RA-18-0198, (Cns), Units 1 & 2 - Supplement to License Amendment Request to Revise Technical Specification Section 3.7.8, Nuclear Service Water System

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(Cns), Units 1 & 2 - Supplement to License Amendment Request to Revise Technical Specification Section 3.7.8, Nuclear Service Water System
ML18303A084
Person / Time
Site: Catawba  Duke energy icon.png
Issue date: 10/29/2018
From: Simril T
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-18-0198
Download: ML18303A084 (34)
v • d • e


Text

Tom Simril

( ~ DUKE Vice President ENERGY Catawba Nuclear Station Duke Energy CN01VP I 4800 Concord Road York, SC 29745 o: 803.701.3340 f: 803.701.3221 tom.simril@duke-energy.com RA-18-0198 10 CFR 50.90 October 29, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station (CNS), Units 1 and 2 Facility Operating License Numbers NPF-35 and NPF-52 Docket Numbers 50-413 and 50-414 Supplement to License Amendment Request to Revise Technical Specification Section 3.7.8, "Nuclear Service Water System"

References:

1. Letter from Duke Energy to the NRC dated September 14, 2017, ADAMS Accession No. ML17261B255
2. E-mail from the NRC to Duke Energy dated March 9, 2018, ADAMS Accession No. ML18068A505
3. Letter from Duke Energy to the NRC dated May 8, 2018, ADAMS Accession No. ML18129A053
4. Letter from Duke Energy to the NRC dated August 17, 2018, ADAMS Accession No. ML18232A245 The Reference 1 letter was submitted for the Catawba Nuclear Station (CNS), Units 1 and 2, Facility Operating License (FOL) Numbers NPF-35 and NPF-52, Docket Numbers 50-413 and 50-414, License Amendment Request (LAR) to Revise Technical Specification Section 3.7.8, "Nuclear Service Water System." The Reference 2 email transmitted Requests for Additional Information (RAls) from the NRC associated with the subject matter LAR. The Reference 3 and Reference 4 letters transmitted RAI Responses to the NRC.

The Nuclear Regulatory Commission (NRC) staff reviewed the application and responses to the request for information and concluded that additional information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed amendment.

Attachment 1 to this letter contains the marked-up Technical Specification Pages, and supersedes those marked-up Technical Specification Pages provided in Reference 1 and Reference 3.

Attachment 2 to this letter contains the marked-up Technical Specification Bases pages and insert pages, and supersedes those marked-up Technical Specification Bases Pages and insert pages www.duke-energy.com

U.S. Nuclear Regulatory Commission RA-18-0198 Page 2 October 29, 2018 provided in Reference 1 and Reference 3. Attachment 3 contains marked-up Unit 1 Renewed FOL pages with proposed Additional Condition language related to the associated commitment made in Reference 1.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the significant hazards consideration analysis provided in the original submittal is not altered by the additional information provided.

There are no new regulatory commitments contained in this letter or the attachments.

In accordance with 10 CFR 50 .91, Duke Energy is notifying the State of South Carolina of this request by transmitting a copy of this letter and enclosure to the designated State Official.

Please direct questions on this matter to Douglas M. Brunson, Engineer Ill, at (803) 701-3865.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 29, 2018.

Sincerely, Tom Simril Vice President, Catawba Nuclear Station : Technical Specification Pages (Mark-up) : Technical Specification Bases Pages (Mark-up, For Information Only) : CNS , Unit 1 Renewed Facility Operating License (Mark-up)

U.S. Nuclear Regulatory Commission RA-18-0198 Page 3 October 29, 2018 xc (with enclosure):

C. Haney, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 J. D. Austin, Senior Resident Inspector U.S. Nuclear Regulatory Commission Catawba Nuclear Station M. Mahoney, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mailstop O-8B1A Rockville, MD 20852 L.D. Garner, Manager S.C. DEHEC Radioactive & Infectious Waste Management garnerld@dhec.sc.gov

U.S. Nuclear Regulatory Commission RA-18-0198 Attachment 1 Technical Specification Pages (Mark-up)

FOR INFORMATION ONLY NSWS 3.7.8

3. 7 PLANT SYSTEMS 3.7.8 Nuclear Service Water System (NSWS)

LCO 3.7.8 Two NSWS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ---NOTE--- A.1 ---NOTES---

Not applicable while in 1. Enter applicable Condition C of this LCO Conditions and unless entry is directed Required Actions of by Note 2 of Condition LCO 3.8.1, "AC C. Sources-Operating," for emergency diesel One NSWS train generator made inoperable. inoperable by NSWS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by NSWS.

Restore NSWS train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

(continued)

Catawba Units 1 and 2 3.7.8-1 Amendment Nos. 271/267

FOR INFORMATION ONLY NSWS 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. NOTES B.1 Restore NSWS supply 30 days

1. Entry into this header to OPERABLE Condition shall only status.

be allowed for pre-planned activities as described in the Bases of this Specification.

2. Immediately enter Condition A of this LCO if one or more NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE.
3. Immediately enter LCO 3.0.3 if one or more NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE.

One NSWS supply header inoperable due to NSWS being aligned for single supply header operation.

(continued)

Catawba Units 1 and 2 3.7.8-2 Amendment Nos. 271/267

NSWS 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. -----------NOTES----------- C.1 Restore NSWS train to 14 days

1. Entry into this OPERABLE status.

Condition shall only be allowed for Unit 1 and for pre-planned activities as described in the Bases of this Specification. Entry into this Condition shall not be allowed while Unit 2 is in MODE 1, 2, 3, or 4.

2. Immediately enter Condition A of this LCO if one or more Unit 1 required NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE.
3. Immediately enter LCO 3.0.3 if one or more Unit 1 required NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE.

One NSWS train inoperable due to NSWS being aligned for single Auxiliary Building discharge header operation.

(continued)

!I NSERT 1 here I Catawba Units 1 and 2 3.7.8-3 Amendment Nos. 271/267

INSERT 1 for TS 3.7.8 NSWS 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. NOTES D.1 Restore NSWS Pond 30 days

1. Entry into this return header to Condition shall only OPERABLE status.

be allowed for pre-planned activities as described in the Bases of this Specification

2. Immediately enter Condition A of this LCO if one or more NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE.
3. Immediately enter LCO 3.0.3 if one or more NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE.
4. Entry into this Condition shall only be allowed for 60 days per 12-month period.

One NSWS Pond return header inoperable due to NSWS being aligned for single Pond return header operation.

(continued)

NSWS 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ED. Required Action and ED.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C, or D not met.

ED.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 --------------------------------------NOTE----------------------------

Isolation of NSWS flow to individual components does not render the NSWS inoperable.

Verify each NSWS manual, power operated, and In accordance with automatic valve in the flow path servicing safety related the Surveillance equipment, that is not locked, sealed, or otherwise Frequency Control secured in position, is in the correct position. Program SR 3.7.8.2 ----------------------------------NOTE---------------------------------

Not required to be met for valves that are maintained in position to support NSWS single supply header operation, single Auxiliary Building or discharge header operation, or single Pond return header operation.

In accordance with Verify each NSWS automatic valve in the flow path that is the Surveillance not locked, sealed, or otherwise secured in position, Frequency Control actuates to the correct position on an actual or simulated Program actuation signal.

SR 3.7.8.3 Verify each NSWS pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program Catawba Units 1 and 2 3.7.8-5 Amendment Nos. 271 /267

U.S. Nuclear Regulatory Commission RA-18-0198 Attachment 2 Technical Specification Bases Pages (Mark-up, For Information Only)

NSWS B 3.7.8 B 3.7 PLANT SYSTEMS B 3.7.8 Nuclear Service Water System (NSWS)

BASES BACKGROUND The NSWS, including Lake Wylie and the Standby Nuclear Service Water Pond (SNSWP), provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation, and a normal shutdown, the NSWS also provides this function for various safety related and nonsafety related components. The safety related function is covered by this LCO.

The NSWS consists of two independent loops (A and B) of essential equipment, each of which is shared between units. Each loop contains two NSWS pumps, each of which is supplied from a separate emergency diesel generator. Each set of two pumps supplies two trains (1A and 2A, or 1B and 2B) of essential equipment through common discharge piping.

While the pumps are unit designated, i.e., 1A, 1B, 2A, 2B, all pumps receive automatic start signals from a safety injection or blackout signal from either unit. Therefore, a pump designated to one unit will supply post accident cooling to equipment in that loop on both units, provided its associated emergency diesel generator is available. For example, the 1A NSWS pump, supplied by emergency diesel 1A, will supply post accident cooling to NSWS trains 1A and 2A.

One NSWS loop containing two OPERABLE NSWS pumps has sufficient capacity to supply post loss of coolant accident (LOCA) loads on one unit and shutdown and cooldown loads on the other unit. Thus, the OPERABILITY of two NSWS loops assures that no single failure will keep the system from performing the required safety function.

Additionally, one NSWS loop containing one OPERABLE NSWS pump has sufficient capacity to maintain one unit indefinitely in MODE 5 (commencing 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following a trip from RTP) while supplying the post LOCA loads of the other unit. Thus, after a unit has been placed in MODE 5, only one NSWS pump and its associated emergency diesel generator are required to be OPERABLE on each loop, in order for the system to be capable of performing its required safety function, including single failure considerations.

Additional information about the design and operation of the NSWS, along with a list of the components served, is presented in the UFSAR, Section 9.2.1 (Ref. 1). The principal safety related function of the NSWS is the removal of decay heat from the reactor via the CCW System.

Catawba Units 1 and 2 B 3.7.8-1 Revision No. 5

NSWS B 3.7.8 BASES APPLICABLE The design basis of the NSWS is for one NSWS train, in conjunction SAFETY ANALYSES with the CCW System and a containment spray system, to remove core decay heat following a design basis LOCA as discussed in the UFSAR, Section 6.2 (Ref. 2). This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a gradual reduction in the temperature of this fluid as it is supplied to the Reactor Coolant System by the ECCS pumps.

The NSWS is designed to perform its function with a single failure of any active component, assuming the loss of offsite power.

The NSWS, in conjunction with the CCW System, also cools the unit from residual heat removal (RHR), as discussed in the UFSAR, Section 5.4 (Ref. 3), from RHR entry conditions to MODE 5 during normal and post accident operations. The time required for this evolution is a function of the number of CCW and RHR System trains that are operating. Thirty six hours after a trip from RTP, one NSWS train is sufficient to remove decay heat during subsequent operations in MODES 5 and 6. This assumes a maximum NSWS temperature, a simultaneous design basis event on the other unit, and the loss of offsite power.

The NSWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 4).

LCO Two NSWS trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power.

While the NSWS is operating in the normal dual supply and discharge header alignment, an NSWS train is considered OPERABLE during MODES 1, 2, 3, and 4 when:

a. 1. Both NSWS pumps on the NSWS loop are OPERABLE; or
2. One unit's NSWS pump is OPERABLE and one unit's flowpath to the non essential header, AFW pumps, and Containment Spray heat exchangers are isolated (or equivalent flow restrictions); and
b. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

Catawba Units 1 and 2 B 3.7.8-2 Revision No. 5

NSWS B 3.7.8 BASES LCO (continued)

The NSWS system is shared between the two units. The shared portions of the system must be OPERABLE for each unit when that unit is in the MODE of Applicability. Additionally, both normal and emergency power for shared components must also be OPERABLE. If a shared NSWS component becomes inoperable, or normal or emergency power to shared components becomes inoperable, then the Required Actions of this LCO must be entered independently for each unit that is in the MODE of applicability of the LCO, except as noted in a.2 above for operation in the normal dual supply header alignment. In this case, sufficient flow is available, however, this configuration results in inoperabilities within other required systems on one unit and the associated Required Actions must be entered. Use of a NSWS pump and associated diesel generator on a shutdown unit to support continued operation (> 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) of a unit with an inoperable NSWS pump is prohibited. A shutdown unit supplying its associated emergency power source (1EMXG/2EMXH) cannot be credited for OPERABILITY of components supporting the operating unit.

APPLICABILITY In MODES 1, 2, 3, and 4, the NSWS is a normally operating system that is required to support the OPERABILITY of the equipment serviced by the NSWS and required to be OPERABLE in these MODES.

In MODES 5 and 6, the requirements of the NSWS are determined by the systems it supports.

ACTIONS A.1 Condition A is modified by a Note indicating that this Condition is not applicable while in Condition C of this LCO unless entry is directed by Note 2 of Condition C.

If one NSWS train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE NSWS train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE NSWS train could result in loss of NSWS function. Due to the shared nature of the NSWS, both units are required to enter a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action when a NSWS Train becomes inoperable on either unit. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC SourcesOperating," should be entered if an inoperable Catawba Units 1 and 2 B 3.7.8-3 Revision No. 5

NSWS B 3.7.8 BASES ACTIONS (continued)

NSWS train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS LoopsMODE 4," should be entered if an inoperable NSWS train results in an inoperable decay heat removal train (RHR). An example of when these Notes should be applied is with both units' loop 'A' NSWS pumps inoperable, both units' 'A' emergency diesel generators and both units' 'A' RHR systems should be declared inoperable and appropriate Actions entered. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

B.1 While the NSWS is operating in the single supply header alignment, one of the supply headers is removed from service in support of planned maintenance or modification activities associated with the supply header that is taken out of service. In this configuration, each NSWS train is considered OPERABLE with the required NSWS flow to safety related equipment being fed through the remaining OPERABLE NSWS supply header. While the NSWS is operating in the single supply header alignment, an NSWS train is considered OPERABLE during MODES 1, 2, 3, and 4 when:

a. The associated train related NSWS pumpsBoth NSWS pumps on the NSWS loop are OPERABLE; and
b. The associated piping (except for the supply header that is taken out of service), valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

If one NSWS supply header is inoperable due to the NSWS being aligned for single supply header operation, the NSWS supply header must be restored to OPERABLE status within 30 days. Dual supply header operation is the normal alignment of the NSWS. The Completion Time of 30 days is supported by probabilistic risk analysis. While in Condition B, the single supply header is adequate to perform the heat removal function for all required safety related equipment for both safety trains.

Due to the shared nature of the NSWS, both units are required to enter this Condition when the NSWS is aligned for single supply header operation. In order to prevent the potential for NSWS pump runout, the single NSWS pump flow balance alignment is prohibited while the NSWS is aligned for single supply header operation.

Catawba Units 1 and 2 B 3.7.8-4 Revision No. 5

NSWS B 3.7.8 BASES ACTIONS (continued)

Condition B is modified by three Notes. Note 1 states that entry into this Condition shall only be allowed for pre-planned activities as described in the Bases of this Specification. Condition B is only allowed to be entered in support of planned maintenance or modification activities associated with the supply header that is taken out of service. An example of a situation for which entry into this Condition is allowed is refurbishment or inspection of a supply header. Entry into this Condition is not allowed in response to unplanned events or for other events involving the NSWS.

Examples of situations for which entry into this Condition is prohibited are emergent repair of discovered piping leaks and other component failures.

For unplanned events or other events involving the NSWS, Condition A must be entered. Note 2 requires immediate entry into Condition A of this LCO if one or more NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE. With one remaining OPERABLE NSWS train, the NSWS can still perform its safety related function. However, with one inoperable NSWS train, the NSWS cannot be assured of performing its safety related function in the event of a single failure of another NSWS component. The most limiting single failure is the failure of an NSWS pit to automatically transfer from Lake Wylie to the SNSWP during a seismic event. While the loss of any NSWS component subject to the requirements of this LCO can result in the entry into Condition A, the most common example is the inoperability of an NSWS pump. This occurs during periodic testing of the emergency diesel generators. Inoperability of an emergency diesel generator renders its associated NSWS pump inoperable. Note 3 requires immediate entry into LCO 3.0.3 if one or more NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE. In this case, the NSWS cannot perform its safety related function.

C.1 While the NSWS is operating in the single Auxiliary Building discharge header alignment, one of the Unit 2 Auxiliary Building discharge headers is removed from service in support of planned maintenance or modification activities associated with the Auxiliary Building discharge header that is taken out of service. In this configuration, the corresponding (train related) Unit 1 NSWS train is inoperable and the required NSWS flow to safety related equipment is discharged through the remaining OPERABLE NSWS Auxiliary Building discharge header.

When in the single Auxiliary Building discharge header alignment with the NSWS Train A discharge header inoperable, the NSWS piping between Catawba Units 1 and 2 B 3.7.8-5 Revision No. 5

NSWS B 3.7.8 BASES ACTIONS (continued) valves 1RNP19 and 1RN63A is isolated. Likewise, when in the single Auxiliary Building discharge header alignment with the NSWS Train B discharge header inoperable, the NSWS piping between valves 1RNP20 and 1RN58B is isolated.

Operation of the NSWS in the single supply header alignment and the single Auxiliary Building discharge header alignment while in either the single supply header alignment or the single Pond return header alignment at the same time is prohibited.

If one NSWS train is inoperable due to the NSWS being aligned for single Auxiliary Building discharge header operation, the NSWS train must be restored to OPERABLE status within 14 days. Dual Auxiliary Building discharge header operation is the normal alignment of the NSWS. The Completion Time of 14 days is supported by probabilistic risk analysis. While in Condition C, the single Auxiliary Building discharge header is adequate to perform the heat removal function for all required safety related equipment for its respective safety train. Due to the design of the NSWS, only the operating unit is required to enter this Condition when the NSWS is aligned for single Auxiliary Building discharge header operation. Pre-planned activities requiring entry into this Condition are only performed with Unit 2 in an outage (MODE 5, 6, or defueled).

Condition C is modified by three Notes. Note 1 states that entry into this Condition shall only be allowed for Unit 1 and for pre-planned activities as described in the Bases of this Specification. Condition C is only allowed to be entered in support of planned maintenance or modification activities associated with the Auxiliary Building discharge header that is taken out of service. An example of a situation for which entry into this Condition is allowed is refurbishment or inspection of an Auxiliary Building discharge header. Entry into this Condition is not allowed in response to unplanned events or for other events involving the NSWS. Examples of situations for which entry into this Condition is prohibited are emergent repair of discovered piping leaks and other component failures. For unplanned events or other events involving the NSWS, Condition A must be entered.

In addition, Note 1 states that entry into this Condition shall not be allowed while Unit 2 is in MODE 1, 2, 3, or 4. Entry into this Condition is only allowed while the LCO is not applicable to Unit 2. Note 2 requires immediate entry into Condition A of this LCO if one or more Unit 1 required NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE. With one remaining OPERABLE NSWS train, the NSWS can still perform its safety related function. However, with one inoperable NSWS train, the NSWS cannot Catawba Units 1 and 2 B 3.7.8-6 Revision No. 5

NSWS B 3.7.8 BASES ACTIONS (continued) be assured of performing its safety related function in the event of a single failure of another NSWS component. While the loss of any NSWS component subject to the requirements of this LCO can result in the entry into Condition A, the most common example is the inoperability of an NSWS pump. This occurs during periodic testing of the emergency diesel generators. Inoperability of an emergency diesel generator renders its associated NSWS pump inoperable. Note 3 requires immediate entry into LCO 3.0.3 if one or more Unit 1 required NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE. In this case, the NSWS cannot perform its safety related function.

DE.1 and DE.2 If the NSWS train cannot be restored to OPERABLE status within the associated Completion Time, or if the NSWS single supply header, single Aux Building discharge header, or single Pond return header cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating Insert 3 experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the NSWS components or systems may render those components inoperable, but does not affect the OPERABILITY of the NSWS.

Verifying the correct alignment for manual, power operated, and automatic valves in the NSWS flow path provides assurance that the proper flow paths exist for NSWS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Catawba Units 1 and 2 B 3.7.8-7 Revision No. 5

NSWS B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance Frequency Control Program.

SR 3.7.8.2 This SR verifies proper automatic operation of the NSWS valves on an actual or simulated actuation signal. The signals that cause the actuation are from Safety Injection and Phase 'B' isolation. The NSWS is a normally operating system that cannot be fully actuated as part of normal testing. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that states that the SR is not required to be met for valves that are maintained in position to support NSWS single supply header operation, orsingle Auxiliary Building discharge header operation, or single Pond return header operation. When the NSWS is placed in this alignment, certain automatic valves in the system are maintained in position and will not automatically reposition in response to an actuation signal while the NSWS is in this alignment.

SR 3.7.8.3 This SR verifies proper automatic operation of the NSWS pumps on an actual or simulated actuation signal. The signals that cause the actuation are from Safety Injection and Loss of Offsite Power. The NSWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 9.2.

2. UFSAR, Section 6.2.
3. UFSAR, Section 5.4.
4. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

Catawba Units 1 and 2 B 3.7.8-8 Revision No. 5

INSERT 1 FOR TS 3.7.8 BASES Operation of the NSWS in the single supply header alignment while in either the single Pond return header alignment or the single Auxiliary Building discharge header alignment at the same time is prohibited.

INSERT 2 FOR TS 3.7.8 BASES D.1 While the NSWS is operating in the single Pond return header alignment, one of the shared discharge headers from the Aux Bldg to the SNSWP is removed from service in support of planned maintenance or modification activities associated with the Pond return header that is taken out of service.

In this configuration, each NSWS train is considered OPERABLE with the required NSWS flow path from safety related equipment through the remaining OPERABLE NSWS Pond return header. The technical justification for the NSWS single Pond return header alignment demonstrates that the NSWS can meet all design flow requirements in response to all design basis accidents. The utilization of the single pond return header has been analyzed in the PRA risk based assessment with no significant increase in risk. While the NSWS is operating in the single Pond return header alignment, an NSWS train is considered OPERABLE during MODES 1, 2, 3, and 4 when:

a. Both NSWS pumps on the NSWS loop are OPERABLE; and
b. The associated piping (except for the Pond return header that is taken out of service), valves, and instrumentation and controls required to perform the safety related function are OPERABLE.

When in the single Pond return header alignment with the NSWS Train A Pond return header inoperable, the NSWS piping downstream of valves 1RN63A and 1(2)RN846A is isolated. Valve 1RNP20 is locked open, 1RN58B is open with power removed, and 1(2)RN848B are open with power removed to protect against closing that would isolate the discharge flow from both trains.

Similarly, when in the single Pond return header alignment with the NSWS Train B Pond return header inoperable, the NSWS piping downstream of valves 1RN58B and 1(2)RN848B is isolated. In this case valve 1RNP19 is locked open, 1RN63A is open with power removed, and 1(2)RN846A are open with power removed to protect against closing that would isolate the discharge flow from both trains.

When in the single Pond return header alignment the NSWS System is aligned to the SNSWP, with power removed from pit isolation valves 1RN3A and 1RN4B, to preclude a single active failure that could result in the complete loss of one NSWS pit (two NSWS pumps). Aux Bldg discharge crossover piping valves 1RN53B and 1RN54A are open with power removed to allow both Aux Bldg trains to discharge through one header. Similarly, Unit 1 and Unit 2 diesel generator (DG) crossover valves 1(2)RNP08 and 1(2)RNP09 are locked open to allow both trains of DGs to discharge through one header on each unit. Finally, both Unit 1 and Unit 2 NSWS non-essential headers are isolated.

Operation of the NSWS in the single Pond return header alignment while in either the single supply header alignment or the single Auxiliary Building discharge header alignment at the same time is prohibited.

If one NSWS Pond return header is inoperable due to the NSWS being aligned for single Pond return header operation, the NSWS Pond return header must be restored to OPERABLE status within 30 days. The Completion Time of 30 days is supported by probabilistic risk analysis. While in Condition D, the single Pond return header alignment is adequate to perform the heat removal function for all required safety related equipment for both safety trains of both units. Due to the shared nature of the NSWS, both units are required to enter this Condition when the NSWS is aligned for single Pond return header operation. In order to ensure adequate flow to essential components, the single NSWS pump flow balance alignment is prohibited while the NSWS is aligned for single Pond return header operation.

Condition D is modified by four Notes. Note 1 states that entry into this Condition shall only be allowed for pre-planned activities as described in the Bases of this Specification. Condition D is only allowed to be entered in support of planned maintenance or modification activities associated with the Pond return header that is taken out of service. An example of a situation for which entry into this Condition is allowed is refurbishment or inspection of a Pond return header. Entry into this Condition is not allowed in response to unplanned events or for other events involving the NSWS. Examples of situations for which entry into this Condition is prohibited are emergent repair of discovered piping leaks and other component failures. For unplanned events or other events involving the NSWS, Condition A must be entered.

Note 2 requires immediate entry into Condition A of this LCO if one or more NSWS components become inoperable while in this Condition and one NSWS train remains OPERABLE. With one remaining OPERABLE NSWS train, the NSWS can still perform its safety related function. However, with one inoperable NSWS train, the NSWS cannot be assured of performing its safety related function in the event of a single failure of another NSWS component. While the loss of any NSWS component subject to the requirements of this LCO can result in the entry into Condition A, the most common example is the inoperability of an NSWS pump. This occurs during periodic testing of the emergency diesel generators. Inoperability of an emergency diesel generator renders its associated NSWS pump inoperable.

Note 3 requires immediate entry into LCO 3.0.3 if one or more NSWS components become inoperable while in this Condition and no NSWS train remains OPERABLE. In this case, the NSWS cannot perform its safety related function. Note 4 states that entry into this Condition shall only be allowed for 60 days per 12-month period. This limitation of entry into this Condition is in agreement with inputs to the PRA risk based assessment for the NSWS alignment supporting operation in this Condition.

INSERT 3 FOR TS 3.7.8 BASES The following table identifies those actions committed to by Duke Energy in Letter CNS-17-014 dated September 14, 2017 for the approval of License Amendments 300 and 296 for Units 1 and 2, respectively.

  1. REGULATORY COMMITMENTS 1 The support system for the NSWS Discharge piping associated with Train 1A in the Auxiliary Building will be maintained such that stress levels are below the threshold for considering a pipe leak under the Pipe Rupture program. This ensures that for all sections where pipe ruptures are postulated that leaks can be isolated with the NSWS continuing to operate with adequate equipment to support shutdown of both units.

Catawba NSWS piping stress calculations RNG, RNH, and RNE have been revised to indicate the requirement to maintain this low stress level.

2 To reduce stress at the 1A Component Cooling (KC) Heat Exchanger piping return nozzle location, a 1/4" thick reinforcing pad will be added to the existing reinforcing pad per a plant modification. The 1/4" reinforcing pad must be installed prior to entering NSWS Single Pond Return Header Operation.

3 NSWS Flow Balance testing will take place prior to entering Single Pond Return Header Operation. This will ensure the NSWS is capable of providing adequate cooling water flow to support LOCA loads on one unit, concurrent with the shutdown loads of the other unit - while assuming the most limiting single failure, which is loss of one DG and its associated NSWS Pump.

The following table identifies additional considerations as addressed in the submittals by Duke Energy in Letter CNS-17-014 dated September 14, 2017 and in Letter RA-18-0097 dated August 17, 2018 for the approval of License Amendments 300 and 296 for Units 1 and 2, respectively.

  1. ADDITIONAL CONSIDERATIONS 1 During the Completion Time of Condition D, planned or discretionary maintenance that renders one or more NSWS pumps and / or the associated DGs inoperable and unavailable on either train of NSWS is prohibited while in the Single Pond Return Header alignment with one exception. For the DGs, a monthly periodic test is performed to confirm operability. Prior to starting the DG, a "bar and roll" of the DG is performed. This renders the DG inoperable but available, and is allowed while the NSWS is aligned for Single Pond Return Header Operation.

2 The SSCs whose unavailability should be avoided during the Completion Time for Condition D include the following for the opposite train (i.e., opposite the train in the Completion Time, as applicable):

  • Diesel Generators (DGs)
  • Component Cooling System
  • Instrument Air System
  • Standby Shutdown Facility (SSF)
  • 4160V AC Essential Power
  • Engineered Safeguards Features Actuation System

U.S. Nuclear Regulatory Commission RA-18-0198 Attachment 3 CNS, Unit 1 Renewed Facility Operating License (Mark-up)

FOR INFORMATION ONLY (1) Duke Energy Carolinas, LLC, pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use, and operate the facility at the designated location in York County, South Carolina, in accordance with the procedures and limitations set forth in this renewed operating license; (2) North Carolina Electric Membership Corporation to possess the facility at the designated location in York County, South Carolina, in accordance with the procedures and limitations set forth in this renewed operating license; (3) Duke Energy Carolinas, LLC, pursuant to the Act and 10 CFR Part 70 to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (4) Duke Energy Carolinas, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Duke Energy Carolinas, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6) Duke Energy Carolinas, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility authorized herein, and; (7) Duke Energy Carolinas, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2, and Oconee Nuclear Station, Units 1, 2 and 3.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Duke Energy Carolinas, LLC is authorized to operate the facility at reactor core full steady state power level of 3469 megawatts thermal (100%) in accordance with the conditions specified herein.

Renewed license No. NPF-35 Amendment No. 281

(2) Technical Specifications The Technical ecifications contained in Appendix A, as revised through Amendment No. 299, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.

(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4),

following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

(4) Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.

(5) Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

~

Renewed License No. NP'f/z.~~

Amendment 299

FOR INFORMATION ONLY

-4A-(a) Risk-Informed Changes that May be Made Without Prior NRC Approval, A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at CNS. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation; and
2) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1X10*7/year (yr) for CDF and less than 1X 1o..a/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval is not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the Renewed License No. NPF-35 Amendment 287

FOR INFORMATION ONLY

-4C-issuance of the Safety Evaluation unless that falls within a scheduled outage window, then the completion of implementation items will occur 60 days after startup from the scheduled outage. Implementation Item 13 is associated with modifications and will be completed 180 days after modifications are complete.

Renewed License No. NPF-35 Amendment 287

(6) Mitigation Strategies Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fighting assets '
3. Designated staging areas for equipment and materials
4. Command and control
5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
1. Protection and use of personnel assets
2. Communications
3. Minimizing fire spread
4. . Procedures for implementing integrated ftre response strategy
5. Identification of readily-available pre-staged equipment
6. Training on* integrated fire response strategy
7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders (7) Additional Conditions The Additional Condi* ns contained in Appendix B, as revised through Amendment No.2-53 are hereby in*corporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Additional Conditions.
  • D. The facility requires exemptions from certain requirements of Appendix J to 10 CFR Part 50, as delineated below and pursuant to evaluations contained in the referenced SER and SSERs. These include, (a) partial exemption from the requirement of paragraph III.D.2(b)(ii) of Appendix J, the testing of containment airlocks at times when the containment integrity is not required (Section 6.2.6 of the SER, and SSERs
  1. 3 and #4), (b) exemption from the requirement of. paragraph 111.A.(d) of Appendix J, insofar as it requires the venting and draining of lines for type A tests (Section 6.2.6

. of SSER #3), and (c) partial exemption from the requirements of paragraph 111.B of Appendix J, as it relates to bellows testing (Section 6.2.6 of the SER and SSER #3).

These exemptions are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and are consistent with certain special circumstances as discussed in the referenced SER and SSERs. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

~

Renewed License No, i f:~-35 Amendment No. ~

FOR INFORMATION ONLY E. Physical Protection Duke Energy Carolinas, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains safeguards information protected under 10 CFR 73.21, is entitled: "Duke Energy Physical Security Plan," Revision 8 submitted by letter dated May 17, 2007.

Duke Energy Carolinas, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Duke Energy Carolinas, LLC CSP was approved by License Amendment No. 266, as supplemented by a change approved by License Amendment No. 276.

F. Reporting to the Commission Deleted by Amendment No. 230 G. The licensees shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

3. This renewed license is effective as of the date of issuance and shall expire at midnight on December 5, 2043.

FOR THE NUCLEAR REGULA TORY COMMISSION Original Signed By: J.E. Dyer J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A - Technical Specifications
2. Appendix B - Additional Conditions
3. Appendix C - Antitrust Conditions Date of Issuance: December 5, 2003 Renewed License No. NPF-35 Amendment No. 276

FOR INFORMATION ONLY Amendment Implementation Number Additional Condition Date 242

  • The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time of July 15, 2008 at

. Technical Specification 3.7.5 Action "B" 1041 for the 1B AFW pump which was entered at 1041 on ~uly 12, 2008 may be extended by an additional 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.

Upon completion of the :repair and restoration of the 1B NSWS pump, this License Condition is no longer applicable and will expire at 1041 on July 21, 2008.

  • The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time of Technical Specification 3.6.6 Action "A" for the 1B CSS which was entered at 1041 on July 12, 2008 may be extended by an additional 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />. Upon completion of the repair and restoration of the 1B NSWS pump, this License Condition is no longer applicable and will expire at 1041 on July 21, 2008.

Renewed license No. NPF-35 Amendment No. 242 Amendment Implementation Number Additional Condition Date 250 Upon implementation of the Amendment Within 60 days of adopting TSTF-448, Rev. 3, the determination date of amendment of CRE unfiltered air inleakage as required by SR 3.7.10.4, in accordance with Technical Specification 5.5.16.c(i), the assessment of CRE habitability as required by Technical Specification 5.5.16.c.(ii), and the measurement of CRE pressure as required by Technical Specification 5.5.16.d, shall be met.

Following implementation:

(a) The first performance of SR 3. 7.10.4 in accordance with Technical Specification 5.5.16.c(i) shall be within the specified Frequency of 6 years, plus the 18 month allowance of SR 3.0.2, as measured from November 12, 2002, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter (GL) 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Technical Specification 5.5.16.c(ii), shall be within 3 years, plus the 9 month allowance of SR 3.0.2 as measured from November 12, 2002, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to GL 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Technical Specification 5.5.16.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from September 1, 2007, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

!Insert 1 here I Renewed License No. NPF-35 Amendment No. ~

INSERT 1 for CNS Unit 1 Renewed Facility Operating License Amendment Additional Condition Implementation Date Number Prior to entry into TS 3.7.8, To reduce NSWS pipe stress at the 1A Nuclear Service Water Component Cooling (KC) Heat Exchanger piping System (NSWS) Condition D return nozzle location, a 1/4" thick reinforcing pad - One NSWS Pond return 300 will be added to the existing reinforcing pad. header inoperable due to NSWS being aligned for single Pond return header operation.

FOR INFORMATION ONLY APPENDIX C ANTITRUST CONDITIONS Pursuant to an Order by the Atomic Safety and Licensing Board, dated April 23, 1975, the Nuclear Regulatory Commission incorporates in Operating License NPA-35 the following antitrust conditions:

a. The licensee makes the commitments contained herein, recognizing that bulk power supply arrangements between neighboring entities normally tend to serve the public interest. In addition, where there are net benefits to all participants such arrangements also serve the best interests of each of the participants. Among the benefits of such transactions are increased electric system reliability, a reduction in the cost of electric power, and minimization of the environmental effects of the production and sale of electricity.

Any particular bulk power supply transaction may afford greater benefits to one participant than to another. The benefits realized by a small system may be proportionately greater than those realized by a larger system. The relative benefits to be derived by the parties from a proposed transaction, however, should not be controlling upon a decision with respect to the desirability of participating in the transaction. Accordingly, the licensee will enter into proposed bulk power transactions of the types hereinafter described which, on balance, provide net benefits to the licensee. There are net benefits in a transaction if the licensee recovers the cost of the transaction, (as defined in subparagraph (1 )(d) hereof) and there is no demonstrable net detriment to the licensee arising from the transaction.

(1) As used herein:

(a) *sulk Power" means electric power and any attendant energy, supplied or made available at transmission or sub-transmission voltage by one electric system to another.

(b) *Neighboring Entity" means a private or public corporation, a governmental agency or authority, a municipality, a cooperative, or a lawful association of any of the foregoing owning or operating, or proposing to own or operate, facilities for the generation and transmission of electricity which meets each of the following criteria: (1) its existing or proposed facilities are economically and technically feasible of interconnection with those of the licensee and (2) with the exception of municipalities, cooperatives, governmental agencies or authorities, and associations, it is, or upon commencement of operations will be, a public utility and subject to regulation with respect to rates and service under the laws of North Carolina or South Carolina or under the Federal Power Act; provided, however, that as to associations, each member of such association is either a public utility as discussed in this clause (2) or a C-1

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