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| issue date = 05/02/2011
| issue date = 05/02/2011
| title = Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages
| title = Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages
| author name = Repko R T
| author name = Repko R
| author affiliation = Duke Energy Carolinas, LLC
| author affiliation = Duke Energy Carolinas, LLC
| addressee name =  
| addressee name =  
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:p Duke REGIS T. REPKO Duke Vice President Energy, McGuire Nuclear Station Duke Energy MGO1VP /12700 Hagers Ferry Rd.Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis, repko@duke-energy.
{{#Wiki_filter:Duke p                 Duke                                                         Vice REGISPresident T.REPKO Energy,                                                                         McGuire Nuclear Station Duke Energy MGO1VP /12700 Hagers Ferry Rd.
corn May 2, 2011 10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis,repko@duke-energy.corn May 2, 2011                                                                         10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
Document Control Desk  


==Subject:==
==Subject:==
Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages  
Duke Energy Carolinas, LLC (Duke Energy)
McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages


==References:==
==References:==
License Amendment Request for Emergency Core Cooling System (ECCS)
Water Management Initiative (TAC Nos ME4051 and ME4052), and Electronic Mail from NRC to Duke Energy, dated April 15, 2011 On May 28, 2010, Duke Energy submitted a license amendment request (LAR) for the Renewed Facility Operating Licenses (FOL) and Technical Specifications (TS) for McGuire Nuclear Station Units 1 and 2 to allow the manual operation of the Containment Spray System (CSS) in lieu of automatic actuation, and revise the minimum volume and low level setpoint on the Refueling Water Storage Tank (ML101600256).
In response to the NRC's Request for Additional Information (RAI) of January 31, 2011, as amended on February 28, 2011, Duke Energy's response of March 23, 2011 (ML110840443) committed to providing a letter informing the NRC of the completion of the re-qualification of all affected Unit 1 pipe supports by May 2, 2011. Please be advised that the re-qualification of those pipe supports has been completed. The re-qualification effort did not identify any additional supports requiring modification other than that stated in Duke Energy's letter of March 23, 2011.
On April 15, 2011, the NRC electronically transmitted an RAI. Duke Energy's response to this RAI is contained in Attachment 1 to this letter.
In addition, replacement Technical Specification pages 3.5.4-2, 3.6.6-1 and 3.6.6-2 are enclosed as Attachment 2 to this letter. These pages were changed by Amendments 261/241, approved by the NRC Safety Evaluation of March 29, 2011 (ML110680357) for the relocation of specific surveillance frequencies to a licensee controlled program (TSTF-425). The replacement pages do not contain any changes in addition to those requested by Duke Energy's May 28, 2010 submittal.
www. duke-energy cornOU


License Amendment Request for Emergency Core Cooling System (ECCS)Water Management Initiative (TAC Nos ME4051 and ME4052), and Electronic Mail from NRC to Duke Energy, dated April 15, 2011 On May 28, 2010, Duke Energy submitted a license amendment request (LAR) for the Renewed Facility Operating Licenses (FOL) and Technical Specifications (TS) for McGuire Nuclear Station Units 1 and 2 to allow the manual operation of the Containment Spray System (CSS) in lieu of automatic actuation, and revise the minimum volume and low level setpoint on the Refueling Water Storage Tank (ML101600256).
U.S. Nuclear Regulatory Commission May 2,2011 Page 2 There are no Regulatory Commitments contained in this letter.
In response to the NRC's Request for Additional Information (RAI) of January 31, 2011, as amended on February 28, 2011, Duke Energy's response of March 23, 2011 (ML1 10840443)committed to providing a letter informing the NRC of the completion of the re-qualification of all affected Unit 1 pipe supports by May 2, 2011. Please be advised that the re-qualification of those pipe supports has been completed.
The information contained in this letterdid not result in any impact to the original No Significant Hazards Consideration or the Environmental Consideration contained in the May 28, 2010 submittal.
The re-qualification effort did not identify any additional supports requiring modification other than that stated in Duke Energy's letter of March 23, 2011.On April 15, 2011, the NRC electronically transmitted an RAI. Duke Energy's response to this RAI is contained in Attachment 1 to this letter.In addition, replacement Technical Specification pages 3.5.4-2, 3.6.6-1 and 3.6.6-2 are enclosed as Attachment 2 to this letter. These pages were changed by Amendments 261/241, approved by the NRC Safety Evaluation of March 29, 2011 (ML1 10680357) for the relocation of specific surveillance frequencies to a licensee controlled program (TSTF-425).
Pursuant to 10 CFR 50.91, a copy of this letter is being sent to the designated official of the State of North Carolina.
The replacement pages do not contain any changes in addition to those requested by Duke Energy's May 28, 2010 submittal.
If you have any questions or require additional information, please contact K. L. Ashe at (980) 875-4535.
www. duke-energy cornOU U.S. Nuclear Regulatory Commission May 2,2011 Page 2 There are no Regulatory Commitments contained in this letter.The information contained in this letterdid not result in any impact to the original No Significant Hazards Consideration or the Environmental Consideration contained in the May 28, 2010 submittal.
Very truly yours, R. T. Repko Attachments xc (with attachments):
Pursuant to 10 CFR 50.91, a copy of this letter is being sent to the designated official of the State of North Carolina.If you have any questions or require additional information, please contact K. L. Ashe at (980) 875-4535.Very truly yours, R. T. Repko Attachments xc (with attachments):
V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)
V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)NRC Senior Project Manager (McGuire)U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 W. L. Cox IIl, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645 U.S. Nuclear Regulatory Commission May 2, 2011 Page 3 Regis T. Repko affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
NRC Senior Project Manager (McGuire)
Regis T. Repko, Vice President, McGuire Nuclear Station Subscribed and sworn to me: (no\, Date-4 20HI dýý_Ovu 6/'>I Notary Public My commission expires: 'Date?012-SEAL K Attachment I Response to NRC Request for Additional Information U.S. Nuclear Regulatory Commission Attachment 1 May 2, 2011 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEART REACTOR REGULATION REGARDING LICENSE AMENDMENT REQUEST RELATED TO EMERGENCY CORE COOLING SYSTEM (ECCS) WATER MANAGEMENT INITIATIVE McGUIRE NUCLEAR STATION, UNITS 1 AND 2 In Attachment 2 to the LAR, Technical Specification (TS) Table 3.3.2-1, insert 1, implies that the requirements of Function 2a are not applicable following implementation of the modifications associated with the LAR.The NRC staff requests the following information:
U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 W. L. Cox IIl, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645
: 1. Justify deletion of the proposed Function 2a from TS Table 3.3.2-1 2. Describe all the surveillance tests performed in Function 2a that are proposed to be deleted 3. Describe the TS related controls and instrumentation functions associated with the manual operation of the containment spray system that are required to be surveillance tested and describe according to which TS these will be tested.Duke Response: The requirements of Function 2 of Technical Specification (TS) Table 3.3.2-1, including Function 2a, are no longer applicable following approval of the LAR and implementation of the associated modifications.
 
Table 3.3.2-1 lists Engineered Safety Features Actuation System (ESFAS)functions.
U.S. Nuclear Regulatory Commission May 2, 2011 Page 3 Regis T. Repko affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
At McGuire, ESFAS functions are performed by the Westinghouse Solid State Protection System (SSPS) using bistable and switch inputs from the W7300 process control system, field instruments and Main Control Board (MCB) manual switches.Following implementation of the associated modifications, circuitry controlling the containment spray pumps and related motor valves will no longer go through the SSPS. Actuation and interlock circuitry will remain safety-related, but will be implemented instead in auxiliary relay cabinets.Therefore, this circuitry will no longer be considered ESFAS at McGuire, and all Function 2 functions, including 2a, are being deleted from TS Table 3.3.2-1. This is identical to the TS change approved previously for Catawba Nuclear Station on June 28, 2010 as amendments 257/252 (ML092530088).
Regis T. Repko, Vice President, McGuire Nuclear Station Subscribed and sworn to me:          (no\,       -4 20HI Date dýý_Ovu 6/'>                                  INotary Public My commission expires:                        ?012-
TS Table 3.3.2-1, Function 2a presently requires the completion of Surveillance Requirement (SR) 3.3.2.7, Trip Actuating Device Operational Test (TADOT) every 18 months. The TADOT for a manual function consists of operating the actuating device and verifying the operability of the alarm, interlock, and trip functions.
                                      'Date SEAL
The current implementing procedure is PT/1 (2)/A/4200/009A
 
& B, which is the integrated testing of the entire ESFAS for train A and B, respectively.
K Attachment I for Additional Information Response to NRC Request
The procedure currently satisfies TS Table 3.3.2-1 surveillance requirement for Function 2a by manual operation of the "Initiate Phase B & Cont Spray Train A" pushbutton.
 
Following LAR implementation, this procedure step will be revised to test only the Phase B Page 1 of 2 U.S. Nuclear Regulatory Commission Attachment 1 May 2, 2011 Containment Isolation function, which uses the same existing (but relabeled) switch, and is retained in Table 3.3.2-1 as ESFAS Function 3b. Surveillance will continue as part of ESF testing under procedure PT/1 (2)/A/4200/009A
U.S. Nuclear Regulatory Commission                                                   Attachment 1 May 2, 2011 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEART REACTOR REGULATION REGARDING LICENSE AMENDMENT REQUEST RELATED TO EMERGENCY CORE COOLING SYSTEM (ECCS) WATER MANAGEMENT INITIATIVE McGUIRE NUCLEAR STATION, UNITS 1 AND 2 In Attachment 2 to the LAR, Technical Specification (TS) Table 3.3.2-1, insert 1, implies that the requirements of Function 2a are not applicable following implementation of the modifications associated with the LAR.
& B.The current Containment Spray system component surveillance requirements are listed in the procedure by reference to SR 3.6.6.3 and SR 3.6.6.4 "Containment Spray System". Following implementation of the modifications associated with ECCS Water Management on the respective Unit, the requirements of SR 3.6.6.3 and SR 3.6.6.4 shall no longer be applicable.
The NRC staff requests the following information:
However, the manual spray pump actuation will be done using the pump start/stop pushbuttons on the MCB.Manual containment spray pump operation will continue to be tested periodically as required by SR 3.6.6.2 for verification of the spray pump developed head in accordance with the Technical Specification 5.5.8 Inservice Testing Program (quarterly minflow and 18 month full flow testing, PT/1 &2/A/4208/001A
: 1. Justify deletion of the proposed Function 2a from TS Table 3.3.2-1
& B, PT/1 &2/A/4208/021A
: 2. Describe all the surveillance tests performed in Function 2a that are proposed to be deleted
& 021B). In addition, the manual start/stop push-buttons must be used in order to test the Containment Pressure Control System (CPCS), which is verified at 18 month intervals by SR 3.6.6.5.The procedure implementing SR 3.6.6.5 (CPCS functions for Containment Spray Pump) is PT/1(2)/A/4150/020, "NS Train CPCS Interlock Verification".
: 3. Describe the TS related controls and instrumentation functions associated with the manual operation of the containment spray system that are required to be surveillance tested and describe according to which TS these will be tested.
This procedure exercises the pump "START" pushbutton and the acceptance criteria are given in the procedure step. The acceptance criteria are that the Containment Spray Pump start is inhibited when the simulated containment pressure signal is below the setpoint, and is permitted when it is above the setpoint.
Duke Response:
There are no other instrumentation and control functions associated with pump"START" pushbutton.
The requirements of Function 2 of Technical Specification (TS) Table 3.3.2-1, including Function 2a, are no longer applicable following approval of the LAR and implementation of the associated modifications. Table 3.3.2-1 lists Engineered Safety Features Actuation System (ESFAS) functions. At McGuire, ESFAS functions are performed by the Westinghouse Solid State Protection System (SSPS) using bistable and switch inputs from the W7300 process control system, field instruments and Main Control Board (MCB) manual switches.
In conclusion, the surveillance test of the containment spray manual actuation switch in ESFAS Table 3.3.2-1, Function 2a is no longer applicable.
Following implementation of the associated modifications, circuitry controlling the containment spray pumps and related motor valves will no longer go through the SSPS. Actuation and interlock circuitry will remain safety-related, but will be implemented instead in auxiliary relay cabinets.
The new functionality is implemented using the pump start/stop pushbutton on the MCB. Equivalent surveillance of this switch is already included elsewhere in the Technical Specifications.
Therefore, this circuitry will no longer be considered ESFAS at McGuire, and all Function 2 functions, including 2a, are being deleted from TS Table 3.3.2-1. This is identical to the TS change approved previously for Catawba Nuclear Station on June 28, 2010 as amendments 257/252 (ML092530088).
No new surveillance is required.Page 2 of 2 Attachment 2 Replacement Technical Specification Pages RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 Verify RWST borated water temperature is > 70&deg;F and In accordance with< 1000F. the Surveillance Frequency Control Program SR 3.5.4.2 Verify RWST borated water volume is > 372,100 gallons. In accordance with the Surveillance Frequency Control Program SR 3.5.4.3 Verify RWST boron concentration is within the limits In accordance with specified in the COLR. the Surveillance Frequency Control Program 3 McGuire Units I and 2 3.5.4-2 Amendment Nos. &#xfd;2, --
TS Table 3.3.2-1, Function 2a presently requires the completion of Surveillance Requirement (SR) 3.3.2.7, Trip Actuating Device Operational Test (TADOT) every 18 months. The TADOT for a manual function consists of operating the actuating device and verifying the operability of the alarm, interlock, and trip functions. The current implementing procedure is PT/1 (2)/A/4200/009A & B, which is the integrated testing of the entire ESFAS for train A and B, respectively. The procedure currently satisfies TS Table 3.3.2-1 surveillance requirement for Function 2a by manual operation of the "Initiate Phase B & Cont Spray Train A" pushbutton.
Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE.APPLICABILITY:
Following LAR implementation, this procedure step will be revised to test only the Phase B Page 1 of 2
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours train inoperable, train to OPERABLE status.B. Required Action and B. 1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power operated, In accordance with and automatic valve in the flow path that is not locked, the Surveillance sealed, or otherwise secured in position is in the correct Frequency Control position.
 
Program LI (continued)
U.S. Nuclear Regulatory Commission                                                Attachment 1 May 2, 2011 Containment Isolation function, which uses the same existing (but relabeled) switch, and is retained in Table 3.3.2-1 as ESFAS Function 3b. Surveillance will continue as part of ESF testing under procedure PT/1 (2)/A/4200/009A & B.
*McGuire Units 1 and 2 3.6.6-1 Amendment Nos Containment Spray System 3.6.6 SURVEILLANCE FREQUENCY SR 3.6.6.2 Verify each containment spray pump's developed head at In accordance with the flow test point is greater than or equal to the required the Inservice developed head. Testing Program SR 3.6.6.3 Verify each automatic containment spray valve in the flow In accordance with path that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the correct position on an actual or Frequency Control simulated actuation signal. Program SR 3.6.6.4"fVerify each containment spray pump starts automatically In accordance with on an actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.6.6.5 Verify that each spray pump is de-energized and In accordance with prevented from starting upon receipt of a terminate signal the Surveillance and is allowed to start upon receipt of a start permissive Frequency Control from the Containment Pressure Control System (CPCS). Program SR 3.6.6.6 Verify that each spray pump discharge valve closes or is In accordance with prevented from opening upon receipt of a terminate the Surveillance signal and is allowed to open upon receipt of a start Frequency Control permissive from the Containment Pressure Control Program System (CPCS).SR 3.6.6.7 Verify each spray nozzle is unobstructed.
The current Containment Spray system component surveillance requirements are listed in the procedure by reference to SR 3.6.6.3 and SR 3.6.6.4 "ContainmentSpray System". Following implementation of the modifications associated with ECCS Water Management on the respective Unit, the requirements of SR 3.6.6.3 and SR 3.6.6.4 shall no longer be applicable.
Following activities which could result in nozzle blockage McGuire Units 1 and 2 3.6.6-2 Amendment Nos-&#xfd;"?}}
However, the manual spray pump actuation will be done using the pump start/stop pushbuttons on the MCB.
Manual containment spray pump operation will continue to be tested periodically as required by SR 3.6.6.2 for verification of the spray pump developed head in accordance with the Technical Specification 5.5.8 Inservice Testing Program (quarterly minflow and 18 month full flow testing, PT/1 &2/A/4208/001A & B, PT/1 &2/A/4208/021A & 021B). In addition, the manual start/stop push-buttons must be used in order to test the Containment Pressure Control System (CPCS),
which is verified at 18 month intervals by SR 3.6.6.5.
The procedure implementing SR 3.6.6.5 (CPCS functions for Containment Spray Pump) is PT/1(2)/A/4150/020, "NS Train CPCS Interlock Verification". This procedure exercises the pump "START" pushbutton and the acceptance criteria are given in the procedure step. The acceptance criteria are that the Containment Spray Pump start is inhibited when the simulated containment pressure signal is below the setpoint, and is permitted when it is above the setpoint. There are no other instrumentation and control functions associated with pump "START" pushbutton.
In conclusion, the surveillance test of the containment spray manual actuation switch in ESFAS Table 3.3.2-1, Function 2a is no longer applicable. The new functionality is implemented using the pump start/stop pushbutton on the MCB. Equivalent surveillance of this switch is already included elsewhere in the Technical Specifications. No new surveillance is required.
Page 2 of 2
 
Attachment 2 Replacement Technical Specification Pages
 
RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR 3.5.4.1    Verify RWST borated water temperature is > 70&deg;F and     In accordance with
              < 1000F.                                                the Surveillance Frequency Control Program SR 3.5.4.2   Verify RWST borated water volume is > 372,100 gallons. In accordance with the Surveillance Frequency Control Program SR 3.5.4.3   Verify RWST boron concentration is within the limits    In accordance with specified in the COLR.                                   the Surveillance Frequency Control Program 3
McGuire Units I and 2                3.5.4-2                        Amendment Nos.&#xfd;2,      --
 
Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6            Two containment spray trains shall be OPERABLE.
APPLICABILITY:        MODES 1, 2, 3, and 4.
ACTIONS CONDITION                      REQUIRED ACTION                  COMPLETION TIME A. One containment spray       A.1    Restore containment spray      72 hours train inoperable,                   train to OPERABLE status.
B. Required Action and        B. 1    Be in MODE 3.                 6 hours associated Completion Time not met.              AND B.2     Be in MODE 5.                 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                       FREQUENCY SR 3.6.6.1   Verify each containment spray manual, power operated,        In accordance with and automatic valve in the flow path that is not locked,     the Surveillance sealed, or otherwise secured in position is in the correct    Frequency Control position.                                                    Program (continued)
* LI McGuire Units 1 and 2                    3.6.6-1                              Amendment Nos
 
Containment Spray System 3.6.6 SURVEILLANCE                                      FREQUENCY SR 3.6.6.2    Verify each containment spray pump's developed head at        In accordance with the flow test point is greater than or equal to the required  the Inservice developed head.                                              Testing Program SR 3.6.6.3   Verify each automatic containment spray valve in the flow    In accordance with path that is not locked, sealed, or otherwise secured in      the Surveillance position, actuates to the correct position on an actual or    Frequency Control simulated actuation signal.                                  Program SR 3.6.6.4"fVerify each containment spray pump starts automatically          In accordance with on an actual or simulated actuation signal.                  the Surveillance Frequency Control Program SR 3.6.6.5   Verify that each spray pump is de-energized and                In accordance with prevented from starting upon receipt of a terminate signal    the Surveillance and is allowed to start upon receipt of a start permissive    Frequency Control from the Containment Pressure Control System (CPCS).           Program SR 3.6.6.6   Verify that each spray pump discharge valve closes or is      In accordance with prevented from opening upon receipt of a terminate            the Surveillance signal and is allowed to open upon receipt of a start          Frequency Control permissive from the Containment Pressure Control               Program System (CPCS).
SR 3.6.6.7   Verify each spray nozzle is unobstructed.                     Following activities which could result in nozzle blockage McGuire Units 1 and 2                     3.6.6-2                             Amendment Nos-&#xfd;"?}}

Latest revision as of 01:11, 13 November 2019

Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages
ML11124A125
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 05/02/2011
From: Repko R
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11124A125 (10)
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Text

Duke p Duke Vice REGISPresident T.REPKO Energy, McGuire Nuclear Station Duke Energy MGO1VP /12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis,repko@duke-energy.corn May 2, 2011 10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Response to Request for Additional Information Related to License Amendment, Confirmation of the Completion of Unit 1 Pipe Support Re-Qualification, and Replacement Technical Specification Pages

References:

License Amendment Request for Emergency Core Cooling System (ECCS)

Water Management Initiative (TAC Nos ME4051 and ME4052), and Electronic Mail from NRC to Duke Energy, dated April 15, 2011 On May 28, 2010, Duke Energy submitted a license amendment request (LAR) for the Renewed Facility Operating Licenses (FOL) and Technical Specifications (TS) for McGuire Nuclear Station Units 1 and 2 to allow the manual operation of the Containment Spray System (CSS) in lieu of automatic actuation, and revise the minimum volume and low level setpoint on the Refueling Water Storage Tank (ML101600256).

In response to the NRC's Request for Additional Information (RAI) of January 31, 2011, as amended on February 28, 2011, Duke Energy's response of March 23, 2011 (ML110840443) committed to providing a letter informing the NRC of the completion of the re-qualification of all affected Unit 1 pipe supports by May 2, 2011. Please be advised that the re-qualification of those pipe supports has been completed. The re-qualification effort did not identify any additional supports requiring modification other than that stated in Duke Energy's letter of March 23, 2011.

On April 15, 2011, the NRC electronically transmitted an RAI. Duke Energy's response to this RAI is contained in Attachment 1 to this letter.

In addition, replacement Technical Specification pages 3.5.4-2, 3.6.6-1 and 3.6.6-2 are enclosed as Attachment 2 to this letter. These pages were changed by Amendments 261/241, approved by the NRC Safety Evaluation of March 29, 2011 (ML110680357) for the relocation of specific surveillance frequencies to a licensee controlled program (TSTF-425). The replacement pages do not contain any changes in addition to those requested by Duke Energy's May 28, 2010 submittal.

www. duke-energy cornOU

U.S. Nuclear Regulatory Commission May 2,2011 Page 2 There are no Regulatory Commitments contained in this letter.

The information contained in this letterdid not result in any impact to the original No Significant Hazards Consideration or the Environmental Consideration contained in the May 28, 2010 submittal.

Pursuant to 10 CFR 50.91, a copy of this letter is being sent to the designated official of the State of North Carolina.

If you have any questions or require additional information, please contact K. L. Ashe at (980) 875-4535.

Very truly yours, R. T. Repko Attachments xc (with attachments):

V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)

NRC Senior Project Manager (McGuire)

U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 W. L. Cox IIl, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission May 2, 2011 Page 3 Regis T. Repko affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Regis T. Repko, Vice President, McGuire Nuclear Station Subscribed and sworn to me: (no\, -4 20HI Date dýý_Ovu 6/'> INotary Public My commission expires: ?012-

'Date SEAL

K Attachment I for Additional Information Response to NRC Request

U.S. Nuclear Regulatory Commission Attachment 1 May 2, 2011 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEART REACTOR REGULATION REGARDING LICENSE AMENDMENT REQUEST RELATED TO EMERGENCY CORE COOLING SYSTEM (ECCS) WATER MANAGEMENT INITIATIVE McGUIRE NUCLEAR STATION, UNITS 1 AND 2 In Attachment 2 to the LAR, Technical Specification (TS) Table 3.3.2-1, insert 1, implies that the requirements of Function 2a are not applicable following implementation of the modifications associated with the LAR.

The NRC staff requests the following information:

1. Justify deletion of the proposed Function 2a from TS Table 3.3.2-1
2. Describe all the surveillance tests performed in Function 2a that are proposed to be deleted
3. Describe the TS related controls and instrumentation functions associated with the manual operation of the containment spray system that are required to be surveillance tested and describe according to which TS these will be tested.

Duke Response:

The requirements of Function 2 of Technical Specification (TS) Table 3.3.2-1, including Function 2a, are no longer applicable following approval of the LAR and implementation of the associated modifications. Table 3.3.2-1 lists Engineered Safety Features Actuation System (ESFAS) functions. At McGuire, ESFAS functions are performed by the Westinghouse Solid State Protection System (SSPS) using bistable and switch inputs from the W7300 process control system, field instruments and Main Control Board (MCB) manual switches.

Following implementation of the associated modifications, circuitry controlling the containment spray pumps and related motor valves will no longer go through the SSPS. Actuation and interlock circuitry will remain safety-related, but will be implemented instead in auxiliary relay cabinets.

Therefore, this circuitry will no longer be considered ESFAS at McGuire, and all Function 2 functions, including 2a, are being deleted from TS Table 3.3.2-1. This is identical to the TS change approved previously for Catawba Nuclear Station on June 28, 2010 as amendments 257/252 (ML092530088).

TS Table 3.3.2-1, Function 2a presently requires the completion of Surveillance Requirement (SR) 3.3.2.7, Trip Actuating Device Operational Test (TADOT) every 18 months. The TADOT for a manual function consists of operating the actuating device and verifying the operability of the alarm, interlock, and trip functions. The current implementing procedure is PT/1 (2)/A/4200/009A & B, which is the integrated testing of the entire ESFAS for train A and B, respectively. The procedure currently satisfies TS Table 3.3.2-1 surveillance requirement for Function 2a by manual operation of the "Initiate Phase B & Cont Spray Train A" pushbutton.

Following LAR implementation, this procedure step will be revised to test only the Phase B Page 1 of 2

U.S. Nuclear Regulatory Commission Attachment 1 May 2, 2011 Containment Isolation function, which uses the same existing (but relabeled) switch, and is retained in Table 3.3.2-1 as ESFAS Function 3b. Surveillance will continue as part of ESF testing under procedure PT/1 (2)/A/4200/009A & B.

The current Containment Spray system component surveillance requirements are listed in the procedure by reference to SR 3.6.6.3 and SR 3.6.6.4 "ContainmentSpray System". Following implementation of the modifications associated with ECCS Water Management on the respective Unit, the requirements of SR 3.6.6.3 and SR 3.6.6.4 shall no longer be applicable.

However, the manual spray pump actuation will be done using the pump start/stop pushbuttons on the MCB.

Manual containment spray pump operation will continue to be tested periodically as required by SR 3.6.6.2 for verification of the spray pump developed head in accordance with the Technical Specification 5.5.8 Inservice Testing Program (quarterly minflow and 18 month full flow testing, PT/1 &2/A/4208/001A & B, PT/1 &2/A/4208/021A & 021B). In addition, the manual start/stop push-buttons must be used in order to test the Containment Pressure Control System (CPCS),

which is verified at 18 month intervals by SR 3.6.6.5.

The procedure implementing SR 3.6.6.5 (CPCS functions for Containment Spray Pump) is PT/1(2)/A/4150/020, "NS Train CPCS Interlock Verification". This procedure exercises the pump "START" pushbutton and the acceptance criteria are given in the procedure step. The acceptance criteria are that the Containment Spray Pump start is inhibited when the simulated containment pressure signal is below the setpoint, and is permitted when it is above the setpoint. There are no other instrumentation and control functions associated with pump "START" pushbutton.

In conclusion, the surveillance test of the containment spray manual actuation switch in ESFAS Table 3.3.2-1, Function 2a is no longer applicable. The new functionality is implemented using the pump start/stop pushbutton on the MCB. Equivalent surveillance of this switch is already included elsewhere in the Technical Specifications. No new surveillance is required.

Page 2 of 2

Attachment 2 Replacement Technical Specification Pages

RWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 Verify RWST borated water temperature is > 70°F and In accordance with

< 1000F. the Surveillance Frequency Control Program SR 3.5.4.2 Verify RWST borated water volume is > 372,100 gallons. In accordance with the Surveillance Frequency Control Program SR 3.5.4.3 Verify RWST boron concentration is within the limits In accordance with specified in the COLR. the Surveillance Frequency Control Program 3

McGuire Units I and 2 3.5.4-2 Amendment Nos.ý2, --

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train inoperable, train to OPERABLE status.

B. Required Action and B. 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 not met. AND B.2 Be in MODE 5. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power operated, In accordance with and automatic valve in the flow path that is not locked, the Surveillance sealed, or otherwise secured in position is in the correct Frequency Control position. Program (continued)

  • LI McGuire Units 1 and 2 3.6.6-1 Amendment Nos

Containment Spray System 3.6.6 SURVEILLANCE FREQUENCY SR 3.6.6.2 Verify each containment spray pump's developed head at In accordance with the flow test point is greater than or equal to the required the Inservice developed head. Testing Program SR 3.6.6.3 Verify each automatic containment spray valve in the flow In accordance with path that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the correct position on an actual or Frequency Control simulated actuation signal. Program SR 3.6.6.4"fVerify each containment spray pump starts automatically In accordance with on an actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.6.6.5 Verify that each spray pump is de-energized and In accordance with prevented from starting upon receipt of a terminate signal the Surveillance and is allowed to start upon receipt of a start permissive Frequency Control from the Containment Pressure Control System (CPCS). Program SR 3.6.6.6 Verify that each spray pump discharge valve closes or is In accordance with prevented from opening upon receipt of a terminate the Surveillance signal and is allowed to open upon receipt of a start Frequency Control permissive from the Containment Pressure Control Program System (CPCS).

SR 3.6.6.7 Verify each spray nozzle is unobstructed. Following activities which could result in nozzle blockage McGuire Units 1 and 2 3.6.6-2 Amendment Nos-ý"?

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