ventilation 8.0 in wg 9000 cfm Control Room Area Ventilation 8.0 in wg 6000 cfm Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm Containment Purge (non-ESF) (2 fans) 8.0 in wg 25,000 cfm l Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm INSERT 7e (Unit 1)

ESF Ventilation System Wattage @ 600 VAC Annulus Ventilation 45 6.7kW Control Room Area Ventilation 25 2.5kW Aux. Bldg. Filtered Exhaust 40 4.0kW Containment Purge (non-ESF) 120 12 kW Fuel Bldg. Ventilation 80 + 3/17.3 kW Catawba Unit l' - INSERT Page 5.0-14 1

I

i

)

INSERT 7a (Unit 2) g i

l ESF Ventilation System Penetration Flowrate Annulus Ventilation < 0.05% 9000 cfm j Control Room Area Ventilation < 0.05% 6000 cfm l ' Aux. Bldg. Filtered Exhaust < 0.05% 30,000 cfm ,

Containment Purge (non-ESF) (2fems) <1% 25,000 cfm l !

Fuel Bldg. Ventilation < 0.05% 16,565 cfm !

l I

l 1

l l

t I l 1 l

1 Catawba Unit 2 INSERT Page 5.0-12 1

l INSERT 7b (Unit 2) -

D i

ESF Ventilation System Penetration Flowrate Annulus Ventilation < 0.05% 9000 cfm

! Control Room Area Ventilation < 0.05% 6000 cfm Aux. Bldg. Filtered Exhaust < 0.05% 30,000 cfm Containment Purge (non-ESF)(2fems) <1% 25,000 cfm l Fuel Bldg. Ventilation < 0.05% 16,565 cfm INSERT 7c (Unit 2) g l

ESF Ventilation System Penetration RH Annulus Ventilation <4% 95 %

i- Control Room Area Ventilation < 0.95% 95 %

Auxiliary Bldg. Filtered Exhaust <4% 95 %

Containment Purge (non-ESF) <6% 95 %

i Fuel Bldg. Ventilation <4% 95 %

l c

i-l-

L.

Catawba Unit 2 INSERT Page 5.0-13

\,

s.

INSERT 7d (Unit 2) I ESF Ventilation System Delta P Flowrate Annulus Ventilation 8.0 in wg 9000 cfm Control Room Area Ventilation 8.0 in wg 6000 cfm Aux. Bldg. Filtered Exhaust 8.0 in wg 30,000 cfm Containment Purge (non-ESF)(2fms) 8.0 in wg 25,000 cfm l Fuel Bldg. Ventilation 8.0 in wg 16,565 cfm INSERT 7e (Unit 2) [

ESF Ventilation System Wattage @ 600 VAC Annulus Ventilation 45 6.7kW Control Room Area Ventilation 25 2.5kW Aux. Bldg. Filtered Exhaust 40 4.0kW Containment Purge (non-ESF) 120 12 kW Fuel Bldg. Ventilation 80 + 8/-17.3 kW Catawba Unit 2 . INSERT Page 5.0-14

_ _ - - - - - _ - _ - - - _ _ - - - _ -- _ - - _ - - - - - - - _ - - - - - - - --

v t e Letter Sequence Meeting
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)
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]

ML20236U092

Text

Subject:

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