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{{#Wiki_filter:}} | {{#Wiki_filter:S DUKE Steven D. CappsVice President~''ENERG..Y McGuire Nuclear StationDuke EnergyMG01VP I 12700 Hagers Ferry RoadHuntersville, NC 280780: 980.875.4805Seril No MNS16-02 1' 980.875.4809Seril N. MN-16002Steven.Capps@duke-energy.comJanuary 7, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionWashington, D.C. 20555ATTENTION: Document Control Desk | ||
==Subject:== | |||
Duke Energy Carolinas, LLC (Duke Energy)":McGuire Nuclear Station (MNS), Units 1 and 2,Docket Numbers 50-369 and 50-370, Renewed Facility Operating LicensesNPF-9 and NPF-17Catawba Nuclear Station (CNS), Units 1 and 2Docket Numbers 50-413 and 50-41 4, Renewed Facility Operating LicensesNPF-35 and NPF-52Proposed Technical Specifications (TS) Amendment TS 3.7.10, "Control RoomArea Chilled Water System" (MNS), and TS 3.7.11, "Control Room Area ChilledWater System" (CNS)Pursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the MNS and CNSFacility Operating Licenses and subject Technical Specifications (TS). This proposed licenseamendment request (LAR) modifies the TS by adding a new Action for both trains of ControlRoom Area Chilled Water Systems (CRACWS) inoperable. The new Action allows a finite timeto restore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at or below 90°F.The proposed LAR is modeled after TSTF-477; Rev. 3, "Add Action for Two Inoperable ControlRoom AC Subsystems." This TSTF is specific to the BWR NUREGs 1433 and 1434. DukeEnergy has determined this TSTF is readily adaptable to a NUREG-1 431 Standard TS for aWestinghouse plant. This topic was discussed with the NRC Staff on April 9, 2014. Theproposed amendment is not being submitted under the Consolidated Line Item ImprovementProcess (CLIIP) process.Attachment 1 provides Duke Energy's evaluation of the amendment, which contains adescription of the proposed changes, the technical evaluation, the regulatory analysis, thedetermination that this LAR contains No Significant Hazards Considerations, the basis for thecategorical exclusion from performing an Environmental Assessment/Impact Statement, andprecedent for the LAR.Attachment 2A provides the existing MNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.www.duke-energy.com U.S. Nuclear Regulatory Commission-MNS-1 6-002Page 2Attachment 2B provides the existing CNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.Attachment 3A provides a portion of the existing MNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the MNS Bases Control Program (TS 5.5.14).Attachment 3B provides a portion of the existing CNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the CNS Bases Control Program (TS 5.5.14).This proposed LAR has been reviewed and approved by the MNS and CNS Plant OperationsReview Committees in accordance with the requirements of the Duke Energy Quality AssuranceProgram.In accordance with 10 CFR 50.91, Duke Energy is notifying the applicable state officials of thisapplication for license amendment by transmitting a copy of this letter and its attachments to thedesignated officials.This submittal will not impact the MNS or CNS Updated Final Safety Analysis Reports(UFSARs).Duke Energy requests approval of this submittal within one calendar year of the submittal dateand an implementation period of 60 days from the date of amendment issuance.There are no regulatory commitments contained in this amendment.Please direct any questions you may have in this matter to Lee A. Hentz at (980) 875-41 87.I declare under penalty of perjury that the foregoing is true and correct. Executed on January 7,2016.Sincerely,Steven D. CappsAttachments U.S. Nuclear Regulatory CommissionMNS-1 6-002Page 3xc (with attachments):Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257G.A. Hutto, IllSenior Resident Inspector (Catawba)U.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG. E. Miller (addressee only)NRC Project Manager (Catawba and McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A11555 Rockville PikeRockville, MD 20852-2738S.E. JenkinsManagerRadioactive and Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IllSection ChiefDivision of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 ATTACHMENT 1EVALUATION OF PROPOSED AMENDMENT1.0 SUMMARY DESCRIPTION2.0 DETAILED DESCRIPTION | |||
==3.0 TECHNICAL EVALUATION== | |||
3.1 TS System Descriptions3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse Plant3.3 Operational Burden3.4 System Reliability Improvements3.5 Control Room Equipment Temperature Limit Validation3.6 Application of Proposed Change | |||
==4.0 REGULATORY EVALUATION== | |||
4.1 Applicable Regulatory Requirements/Criteria4.2 Precedents4.3 No Significant Hazards Consideration4.4 Conclusion | |||
==5.0 ENVIRONMENTAL CONSIDERATION== | |||
S | |||
==6.0 REFERENCES== | |||
I ATTACHMENT 11.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the McGuire NuclearStation (MNS) and Catawba Nuclear Station (CNS) Facility Operating Licenses and subjectTechnical Specifications (TS). This proposed license amendment request (LAR) modifies MNSTS 3.7.10, "Control Room Area Chilled Water Systems," and corresponding CNS TS 3.7.11 byadding a new Action for both trains of Control Room Area Chilled Water Systems (CRACWS)inoperable. The new Action allows a finite time, 24 hours, to restore one train to Operablestatus and requires periodic verification that Control Room temperature is maintained at orbelow 900°F.2.0 DETAILED DESCRIPTIONAs discussed in a meeting with the NRC staff on April 9, 2014, the proposed LAR is modeledafter TSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems." TSTF-477 is applicable only to BWR (General Electric) NUREGs 1433 and 1434, and adoption of thisTSTF is available to BWRs via the Consolidated Line Item Improvement Process (CLIIP). Sincethe CNS and MNS TS are based on the Westinghouse NUREG-1431 Standard TSs, this DukeEnergy LAR is not proposed to be processed via the CLIIP process. TSTF-477 adds aCondition to restore one Control Room AC subsystem within 72 hours in the event two ControlRoom AC subsystems become inoperable.Since the Duke Energy meeting with the NRC staff, the Technical Specification Task Force hassubmitted a Traveler, TSTF-553, for NRC review. TSTF-553 is similar to TSTF-477 but isapplicable to Westinghouse (NUREG-1 431) and Babcock & Wilcox (NUREG-1 430) plants andprovides a Completion Time of 24 hours for both plant types in the event two Control Room ACsubsystems become inoperable. TSTF-553 also includes a note that precludes use of the 24hour allowance when the second train is intentionally made inoperable. Although TSTF-553 hasnot yet been reviewed or approved by the NRC, the LAR proposed by Duke Energy adopts themore conservative 24 hour Completion Time and the additional restriction regarding intentionalentry into the Condition.The proposed LAR revises MNS TS 3.7.10 and CNS TS 3.7.11 as follows:a. Add a new Action B. New Action B applies when two CRACWS trains are inoperable.Required Action B.1 requires verification once per 4 hours that Control Roomtemperature is less than or equal to 90°F. Required Action B.2 requires restoration ofone CRACWS train to operable status within 24 hours.b. New Condition B is modified by a Note which states, "Not applicable when secondCRACWS train intentionally made inoperable." If the second CRACWS train isintentionally made inoperable, there is no applicable Condition~and immediate entry intoLCO 3.0.3 is required.c. Existing Action B, now renamed Action C, which applies when the Required Action andassociated Completion Time of Condition A (one CRACWS train inoperable) is not metin MODES 1, 2, 3,or 4, is revised to also be applicable when the Required Actions andassociated Completion Times of new Condition B~are not met. Renumbered Condition Crequires being in Mode 3 in 6 hours and Mode 5 in 36 hours.2 ATTACHMENT 1d. Existing Action C, now renamed Action D, remains unchanged.e. For MNS, existing Action 0, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of irradiated fuel assemblies or during corealterations, is revised to be applicable when the Required Actions and associatedCompletion Times of new Condition B are not met.f. For CNS, existing Action D, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of recently irradiated fuel assemblies, is revisedto be applicable when the Required Actions and associated Completion Times of newCondition B are not met.g. Existing Action E, which applied when two CRACWS trains are inoperable in MODE 1,2, 3, or 4, and requires entry into LCO 3.0.3, is no longer needed and deleted (redundantto revised Condition C.).The marked-up TS pages showing the proposed changes above are provided in Attachments2A and 2B.The corresponding TS Bases pages showing the proposed changes are provided inAttachments 3A and 3B. The TS Bases change will be processed after LAR approval under theMNS and CNS Bases Control Program (TS 5.5.14). They are provided in this LAR forinformation only. | |||
==3.0 TECHNICAL EVALUATION== | |||
3.1 TS System DescriptionsThe CRACWS provides air temperature control for the Control Room, Control Room Area, andSwitchgear Rooms. The Control Room Area (CRA) consists predominately of the Vital Batteryand Equipment Rooms, Motor Control Center (MCC) rooms, and Cable Rooms. TheSwitchgear Rooms contain the essential switchgear. The CRA and Switchgear Rooms are notpart of the Control Room Envelope and not governed by the CRACWS Technical Specifications.The CRACWS consists of two independent and redundant trains. Each train consists of achiller package, chilled water pump, air handling units with cooling coils, instrumentation, andcontrols.The CRACWS is an emergency system, which also operates during normal unit operations. Asingle train will provide the required temperature control to maintain the Control Room atapproximately 75°F for MNS and 74°F for CNS, respectively. The design basis of the CRACWSis to maintain the Control Room temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety related trains. During emergencyoperation, the CRACWS maintains the Control Room temperature between 75°F and 90°F forMNS and between 72°F and 85°F for CNS, respectively. A single active failure of a componentof the CRACWS, with a loss of offsite power, does not impair the ability of the system to performits design function. Redundant detectors and controls are provided for Control Roomtemperature control. The CRACWS is designed in accordance with Seismic Category I3 ATTACHMENT 1requirements. The CRACWS is capable of removing sensible and latent heat loads from theControl Room, which include consideration of equipment heat loads and personnel occupancyrequirements, to ensure equipment operability.Two independent and redundant trains of the CRACWS are required to be operable to ensurethat at least one is available, assuming a single failure disabling the other train. The CRACWSis shared between the two units. The system must be operable for each unit when that unit is inthe Mode of Applicability.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) are governed by separateTechnical Specifications; MNS TS 3.7.9 and CNS TS 3.7.10. The CRAVS is an emergencyredundant system that provides a protected habitable environment for the Control RoomEnvelope from which occupants can control the Units following an uncontrolled release ofradioactivity, hazardous chemicals, or smoke. The CRAVS does not provide a protectedhabitable environment for the Control Room Area or Switchgear Rooms. The inoperability ofCRACWS does not impact the operability of CRAVS.The MNS CRACWS and CRAVS are described in MNS UFSAR Section 6.4. The CNSCRACWS and CRAVS are described in CNS UFSAR Section 9.4.3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse PlantTSTF-477 Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems," was NRCapproved for adoption in 2007. This BWR (GE) specific TSTF allows for two trains of ControlRoom cooling to be inoperable for up to 72 hours as long as the Control Room areatemperature can be maintained (and monitored) within a pre-determined limit, commonly 90°F.The 72 hour Completion Time was deemed reasonable considering that Control Roomtemperature is being maintained within limits and the low probability of an event occurring thatwould require Control Room area isolation. Alternate methods of maintaining control roomtemperature, such as non-safety grade air conditioning systems or fans, can also be used tomaintain control room temperature. As previously stated in Section 2.0, Duke Energy will adoptthe more conservative Completion Time of 24 hours proposed by TSTF-553.TSTF-477 Rev. 3 is deterministically justified and relies on safety related cabinet equipmentqualification (EQ) temperature limits and Control Room heat-up assumptions. For the GEplants, a GE Topical Report supports the EQ justification. Duke Energy has performed sitespecific confirmations that equipment qualification for Control Room safety relatedinstrumentation and devices remains valid up to 90°F. Note MNS TS 3.7.10 and CNS TS 3.7.11already contain a Surveillance Requirement (SR) that confirms the Control Room is 90°F or lessevery 12 hours.AS precedent; TSTF-477 Rev. 3 references other GE Technical Specifications that currentlyprovide an Action with a finite time to restore one train to operable status when both trains areinoperable. MNS and CNS have similar Technical Specifications:1. MNS and CNS TSs 3.3.3, "Post Accident Monitoring" (7 days).2. MNS TS 3.7.11 and CNS TS 3.7.12, "Auxiliary Building Filtered Ventilation ExhaustSystem" (24 hours).4 ATTACHMENT 1Duke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, Request for AdditionalInformation (RAIs), and the NRC Safety Evaluations (SE) that adopted TSTF-477 Rev. 3.Based on that review, Duke Energy did not identify an issue that could not be addressed at ourplants and did not identify any GE/BWR specific requirements or conditions.3.3 Operational BurdenBoth MNS and CNS have experienced the inoperability of both trains of Control Room cooling.These occurred in 2005 and 2010 at MNS and in 2011 at CNS. With Control Room coolingbeing a shared system, these three events led to the initiation of a two unit shutdown.For the MNS events, one Control Room cooling train was functional but not operable. Notice ofEnforcement Discretion (NOEDs) were submitted and granted for MNS on both occasions toremain at power operation until one cooling train was restored to Operable status.For the CNS event, the "A" cooling train was in planned maintenance when the "B" cooling traintripped due to a chiller controls system micro-processor failure. Both units initiated a shutdownand proceeded to Mode 3 while a NOED was processed to not proceed to Mode 4. The "A"cooling train was restored shortly thereafter.As part of the 2010 NRC approved NOED, MNS committed to submit an LAR to addressoperability requirements of the Control Room cooling Technical Specification.3.4 System Reliability ImprovementsThe 2005 MNS event was caused by a degraded oil pressure switch, which prohibited the "A"cooling train chiller compressor from starting. At the time, the redundant cooling train wasfunctional but administratively inoperable due to support system alignments for refueling outageEngineered Safety Features (ESF) testing. The degraded oil pressure switch was replaced, andthen in 2007, the original chiller controls were replaced with digital controls, which improved thereliability of the oil pressure switch function.For the 2010 MNS event, the loss of the operating train of Control Room cooling was caused byhigh vibration of the hot gas bypass line (HGBP), which led to a breach of the coolant line. Atthe time, the redundant cooling train was in a planned maintenance evolution and temporarilyunavailable.Since 2010, both MNS Control Room cooling trains have been upgraded with new HGBP pipingto reduce vibration interactions, vibration isolators have been installed, corroded and erodedservice water piping has been replaced, small bore piping and tubing has been replaced, andpiping analysis models were developed to identify potential thermal stresses. In addition, thecondenser normal operating head pressure was reduced, which further reduced HGBP pipingvibration.After the 2011 CNS chiller micro-processor failure, significant efforts were made to determinethe cause of the failure and to enable the chiller to be rapidly restarted. The failed micro-processor was sent to the original qualifier of the controls who, in concert with the originalmanufacturer of the controls, investigated the cause of the failure. The manufacturer has manyyears of in-service experience with this type of micro-processor and has experienced very few5 ATTACHMENT 1failures. The failed micro-processor was subject to multiple tests, but the problem did not re-occur.Both companies recommended that failures of this type be addressed by removing andreapplying power to the micro-processor, similar to how many computer related problems areaddressed. This allows rapid re-start of the chiller. CNS has incorporated such actions into thecurrent operating procedures. In addition, CNS maintenance procedures have been enhancedto provide direction on how to replace a micro-processor which can now be done very quickly.Since MNS utilizes the same chiller controls, similar operating and maintenance procedureenhancements were incorporated.3.5 Control Room Equipment Temperature Limit ValidationMNS TS 3.7.10 and CNS TS 3.7.11 currently contain an SR that confirms the Control Room is90°F or less every 12 hours. As such, the current licensed design temperature of the ControlRoom equipment remains unchanged by the proposed TS changes.Duke Energy has also concluded that the 90°F limit in the new proposed TS Action B remainsunchanged based on a review of design specifications for the respective Control Room safetyrelated instruments and devices. Design specifications for protective equipment in the ControlRoom specify no loss of protective function over the temperature range of 40°F to 90°F and ahumidity range of 15 to 95% relative humidity.Therefore, monitoring of bulk Control Room temperature every 4 hours to ensure that ambienttemperature is less than or equal to 90°F would verify that the Control Room temperature is ator below the design limit.3.6 Application of Proposed ChangeThe most likely application of proposed Condition B and the associated Required Actions iswhen both CRACWS trains are inoperable but one train is functional with the ability to cool theControl Room. In this case, the Control Room temperature would remain constant at a normalvalue, and the 90°F limit is not challenged. One CRACWS would need to be restored toOperable status within 24 hours.In the event both CRACWS trains are inoperable and non-functional, MNS and CNS havedeveloped '"Abnormal Procedures" (AP) to mitigate rising temperatures in the Control Room andtake actions to shutdown the affected Units if temperature rises above 90°F, or there areindications of instrumentation malfunctions that have safety significance.4.0. REGULATORY EVALUATION4.1 Applicable Regulatory Requirements/CriteriaGeneral Design Criterion (GDC) 19, "Control Room" states in part:A Control Room shall be provided from which actions can be taken to operate thenuclear power unit safely under normal conditions and to maintain it in a safe condition6 ATTACHMENT 1under accident conditions, including loss-of-coolant accidents. Adequate radiationprotection shall be provided to permit access and occupancy of the control room underaccident conditions without personnel receiving radiation exposures in excess of 5 remwhole body, or its equivalent to any part of the body, for the duration of the accident.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) provide compliance withGDC 19. The CRAVS is an emergency redundant system that provides a protected habitableenvironment for the Control Room Envelope from which occupants can control the Unitsfollowing an uncontrolled release of radioactivity, hazardous chemicals, or smoke. Theproposed changes to the CRACWS TS do not impact the operability of CRAVS.In addition, the operability requirements of the CRACWS have not changed. The regulatoryrequirements do not specifically address Completion Times with inoperable systems. As aresult, the regulatory requirements and criteria are not affected by the proposed change.4.2 PrecedentsDuke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, PAls, and NRC SEsthat recently adopted TSTF-477 Rev. 3. Based on that review, Duke Energy did not identify anissue that could not be addressed at our plants and did not identify any GE/BWR specificrequirements or conditions.*PSEG Hope Creek Generating Station, LAR dated February 28, 2011 (ADAMSAccession No. ML1 10590636); as supplemented by letters dated August 29, 2011(ML1 12420124), December 16, 2011 (ML1 13530205), and January 26, 2012(ML12026A458); NRC SE dated February 8, 2012 (ML120180078).* SNC Edwin I. Hatch Nuclear Plant, LAR dated January 16, 2014, (ADAMS AccessionNo. ML14016A202); as supplemented by letter dated May 2, 2014 (ML14122A339); andNRC SE dated December 10, 2014 (ML14279A261).4.3 No Significant Hazards ConsiderationPursuant to 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes a licenseamendment request (LAR) for the Renewed Facility Operating License (FOL) and TechnicalSpecifications (TS) for McGuire (MNS) and Catawba (CNS) Nuclear Stations, Units I and 2.This proposed LAR modifies MNS TS 3.7.10, "Control Room Area Chilled Water Systems," andcorresponding CNS TS 3.7.11 by adding a new Action for both trains of Control Room AreaChilled Water Systems (CRACWS) inoperable. The new Action allows a finite time, 24 hours, torestore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at-or below 90°F degrees.- The-proposed LAR is modeled afterTSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems."Duke Energy has concluded that operation of the McGuire and Catawba Nuclear Stations inaccordance with the proposed generic changes to the Technical Specifications does not involvea significant hazards consideration. Duke Energy's conclusion is based on its evaluation, inaccordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c) asdiscussed below:7 ATTACHMENT 11. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?Response: No.The proposed change allows 24 hours to restore an inoperable CRACWS train when both trainsare inoperable provided Control Room temperature is verified to be within the design limitsevery 4 hours. The equipment qualification temperature of Control Room equipment is notaffected. The CRACWS is not an initiator of any accident previously evaluated. As a result, theprobability of any accident previously evaluated is not increased.The consequences of an accident during the proposed 24 hour Completion Time are nodifferent than the consequences of an accident during the existing 1 hour Completion Timeprovided in LCO 3.0.3 to prepare for a shutdown. The proposed TS changes do not increase orchange the current Control Room temperature limit. As a result, the consequences of anyaccident previously evaluated are not significantly increased.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?Response: No.No new or different accidents result from utilizing the proposed change. The TS changes do notinvolve a physical alteration of the plant or a change in the methods governing normal plantoperation. In addition, the changes do not impose any new or different requirements. Should thenew Actions not be met, the existing and proposed Actions require a plant shutdown. Thechanges do not alter assumptions made in the safety analysis. The proposed changes areconsistent with the safety analysis assumptions.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: No.The proposed change provides a limited period of time to restore an inoperable CRACWS traininstead of requiring an immediate plant shutdown. A plant shutdown is a transient, which maybe avoided by providing a limited time to make repairs. In addition, the Control RoomtemPerature must be maintained less than a limit set to_ ensure habitability of the Control Roomand the operability of-the equipment cooled by the CRACWS. The potential to avoid a planttransient, in conjunction with maintaining the Control Room temperature and the low probabilityof an event occurring during this time period, offset any risk associated with the limitedCompletion Time.Therefore, the proposed change does not involve a significant reduction in a margin of safety.8 ATTACHMENT 1Based on the above, Duke Energy concludes that the proposed change presents no significanthazards consideration under the standards set forth in 10 CER 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.4.4 ConclusionIn conclusion, based on the considerations discussed above, (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission's regulations,and (3) the approval of the proposed change will not be inimical to the common defense andsecurity or to the health and safety of the public. | |||
==5.0 ENVIRONMENTAL CONSIDERATION== | |||
SA review has determined that the proposed change would change a requirement with respect toinstallation or use of a facility component located within the restricted area, as defined in 10CER 20, or would change an inspection or surveillance requirement. However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant change in thetypes or significant increase in the amounts of any effluents that may be released offsite, or (iii)a significant increase in individual or cumulative occupational radiation exposure. Accordingly,the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR51 .22(c)(g).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmentalassessment need be prepared in connection with the proposed change.9 ATTACHMENT | |||
==16.0 REFERENCES== | |||
: 1) TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, datedMarch 26, 2007.2) NRC Letter, Summary of April 9, 2014, Public Teleconference Regarding PotentialSubmission of a License Amendment Request to Implement TSTF-477 for Control Room AirConditioning subsystems, dated April 21, 2014, ADAMS Accession No.ML14101A243.3) TSTF-553, Revision 0, Add Action for Two Inoperable CREA TCS Trains, transmitted forNRC review on October 31, 2015.4) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Units 1and 2, Docket Number 50-369 and 50-370 Notice of Enforcement Discretion RequestTechnical Specification (TS) 3. 7.10, Control Room Area Chilled water System, datedJanuary 14, 2010.5) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Unit 250-370 Notice of Enforcement Discretion Request Technical Specification 3. 7.10, ControlRoom Area Chilled water System (CRACWS), dated October 12, 2005.6) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke Energy) Catawba Nuclear Station,Units I and 2, Docket Number 50-4 13 and 50-4 14 Notice of Enforcement Discretion (NOED)Request Technical Specification (TS) 3. 7.11, "Control Room Area Chilled water System(CRACWS)" TS Limiting condition for Operation (LCO) 3.0.3 dated December 19, 2011.7) PSEG Letter, Hope Creek Generating Station, Facility Operating License No. NPF-57 NRCDocket No. 50-354 Application for Technical Specification Change TSF-4 77, Revision 3,Add Action for Two Inoperable Control Room AC Subsystems to the TechnicalSpecifications Using Consolidated Line Item Improvement Process, dated February 28,2011.8) Southern Nuclear Letter, Edwin I. Hatch Nuclear Plant Application for TechnicalSpecification Change to Revise Action Statements for Inoperable Control Room Airconditioning Subsystems, dated January 16, 2014.10 ATTACHMENT 2AMNS MARKED UP TECH SPEC PAGES CRACWS3.7.103.7 PLANT SYSTEMS3.7.10 Control Room Area Chilled Water System (CRACWS)LCO 3.7.10APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of irradiated fuel assemblies,During CORE ALTERATIONS.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.CAB_,. Required Action and ,B.1 Be in MODE 3. 6 hoursassociated CompletionTime of Condition A not ANDmet in MODE1, 2, Cor.ior 1.2 Be in MODE 5. 36 hoursDRequired Action and ¢.1 Place OPERABLE Immediatelyassociated Completion CRACWS train inTime of Condition A not operation.met in MODE 5 or 6, orduring movement of ORirradiated fuel Dassemblies, or during p.2.1 Suspend CORE ImmediatelyCORE ALTERATIONS. ALTERATIONS.ANDDZ;.2.2 Suspend movement of Immediatelyirradiated fuel assemblies.INSERT 1 New Condition B(continued)McGuire Units 1 and 23.7.10-1Mc~ure nitsI ad 2 .7.0-1Amendment No. 1-84/1t6e CRACWS3.7.10ACTIONS (continued)CONDITION [REQUIRED ACTION COMPLETION TIMEin MODE 5or 6, or duringmovement of irradiatedfuel assemblies, orduring COREALTERATIONS.Efr.1ANDE012Suspend COREALTERATIONS.Suspend movement ofirradiated fuel assemblies.ImmediatelyImmediatelyE. C"RA.\AI trains E.1 E nter !C 3.0.3 ~ vt41efihteySURVEILLANCE REQUIREMENTS _______SURVEILLANCE FREQUENCYSR 3.7.10.1 Verify the control room temperature is < 900F. In accordance withthe SurveillanceFrequency ControlProgramINSERTRequired Action and associated Completion Timeof Condition B not metIIMcGuire Units 1 and 23.7.10-2Mc~ure nits1 ad 2 .7.0-2Amendment No. | |||
INSERT 1 TS 3.7.10 New Condition BCONDITION f REQUIRED ACTION jCOMPLETION TIMENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature _< 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hours24 hoursU U ATTACHMENT 2BCNS MARKED UP TECH SPEC PAGES CRACWS3.7.113.7 PLANT SYSTEMS3.7.11 Control Room Area Chilled Water System (CRACWS)LCO 3.7.11APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of recently irradiated fuel assemblies.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.C.-BC. Required Action and B.1 Be in MODE 3. 6 hoursassociated CompletionTime of Condition A bnot ANDmet in MODE 1, 2, 3,\ C 36 hoursor 4. )--- .2 Be in MODE 5.-e;D. Required Action and Place OPERABLE Immediatelyassociated Completion CRACWS train in operation.Time of Condition A notmet in MODE 5or 6,or ORduring movement ofrecently irradiated fuel Suspend movement ofassemblies, recently irradiated fuel Immediatelyassemblies.(continued)INSERT 1 New Condition BCatawba Units 1 and 23.7.11-1Cataba nits1 ad 2 .7.1-1Amendment Nos. 1-98/1-9 CRACWS3.7.11CONDITION REQUIRED ACTION COMPLETION TIME-DE. Two CRA.CWS train-sT... in TnMODE 5or 6, or duringmovement of recentlyirradiated fuelassemblies.DE.1 Suspend movement ofrecently irradiated fuelassemblies.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.7.11.1 Verify the control room temperature is < 90°F. In accordance withthe SurveillanceFrequency ControlProgramNSERT1/4tNSERTRequired Action and associatedCompletion Time of Condition Bmetnotl IICatawba Units 1 and 23.7.11-2Cataba nits1 ad 2 .7.1-2Amendment Nos. 263, 2-59 INSERT 1 TS 3.7.11 New Condition BCONDITION REQUIRED ACTION [COMPLETION TIMEB. --- NOTENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature < 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hours24 hoursa a ATTACHMENT 3AMNS MARKED UP TECH SPEC BASES PAGES B 3.7 PLANT SYSTEMSB 3.7.10 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room followingisolation of the control room.The CRACWS consists of two independent and redundant trains thatprovide cooling of recirculated control room air. Each train consists ofcooling coils, instrumentation, and controls to provide for control roomtemperature control. The CRACWS is a subsystem providing airtemperature control for the control room.The CRACWS is an emergency system, parts of which may also operateduring normal unit operations. A single train will provide the requiredtemperature control to maintain the control room at approximately 75°F.The CRACWS operation in maintaining the control room temperature isdiscussed in the UFSAR, Section 6.4 (Ref. 1).There are components that are part of the CRACWS but do not affect theCRAVS. These components are associated with the Control Room AreaAir Handling units, the Switchgear Air Handling units. LCO 3.7.10 doesnot apply if a CRAVS component does not directly impact the CRACWS.APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 75°F and 90°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.The CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).McGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-1Revision No. "I"1-5 CRACWSB 3.7.10BASESLCO Two independent and redundant trains of the CRACWS arerequired to be OPERABLE to ensure that at least one is available,assuming a single failure disabling the other train. Total systemfailure could result in the equipment operating temperatureexceeding limits in the event of an accident.The CRACWS is considered to be OPERABLE when theindividual components necessary to maintain the control roomtemperature are OPERABLE in both trains. These componentsinclude the cooling coils and associated temperature controlinstrumentation. In addition, the CRACWS must be operable tothe extent that air circulation can be maintained.The CRACWS is shared between the two units. The system mustbe OPERABLE for each unit when that unit is in the MODE ofApplicability. Additionally, both normal and emergency powermust also be OPERABLE because the system is shared. If aCRACWS component becomes inoperable, or normal oremergency power to a CRACWS component becomes inoperable,then the Required Actions of this LCO must be enteredindependently for each unit that is in the MODE of applicability ofthe LCO.APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of irradiatedfuel assemblies and during CORE ALTERATIONS, the CRACWSmust be OPERABLE to ensure that the control room temperaturewill not exceed equipment operational requirements followingisolation of the control room.ACTIONS A.1With one CRACWS train inoperable, action must be taken torestore OPERABLE status within 30 days. In this Condition, theremaining OPERABLE CRACWS train is adequate to maintain thecontrol room temperature within limits. However, the overallreliability is reduced because a single failure in the OPERABLECRACWS train could result in loss of CRACWS function. The30 day Completion Time is based on the low probability of anevent requiring control room isolation, the consideration that theremaining train can provide the required protection, and thatalternate safety or nonsafety related cooling means are available.(ew paragraph) anB2Im mMcGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-2Revision No. "I-I-5 INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored toensure that temperature is being maintained low enough that equipment in the control room isnot adversely affected and remains habitable. Mitigating actions, such as opening cabinetdoors, use of fans, or opening control room doors or ventilation paths, may be used to maintaincontrol room temperature. With the control room temperature being maintained within thetemperature limit, 24 hours is allowed to restore a CRACWS train to OPERABLE status. ThisCompletion Time is reasonable considering that the control room temperature is beingmaintained within limits and the low probability of an event occurring requiring control roomisolation.The condition is modified by a Note stating it is not applicable when the second CRACWS trainis intentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time. | |||
CRACWSB 3.7.10BASESACTIONS (continued) assocated t ra~nIn MODE 1, 2, 3, or 4, if the inoperable- R:ACWS trafti cannot berestored to OPERABLE status within the Time, the unit must be placed in a MODE that minimizes the risk.To achieve this status, the unit must be placed in at least MODE 3within 6 hours, and in MODE 5 within 36 hours. The allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.D D 0[A. 1,X32.1. and [.2.2In MODE 5 or 6, or during movement of irradiated fuel, or duringCORE ALTERATIONS, if the inoperable CRACWS train cannot berestored to OPERABLE status within the required CompletionTime, the OPERABLE CRACWS train must be placed in operationimmediately. This action ensures that the remaining train isOPERABLE, that no failures preventing automatic actuation willoccur, and that active failures will be readily detected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity thatmight require isolation of the control room. This places the unit ina condition that the movement of fuel if Required Actions B.1 or B.2 cannotE be met within the required Completion1 and.2 /TimesIn MODE 5 or 6, or during movement f. irradiated fuel assemblies,or during CORE ALTERATIONS, hiprbe, action must be taken immediately to suspend activities Ithat could result in a release of radioactivity that might requireisolation of the control room. This places the unit in a conditionthat minimizes risk. This does not preclude the movement of fuelto a safe position.If b.,cth ;r,,, ,noop,.rabohl in MODEN: "1. 2. 3. or I the"cotinrrl roomir a y n,,o.. t .,bo. c,, ap...blc ofI pz-^ r- In^g^....... .. .... .. .t".. ,i.,,,,, itSIrIIIdtjlltd lUIiL~, i. I. I 3I.0.3.. III..u l.iat ,b 1 lc.,tcz,McGuire Units 1 and 2B37103RvsoN.1-5B 3.7.10-3Revision No. ffff5 CRACWSB 3.7.10BASESSURVEILLANCE SR 3.7.10.1REQUIREMENTSThis SR verifies that the heat removal capability of the system issufficient to maintain the temperature in the control room at orbelow 90°F. The Surveillance Frequency is based on operatingexperience, equipment reliability, and plant risk and is controlledunder the Surveillance Frequency Control Program.REFERENCES1. UFSAR, Section 6.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).McGuire Units 1 and 2B37104RvsoN.1--B 3.7.10-4Revision No. 4-'1-5 ATTACHMENT 3BONS MARKED UP TECH SPEC BASES PAGES CRACWSB 3.7.11B 3.7 PLANT SYSTEMSB 3.7.11 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room and thecontrol room area.The CRACWS consists of two independent and redundant trains thatprovide cooling to the control room and control room area. Each trainconsists of a chiller package, chilled water pump, and air handling unitswith cooling coils. Chilled water is passed through the cooling coils of theair handling unit to cool the air. Electric duct heaters are then used tocontrol the supply air temperature.The CRACWS provides both normal and emergency cooling to thecontrol room and control room area. A single train will provide therequired temperature control to maintain the control room approximately74°F. The CRACWS operation in maintaining the control roomtemperature is discussed in the UFSAR, Section 9.4 (Ref. 1).APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 72°F and 85°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.Th'e CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).Catawba Units 1 and 2 B 3.7.11-1 Revision No. | |||
CRACWSB 3.7.11BASESLCOTwo independent and redundant trains of the CRACWS are required tobe OPERABLE to ensure that at least one is available, assuming a singlefailure disabling the other train. Total system failure could result in theequipment operating temperature exceeding limits in the event of anaccident.The CRACWS is considered to be OPERABLE when the individualcomponents necessary to maintain the control room temperature areOPERABLE in both trains. These components include a chiller package,chilled water pump, and air handling unit. In addition, the CRACWS mustbe OPERABLE to the extent that air circulation can be maintained.The CRACWS is shared between the two units. The system must beOPERABLE for each unit when that unit is in the MODE of Applicability.Additionally, both normal and emergency power must also beOPERABLE because the system is shared. A shutdown unit supplying itsassociated emergency power source (1 EMXG/2EMXH) cannot becredited for OPERABILITY of components supporting the operating unit.If a CRACWS component becomes inoperable, or normal or emergencypower to a CRACWS component becomes inoperable, then the RequiredActions of this LCO must be entered independently for each unit that is inthe MODE of applicability of the LCO.APPLICABILITYIn MODES 1, 2, 3, 4, 5, and 6, and during movement of recentlyirradiated fuel assemblies, the CRACWS must be OPERABLE to ensurethat the control room temperature will not exceed equipment operationalrequirements following a design basis accident. The CRACWS is onlyrequired to be OPERABLE during fuel handling involving handlingrecently irradiated fuel (i.e., fuel that has occupied part of a critical reactorcore within the previous 72 hours) due to radioactive decay.ACTIONSA.__1With one CRACWS train inoperable, action must be taken to restoreOPERABLE status within 30 days. In this Condition, the remainingOPERABLE CRACWS train is adequate to maintain the control roomtemperature within limits. However, the overall reliability is reducedbecause a single failure in the OPERABLE CRACWS train could result inloss of CRACWS function. The 30 day Completion Time is based on thelow probability of an event, the consideration that the remaining train canprovide the required protection, and that alternate safety or nonsafetyrelated cooling means are available.INSERT 2 B.1 and B.2(new paragraph)ICatawba Units 1 and 2B371-2RvsoNOB 3.7.11-2Revision INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored to ensurethat temperature is being maintained low enough that equipment in the control room is notadversely affected and remains habitable. Mitigating actions, such as opening cabinet doors,use of fans, or opening control room doors or ventilation paths, may be used to maintain controlroom temperature. With the control room temperature being maintained within the temperaturelimit, 24 hours is allowed to restore a CRACWS train to OPERABLE status. This CompletionTime is reasonable considering that the control room temperature is being maintained withinlimits and the low probability of an event occurring requiring control room isolation.The condition is modified by a Note stating it is not applicable when the second CRACWS train isintentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time. | |||
CRACWSB 3.7.11BASESACTIONS (continueIIi an C 1asscae Itrain s)/In MODE 1, 2, 3, or 4, if the inoperab .,<RACWS tr cannot berestored to OPERABLE status within the Completion Time, theunit must be placed in a MODE that minimizes the risk. To achieve thisstatus, the unit must be placed in at least MODE 3 within 6 hours, and inMODE 5 within 36 hours. The allowed Completion Times are reasonable,based on operating experience, to reach the required unit conditions fromfull power conditions in an orderly manner and without challenging unitsystems..l and D.In MODE 5 or 6, or during movement of recently irradiated fuel, if theinoperable CRACWS train cannot be restored to OPERABLE statuswithin the required Completion Time, the OPERABLE CRACWS trainmust be placed in operation immediately. This action ensures that theremaining train is OPERABLE, and that active failures will be readilydetected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity. This placesthe unit in a condition that minimizes accident risk. This does notpreclude th-' ma~,,-m-,rt i'f f, ,--I ta =- nn~itiAnI if Required Actions B.1 or B.2 cannot bemet within the required Completion TimesI* IIn MODE 5or 6,or urn moeeto eetyirradiated fuelassemblies, wihtf RCSt'lq ,o~sle, action must be takenimmediately to suspend activities that could result in a release ofradioactivity. This places the unit in a condition that minimizes risk. Thisdoes not preclude the movement of fuel to a safe position.It hnth CRAPW~ trnir.~ ~IIIUperabIlU MODIIEJ~l 1,2, 3, Ul 4', tllr:: rwII Igr..om........ma..not c ....bl cf p6-o-~F tg ,n ftllded ['urLiuunI.Therefore, LCOJ 3.U.3 must be entered Immediately.Catawba Units I and 2B3.113evsoNoB 3.7.11-3Revision CRACWSB 3.7.11BASESSURVEILLANCE SR 3.7.11.1REQUI REMENTSThis SR verifies that the heat removal capability of the system is sufficientto maintain the temperature in the control room at or below 90°F. TheSurveillance Frequency is based on operating experience, equipmentreliability, and plant risk and is controlled under the SurveillanceFrequency Control Program.REFERENCES1. UFSAR, Section 9.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).3. 10 CFR 50.67, Accident source term.4. Regulatory Guide 1.183, Revision 0.Catawba Units 1 and 2 B371- eiinNAB 3.7.11-4Revision No./,3/ | |||
S DUKE Steven D. CappsVice President~''ENERG..Y McGuire Nuclear StationDuke EnergyMG01VP I 12700 Hagers Ferry RoadHuntersville, NC 280780: 980.875.4805Seril No MNS16-02 1' 980.875.4809Seril N. MN-16002Steven.Capps@duke-energy.comJanuary 7, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionWashington, D.C. 20555ATTENTION: Document Control Desk | |||
==Subject:== | |||
Duke Energy Carolinas, LLC (Duke Energy)":McGuire Nuclear Station (MNS), Units 1 and 2,Docket Numbers 50-369 and 50-370, Renewed Facility Operating LicensesNPF-9 and NPF-17Catawba Nuclear Station (CNS), Units 1 and 2Docket Numbers 50-413 and 50-41 4, Renewed Facility Operating LicensesNPF-35 and NPF-52Proposed Technical Specifications (TS) Amendment TS 3.7.10, "Control RoomArea Chilled Water System" (MNS), and TS 3.7.11, "Control Room Area ChilledWater System" (CNS)Pursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the MNS and CNSFacility Operating Licenses and subject Technical Specifications (TS). This proposed licenseamendment request (LAR) modifies the TS by adding a new Action for both trains of ControlRoom Area Chilled Water Systems (CRACWS) inoperable. The new Action allows a finite timeto restore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at or below 90°F.The proposed LAR is modeled after TSTF-477; Rev. 3, "Add Action for Two Inoperable ControlRoom AC Subsystems." This TSTF is specific to the BWR NUREGs 1433 and 1434. DukeEnergy has determined this TSTF is readily adaptable to a NUREG-1 431 Standard TS for aWestinghouse plant. This topic was discussed with the NRC Staff on April 9, 2014. Theproposed amendment is not being submitted under the Consolidated Line Item ImprovementProcess (CLIIP) process.Attachment 1 provides Duke Energy's evaluation of the amendment, which contains adescription of the proposed changes, the technical evaluation, the regulatory analysis, thedetermination that this LAR contains No Significant Hazards Considerations, the basis for thecategorical exclusion from performing an Environmental Assessment/Impact Statement, andprecedent for the LAR.Attachment 2A provides the existing MNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.www.duke-energy.com U.S. Nuclear Regulatory Commission-MNS-1 6-002Page 2Attachment 2B provides the existing CNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.Attachment 3A provides a portion of the existing MNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the MNS Bases Control Program (TS 5.5.14).Attachment 3B provides a portion of the existing CNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the CNS Bases Control Program (TS 5.5.14).This proposed LAR has been reviewed and approved by the MNS and CNS Plant OperationsReview Committees in accordance with the requirements of the Duke Energy Quality AssuranceProgram.In accordance with 10 CFR 50.91, Duke Energy is notifying the applicable state officials of thisapplication for license amendment by transmitting a copy of this letter and its attachments to thedesignated officials.This submittal will not impact the MNS or CNS Updated Final Safety Analysis Reports(UFSARs).Duke Energy requests approval of this submittal within one calendar year of the submittal dateand an implementation period of 60 days from the date of amendment issuance.There are no regulatory commitments contained in this amendment.Please direct any questions you may have in this matter to Lee A. Hentz at (980) 875-41 87.I declare under penalty of perjury that the foregoing is true and correct. Executed on January 7,2016.Sincerely,Steven D. CappsAttachments U.S. Nuclear Regulatory CommissionMNS-1 6-002Page 3xc (with attachments):Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257G.A. Hutto, IllSenior Resident Inspector (Catawba)U.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG. E. Miller (addressee only)NRC Project Manager (Catawba and McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A11555 Rockville PikeRockville, MD 20852-2738S.E. JenkinsManagerRadioactive and Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IllSection ChiefDivision of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 ATTACHMENT 1EVALUATION OF PROPOSED AMENDMENT1.0 SUMMARY DESCRIPTION2.0 DETAILED DESCRIPTION | |||
==3.0 TECHNICAL EVALUATION== | |||
3.1 TS System Descriptions3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse Plant3.3 Operational Burden3.4 System Reliability Improvements3.5 Control Room Equipment Temperature Limit Validation3.6 Application of Proposed Change | |||
==4.0 REGULATORY EVALUATION== | |||
4.1 Applicable Regulatory Requirements/Criteria4.2 Precedents4.3 No Significant Hazards Consideration4.4 Conclusion | |||
==5.0 ENVIRONMENTAL CONSIDERATION== | |||
S | |||
==6.0 REFERENCES== | |||
I ATTACHMENT 11.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the McGuire NuclearStation (MNS) and Catawba Nuclear Station (CNS) Facility Operating Licenses and subjectTechnical Specifications (TS). This proposed license amendment request (LAR) modifies MNSTS 3.7.10, "Control Room Area Chilled Water Systems," and corresponding CNS TS 3.7.11 byadding a new Action for both trains of Control Room Area Chilled Water Systems (CRACWS)inoperable. The new Action allows a finite time, 24 hours, to restore one train to Operablestatus and requires periodic verification that Control Room temperature is maintained at orbelow 900°F.2.0 DETAILED DESCRIPTIONAs discussed in a meeting with the NRC staff on April 9, 2014, the proposed LAR is modeledafter TSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems." TSTF-477 is applicable only to BWR (General Electric) NUREGs 1433 and 1434, and adoption of thisTSTF is available to BWRs via the Consolidated Line Item Improvement Process (CLIIP). Sincethe CNS and MNS TS are based on the Westinghouse NUREG-1431 Standard TSs, this DukeEnergy LAR is not proposed to be processed via the CLIIP process. TSTF-477 adds aCondition to restore one Control Room AC subsystem within 72 hours in the event two ControlRoom AC subsystems become inoperable.Since the Duke Energy meeting with the NRC staff, the Technical Specification Task Force hassubmitted a Traveler, TSTF-553, for NRC review. TSTF-553 is similar to TSTF-477 but isapplicable to Westinghouse (NUREG-1 431) and Babcock & Wilcox (NUREG-1 430) plants andprovides a Completion Time of 24 hours for both plant types in the event two Control Room ACsubsystems become inoperable. TSTF-553 also includes a note that precludes use of the 24hour allowance when the second train is intentionally made inoperable. Although TSTF-553 hasnot yet been reviewed or approved by the NRC, the LAR proposed by Duke Energy adopts themore conservative 24 hour Completion Time and the additional restriction regarding intentionalentry into the Condition.The proposed LAR revises MNS TS 3.7.10 and CNS TS 3.7.11 as follows:a. Add a new Action B. New Action B applies when two CRACWS trains are inoperable.Required Action B.1 requires verification once per 4 hours that Control Roomtemperature is less than or equal to 90°F. Required Action B.2 requires restoration ofone CRACWS train to operable status within 24 hours.b. New Condition B is modified by a Note which states, "Not applicable when secondCRACWS train intentionally made inoperable." If the second CRACWS train isintentionally made inoperable, there is no applicable Condition~and immediate entry intoLCO 3.0.3 is required.c. Existing Action B, now renamed Action C, which applies when the Required Action andassociated Completion Time of Condition A (one CRACWS train inoperable) is not metin MODES 1, 2, 3,or 4, is revised to also be applicable when the Required Actions andassociated Completion Times of new Condition B~are not met. Renumbered Condition Crequires being in Mode 3 in 6 hours and Mode 5 in 36 hours.2 ATTACHMENT 1d. Existing Action C, now renamed Action D, remains unchanged.e. For MNS, existing Action 0, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of irradiated fuel assemblies or during corealterations, is revised to be applicable when the Required Actions and associatedCompletion Times of new Condition B are not met.f. For CNS, existing Action D, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of recently irradiated fuel assemblies, is revisedto be applicable when the Required Actions and associated Completion Times of newCondition B are not met.g. Existing Action E, which applied when two CRACWS trains are inoperable in MODE 1,2, 3, or 4, and requires entry into LCO 3.0.3, is no longer needed and deleted (redundantto revised Condition C.).The marked-up TS pages showing the proposed changes above are provided in Attachments2A and 2B.The corresponding TS Bases pages showing the proposed changes are provided inAttachments 3A and 3B. The TS Bases change will be processed after LAR approval under theMNS and CNS Bases Control Program (TS 5.5.14). They are provided in this LAR forinformation only. | |||
==3.0 TECHNICAL EVALUATION== | |||
3.1 TS System DescriptionsThe CRACWS provides air temperature control for the Control Room, Control Room Area, andSwitchgear Rooms. The Control Room Area (CRA) consists predominately of the Vital Batteryand Equipment Rooms, Motor Control Center (MCC) rooms, and Cable Rooms. TheSwitchgear Rooms contain the essential switchgear. The CRA and Switchgear Rooms are notpart of the Control Room Envelope and not governed by the CRACWS Technical Specifications.The CRACWS consists of two independent and redundant trains. Each train consists of achiller package, chilled water pump, air handling units with cooling coils, instrumentation, andcontrols.The CRACWS is an emergency system, which also operates during normal unit operations. Asingle train will provide the required temperature control to maintain the Control Room atapproximately 75°F for MNS and 74°F for CNS, respectively. The design basis of the CRACWSis to maintain the Control Room temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety related trains. During emergencyoperation, the CRACWS maintains the Control Room temperature between 75°F and 90°F forMNS and between 72°F and 85°F for CNS, respectively. A single active failure of a componentof the CRACWS, with a loss of offsite power, does not impair the ability of the system to performits design function. Redundant detectors and controls are provided for Control Roomtemperature control. The CRACWS is designed in accordance with Seismic Category I3 ATTACHMENT 1requirements. The CRACWS is capable of removing sensible and latent heat loads from theControl Room, which include consideration of equipment heat loads and personnel occupancyrequirements, to ensure equipment operability.Two independent and redundant trains of the CRACWS are required to be operable to ensurethat at least one is available, assuming a single failure disabling the other train. The CRACWSis shared between the two units. The system must be operable for each unit when that unit is inthe Mode of Applicability.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) are governed by separateTechnical Specifications; MNS TS 3.7.9 and CNS TS 3.7.10. The CRAVS is an emergencyredundant system that provides a protected habitable environment for the Control RoomEnvelope from which occupants can control the Units following an uncontrolled release ofradioactivity, hazardous chemicals, or smoke. The CRAVS does not provide a protectedhabitable environment for the Control Room Area or Switchgear Rooms. The inoperability ofCRACWS does not impact the operability of CRAVS.The MNS CRACWS and CRAVS are described in MNS UFSAR Section 6.4. The CNSCRACWS and CRAVS are described in CNS UFSAR Section 9.4.3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse PlantTSTF-477 Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems," was NRCapproved for adoption in 2007. This BWR (GE) specific TSTF allows for two trains of ControlRoom cooling to be inoperable for up to 72 hours as long as the Control Room areatemperature can be maintained (and monitored) within a pre-determined limit, commonly 90°F.The 72 hour Completion Time was deemed reasonable considering that Control Roomtemperature is being maintained within limits and the low probability of an event occurring thatwould require Control Room area isolation. Alternate methods of maintaining control roomtemperature, such as non-safety grade air conditioning systems or fans, can also be used tomaintain control room temperature. As previously stated in Section 2.0, Duke Energy will adoptthe more conservative Completion Time of 24 hours proposed by TSTF-553.TSTF-477 Rev. 3 is deterministically justified and relies on safety related cabinet equipmentqualification (EQ) temperature limits and Control Room heat-up assumptions. For the GEplants, a GE Topical Report supports the EQ justification. Duke Energy has performed sitespecific confirmations that equipment qualification for Control Room safety relatedinstrumentation and devices remains valid up to 90°F. Note MNS TS 3.7.10 and CNS TS 3.7.11already contain a Surveillance Requirement (SR) that confirms the Control Room is 90°F or lessevery 12 hours.AS precedent; TSTF-477 Rev. 3 references other GE Technical Specifications that currentlyprovide an Action with a finite time to restore one train to operable status when both trains areinoperable. MNS and CNS have similar Technical Specifications:1. MNS and CNS TSs 3.3.3, "Post Accident Monitoring" (7 days).2. MNS TS 3.7.11 and CNS TS 3.7.12, "Auxiliary Building Filtered Ventilation ExhaustSystem" (24 hours).4 ATTACHMENT 1Duke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, Request for AdditionalInformation (RAIs), and the NRC Safety Evaluations (SE) that adopted TSTF-477 Rev. 3.Based on that review, Duke Energy did not identify an issue that could not be addressed at ourplants and did not identify any GE/BWR specific requirements or conditions.3.3 Operational BurdenBoth MNS and CNS have experienced the inoperability of both trains of Control Room cooling.These occurred in 2005 and 2010 at MNS and in 2011 at CNS. With Control Room coolingbeing a shared system, these three events led to the initiation of a two unit shutdown.For the MNS events, one Control Room cooling train was functional but not operable. Notice ofEnforcement Discretion (NOEDs) were submitted and granted for MNS on both occasions toremain at power operation until one cooling train was restored to Operable status.For the CNS event, the "A" cooling train was in planned maintenance when the "B" cooling traintripped due to a chiller controls system micro-processor failure. Both units initiated a shutdownand proceeded to Mode 3 while a NOED was processed to not proceed to Mode 4. The "A"cooling train was restored shortly thereafter.As part of the 2010 NRC approved NOED, MNS committed to submit an LAR to addressoperability requirements of the Control Room cooling Technical Specification.3.4 System Reliability ImprovementsThe 2005 MNS event was caused by a degraded oil pressure switch, which prohibited the "A"cooling train chiller compressor from starting. At the time, the redundant cooling train wasfunctional but administratively inoperable due to support system alignments for refueling outageEngineered Safety Features (ESF) testing. The degraded oil pressure switch was replaced, andthen in 2007, the original chiller controls were replaced with digital controls, which improved thereliability of the oil pressure switch function.For the 2010 MNS event, the loss of the operating train of Control Room cooling was caused byhigh vibration of the hot gas bypass line (HGBP), which led to a breach of the coolant line. Atthe time, the redundant cooling train was in a planned maintenance evolution and temporarilyunavailable.Since 2010, both MNS Control Room cooling trains have been upgraded with new HGBP pipingto reduce vibration interactions, vibration isolators have been installed, corroded and erodedservice water piping has been replaced, small bore piping and tubing has been replaced, andpiping analysis models were developed to identify potential thermal stresses. In addition, thecondenser normal operating head pressure was reduced, which further reduced HGBP pipingvibration.After the 2011 CNS chiller micro-processor failure, significant efforts were made to determinethe cause of the failure and to enable the chiller to be rapidly restarted. The failed micro-processor was sent to the original qualifier of the controls who, in concert with the originalmanufacturer of the controls, investigated the cause of the failure. The manufacturer has manyyears of in-service experience with this type of micro-processor and has experienced very few5 ATTACHMENT 1failures. The failed micro-processor was subject to multiple tests, but the problem did not re-occur.Both companies recommended that failures of this type be addressed by removing andreapplying power to the micro-processor, similar to how many computer related problems areaddressed. This allows rapid re-start of the chiller. CNS has incorporated such actions into thecurrent operating procedures. In addition, CNS maintenance procedures have been enhancedto provide direction on how to replace a micro-processor which can now be done very quickly.Since MNS utilizes the same chiller controls, similar operating and maintenance procedureenhancements were incorporated.3.5 Control Room Equipment Temperature Limit ValidationMNS TS 3.7.10 and CNS TS 3.7.11 currently contain an SR that confirms the Control Room is90°F or less every 12 hours. As such, the current licensed design temperature of the ControlRoom equipment remains unchanged by the proposed TS changes.Duke Energy has also concluded that the 90°F limit in the new proposed TS Action B remainsunchanged based on a review of design specifications for the respective Control Room safetyrelated instruments and devices. Design specifications for protective equipment in the ControlRoom specify no loss of protective function over the temperature range of 40°F to 90°F and ahumidity range of 15 to 95% relative humidity.Therefore, monitoring of bulk Control Room temperature every 4 hours to ensure that ambienttemperature is less than or equal to 90°F would verify that the Control Room temperature is ator below the design limit.3.6 Application of Proposed ChangeThe most likely application of proposed Condition B and the associated Required Actions iswhen both CRACWS trains are inoperable but one train is functional with the ability to cool theControl Room. In this case, the Control Room temperature would remain constant at a normalvalue, and the 90°F limit is not challenged. One CRACWS would need to be restored toOperable status within 24 hours.In the event both CRACWS trains are inoperable and non-functional, MNS and CNS havedeveloped '"Abnormal Procedures" (AP) to mitigate rising temperatures in the Control Room andtake actions to shutdown the affected Units if temperature rises above 90°F, or there areindications of instrumentation malfunctions that have safety significance.4.0. REGULATORY EVALUATION4.1 Applicable Regulatory Requirements/CriteriaGeneral Design Criterion (GDC) 19, "Control Room" states in part:A Control Room shall be provided from which actions can be taken to operate thenuclear power unit safely under normal conditions and to maintain it in a safe condition6 ATTACHMENT 1under accident conditions, including loss-of-coolant accidents. Adequate radiationprotection shall be provided to permit access and occupancy of the control room underaccident conditions without personnel receiving radiation exposures in excess of 5 remwhole body, or its equivalent to any part of the body, for the duration of the accident.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) provide compliance withGDC 19. The CRAVS is an emergency redundant system that provides a protected habitableenvironment for the Control Room Envelope from which occupants can control the Unitsfollowing an uncontrolled release of radioactivity, hazardous chemicals, or smoke. Theproposed changes to the CRACWS TS do not impact the operability of CRAVS.In addition, the operability requirements of the CRACWS have not changed. The regulatoryrequirements do not specifically address Completion Times with inoperable systems. As aresult, the regulatory requirements and criteria are not affected by the proposed change.4.2 PrecedentsDuke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, PAls, and NRC SEsthat recently adopted TSTF-477 Rev. 3. Based on that review, Duke Energy did not identify anissue that could not be addressed at our plants and did not identify any GE/BWR specificrequirements or conditions.*PSEG Hope Creek Generating Station, LAR dated February 28, 2011 (ADAMSAccession No. ML1 10590636); as supplemented by letters dated August 29, 2011(ML1 12420124), December 16, 2011 (ML1 13530205), and January 26, 2012(ML12026A458); NRC SE dated February 8, 2012 (ML120180078).* SNC Edwin I. Hatch Nuclear Plant, LAR dated January 16, 2014, (ADAMS AccessionNo. ML14016A202); as supplemented by letter dated May 2, 2014 (ML14122A339); andNRC SE dated December 10, 2014 (ML14279A261).4.3 No Significant Hazards ConsiderationPursuant to 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes a licenseamendment request (LAR) for the Renewed Facility Operating License (FOL) and TechnicalSpecifications (TS) for McGuire (MNS) and Catawba (CNS) Nuclear Stations, Units I and 2.This proposed LAR modifies MNS TS 3.7.10, "Control Room Area Chilled Water Systems," andcorresponding CNS TS 3.7.11 by adding a new Action for both trains of Control Room AreaChilled Water Systems (CRACWS) inoperable. The new Action allows a finite time, 24 hours, torestore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at-or below 90°F degrees.- The-proposed LAR is modeled afterTSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems."Duke Energy has concluded that operation of the McGuire and Catawba Nuclear Stations inaccordance with the proposed generic changes to the Technical Specifications does not involvea significant hazards consideration. Duke Energy's conclusion is based on its evaluation, inaccordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c) asdiscussed below:7 ATTACHMENT 11. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?Response: No.The proposed change allows 24 hours to restore an inoperable CRACWS train when both trainsare inoperable provided Control Room temperature is verified to be within the design limitsevery 4 hours. The equipment qualification temperature of Control Room equipment is notaffected. The CRACWS is not an initiator of any accident previously evaluated. As a result, theprobability of any accident previously evaluated is not increased.The consequences of an accident during the proposed 24 hour Completion Time are nodifferent than the consequences of an accident during the existing 1 hour Completion Timeprovided in LCO 3.0.3 to prepare for a shutdown. The proposed TS changes do not increase orchange the current Control Room temperature limit. As a result, the consequences of anyaccident previously evaluated are not significantly increased.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?Response: No.No new or different accidents result from utilizing the proposed change. The TS changes do notinvolve a physical alteration of the plant or a change in the methods governing normal plantoperation. In addition, the changes do not impose any new or different requirements. Should thenew Actions not be met, the existing and proposed Actions require a plant shutdown. Thechanges do not alter assumptions made in the safety analysis. The proposed changes areconsistent with the safety analysis assumptions.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: No.The proposed change provides a limited period of time to restore an inoperable CRACWS traininstead of requiring an immediate plant shutdown. A plant shutdown is a transient, which maybe avoided by providing a limited time to make repairs. In addition, the Control RoomtemPerature must be maintained less than a limit set to_ ensure habitability of the Control Roomand the operability of-the equipment cooled by the CRACWS. The potential to avoid a planttransient, in conjunction with maintaining the Control Room temperature and the low probabilityof an event occurring during this time period, offset any risk associated with the limitedCompletion Time.Therefore, the proposed change does not involve a significant reduction in a margin of safety.8 ATTACHMENT 1Based on the above, Duke Energy concludes that the proposed change presents no significanthazards consideration under the standards set forth in 10 CER 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.4.4 ConclusionIn conclusion, based on the considerations discussed above, (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission's regulations,and (3) the approval of the proposed change will not be inimical to the common defense andsecurity or to the health and safety of the public. | |||
==5.0 ENVIRONMENTAL CONSIDERATION== | |||
SA review has determined that the proposed change would change a requirement with respect toinstallation or use of a facility component located within the restricted area, as defined in 10CER 20, or would change an inspection or surveillance requirement. However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant change in thetypes or significant increase in the amounts of any effluents that may be released offsite, or (iii)a significant increase in individual or cumulative occupational radiation exposure. Accordingly,the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR51 .22(c)(g).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmentalassessment need be prepared in connection with the proposed change.9 ATTACHMENT | |||
==16.0 REFERENCES== | |||
: 1) TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, datedMarch 26, 2007.2) NRC Letter, Summary of April 9, 2014, Public Teleconference Regarding PotentialSubmission of a License Amendment Request to Implement TSTF-477 for Control Room AirConditioning subsystems, dated April 21, 2014, ADAMS Accession No.ML14101A243.3) TSTF-553, Revision 0, Add Action for Two Inoperable CREA TCS Trains, transmitted forNRC review on October 31, 2015.4) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Units 1and 2, Docket Number 50-369 and 50-370 Notice of Enforcement Discretion RequestTechnical Specification (TS) 3. 7.10, Control Room Area Chilled water System, datedJanuary 14, 2010.5) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Unit 250-370 Notice of Enforcement Discretion Request Technical Specification 3. 7.10, ControlRoom Area Chilled water System (CRACWS), dated October 12, 2005.6) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke Energy) Catawba Nuclear Station,Units I and 2, Docket Number 50-4 13 and 50-4 14 Notice of Enforcement Discretion (NOED)Request Technical Specification (TS) 3. 7.11, "Control Room Area Chilled water System(CRACWS)" TS Limiting condition for Operation (LCO) 3.0.3 dated December 19, 2011.7) PSEG Letter, Hope Creek Generating Station, Facility Operating License No. NPF-57 NRCDocket No. 50-354 Application for Technical Specification Change TSF-4 77, Revision 3,Add Action for Two Inoperable Control Room AC Subsystems to the TechnicalSpecifications Using Consolidated Line Item Improvement Process, dated February 28,2011.8) Southern Nuclear Letter, Edwin I. Hatch Nuclear Plant Application for TechnicalSpecification Change to Revise Action Statements for Inoperable Control Room Airconditioning Subsystems, dated January 16, 2014.10 ATTACHMENT 2AMNS MARKED UP TECH SPEC PAGES CRACWS3.7.103.7 PLANT SYSTEMS3.7.10 Control Room Area Chilled Water System (CRACWS)LCO 3.7.10APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of irradiated fuel assemblies,During CORE ALTERATIONS.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.CAB_,. Required Action and ,B.1 Be in MODE 3. 6 hoursassociated CompletionTime of Condition A not ANDmet in MODE1, 2, Cor.ior 1.2 Be in MODE 5. 36 hoursDRequired Action and ¢.1 Place OPERABLE Immediatelyassociated Completion CRACWS train inTime of Condition A not operation.met in MODE 5 or 6, orduring movement of ORirradiated fuel Dassemblies, or during p.2.1 Suspend CORE ImmediatelyCORE ALTERATIONS. ALTERATIONS.ANDDZ;.2.2 Suspend movement of Immediatelyirradiated fuel assemblies.INSERT 1 New Condition B(continued)McGuire Units 1 and 23.7.10-1Mc~ure nitsI ad 2 .7.0-1Amendment No. 1-84/1t6e CRACWS3.7.10ACTIONS (continued)CONDITION [REQUIRED ACTION COMPLETION TIMEin MODE 5or 6, or duringmovement of irradiatedfuel assemblies, orduring COREALTERATIONS.Efr.1ANDE012Suspend COREALTERATIONS.Suspend movement ofirradiated fuel assemblies.ImmediatelyImmediatelyE. C"RA.\AI trains E.1 E nter !C 3.0.3 ~ vt41efihteySURVEILLANCE REQUIREMENTS _______SURVEILLANCE FREQUENCYSR 3.7.10.1 Verify the control room temperature is < 900F. In accordance withthe SurveillanceFrequency ControlProgramINSERTRequired Action and associated Completion Timeof Condition B not metIIMcGuire Units 1 and 23.7.10-2Mc~ure nits1 ad 2 .7.0-2Amendment No. | |||
INSERT 1 TS 3.7.10 New Condition BCONDITION f REQUIRED ACTION jCOMPLETION TIMENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature _< 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hours24 hoursU U ATTACHMENT 2BCNS MARKED UP TECH SPEC PAGES CRACWS3.7.113.7 PLANT SYSTEMS3.7.11 Control Room Area Chilled Water System (CRACWS)LCO 3.7.11APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of recently irradiated fuel assemblies.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.C.-BC. Required Action and B.1 Be in MODE 3. 6 hoursassociated CompletionTime of Condition A bnot ANDmet in MODE 1, 2, 3,\ C 36 hoursor 4. )--- .2 Be in MODE 5.-e;D. Required Action and Place OPERABLE Immediatelyassociated Completion CRACWS train in operation.Time of Condition A notmet in MODE 5or 6,or ORduring movement ofrecently irradiated fuel Suspend movement ofassemblies, recently irradiated fuel Immediatelyassemblies.(continued)INSERT 1 New Condition BCatawba Units 1 and 23.7.11-1Cataba nits1 ad 2 .7.1-1Amendment Nos. 1-98/1-9 CRACWS3.7.11CONDITION REQUIRED ACTION COMPLETION TIME-DE. Two CRA.CWS train-sT... in TnMODE 5or 6, or duringmovement of recentlyirradiated fuelassemblies.DE.1 Suspend movement ofrecently irradiated fuelassemblies.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.7.11.1 Verify the control room temperature is < 90°F. In accordance withthe SurveillanceFrequency ControlProgramNSERT1/4tNSERTRequired Action and associatedCompletion Time of Condition Bmetnotl IICatawba Units 1 and 23.7.11-2Cataba nits1 ad 2 .7.1-2Amendment Nos. 263, 2-59 INSERT 1 TS 3.7.11 New Condition BCONDITION REQUIRED ACTION [COMPLETION TIMEB. --- NOTENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature < 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hours24 hoursa a ATTACHMENT 3AMNS MARKED UP TECH SPEC BASES PAGES B 3.7 PLANT SYSTEMSB 3.7.10 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room followingisolation of the control room.The CRACWS consists of two independent and redundant trains thatprovide cooling of recirculated control room air. Each train consists ofcooling coils, instrumentation, and controls to provide for control roomtemperature control. The CRACWS is a subsystem providing airtemperature control for the control room.The CRACWS is an emergency system, parts of which may also operateduring normal unit operations. A single train will provide the requiredtemperature control to maintain the control room at approximately 75°F.The CRACWS operation in maintaining the control room temperature isdiscussed in the UFSAR, Section 6.4 (Ref. 1).There are components that are part of the CRACWS but do not affect theCRAVS. These components are associated with the Control Room AreaAir Handling units, the Switchgear Air Handling units. LCO 3.7.10 doesnot apply if a CRAVS component does not directly impact the CRACWS.APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 75°F and 90°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.The CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).McGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-1Revision No. "I"1-5 CRACWSB 3.7.10BASESLCO Two independent and redundant trains of the CRACWS arerequired to be OPERABLE to ensure that at least one is available,assuming a single failure disabling the other train. Total systemfailure could result in the equipment operating temperatureexceeding limits in the event of an accident.The CRACWS is considered to be OPERABLE when theindividual components necessary to maintain the control roomtemperature are OPERABLE in both trains. These componentsinclude the cooling coils and associated temperature controlinstrumentation. In addition, the CRACWS must be operable tothe extent that air circulation can be maintained.The CRACWS is shared between the two units. The system mustbe OPERABLE for each unit when that unit is in the MODE ofApplicability. Additionally, both normal and emergency powermust also be OPERABLE because the system is shared. If aCRACWS component becomes inoperable, or normal oremergency power to a CRACWS component becomes inoperable,then the Required Actions of this LCO must be enteredindependently for each unit that is in the MODE of applicability ofthe LCO.APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of irradiatedfuel assemblies and during CORE ALTERATIONS, the CRACWSmust be OPERABLE to ensure that the control room temperaturewill not exceed equipment operational requirements followingisolation of the control room.ACTIONS A.1With one CRACWS train inoperable, action must be taken torestore OPERABLE status within 30 days. In this Condition, theremaining OPERABLE CRACWS train is adequate to maintain thecontrol room temperature within limits. However, the overallreliability is reduced because a single failure in the OPERABLECRACWS train could result in loss of CRACWS function. The30 day Completion Time is based on the low probability of anevent requiring control room isolation, the consideration that theremaining train can provide the required protection, and thatalternate safety or nonsafety related cooling means are available.(ew paragraph) anB2Im mMcGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-2Revision No. "I-I-5 INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored toensure that temperature is being maintained low enough that equipment in the control room isnot adversely affected and remains habitable. Mitigating actions, such as opening cabinetdoors, use of fans, or opening control room doors or ventilation paths, may be used to maintaincontrol room temperature. With the control room temperature being maintained within thetemperature limit, 24 hours is allowed to restore a CRACWS train to OPERABLE status. ThisCompletion Time is reasonable considering that the control room temperature is beingmaintained within limits and the low probability of an event occurring requiring control roomisolation.The condition is modified by a Note stating it is not applicable when the second CRACWS trainis intentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time. | |||
CRACWSB 3.7.10BASESACTIONS (continued) assocated t ra~nIn MODE 1, 2, 3, or 4, if the inoperable- R:ACWS trafti cannot berestored to OPERABLE status within the Time, the unit must be placed in a MODE that minimizes the risk.To achieve this status, the unit must be placed in at least MODE 3within 6 hours, and in MODE 5 within 36 hours. The allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.D D 0[A. 1,X32.1. and [.2.2In MODE 5 or 6, or during movement of irradiated fuel, or duringCORE ALTERATIONS, if the inoperable CRACWS train cannot berestored to OPERABLE status within the required CompletionTime, the OPERABLE CRACWS train must be placed in operationimmediately. This action ensures that the remaining train isOPERABLE, that no failures preventing automatic actuation willoccur, and that active failures will be readily detected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity thatmight require isolation of the control room. This places the unit ina condition that the movement of fuel if Required Actions B.1 or B.2 cannotE be met within the required Completion1 and.2 /TimesIn MODE 5 or 6, or during movement f. irradiated fuel assemblies,or during CORE ALTERATIONS, hiprbe, action must be taken immediately to suspend activities Ithat could result in a release of radioactivity that might requireisolation of the control room. This places the unit in a conditionthat minimizes risk. This does not preclude the movement of fuelto a safe position.If b.,cth ;r,,, ,noop,.rabohl in MODEN: "1. 2. 3. or I the"cotinrrl roomir a y n,,o.. t .,bo. c,, ap...blc ofI pz-^ r- In^g^....... .. .... .. .t".. ,i.,,,,, itSIrIIIdtjlltd lUIiL~, i. I. I 3I.0.3.. III..u l.iat ,b 1 lc.,tcz,McGuire Units 1 and 2B37103RvsoN.1-5B 3.7.10-3Revision No. ffff5 CRACWSB 3.7.10BASESSURVEILLANCE SR 3.7.10.1REQUIREMENTSThis SR verifies that the heat removal capability of the system issufficient to maintain the temperature in the control room at orbelow 90°F. The Surveillance Frequency is based on operatingexperience, equipment reliability, and plant risk and is controlledunder the Surveillance Frequency Control Program.REFERENCES1. UFSAR, Section 6.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).McGuire Units 1 and 2B37104RvsoN.1--B 3.7.10-4Revision No. 4-'1-5 ATTACHMENT 3BONS MARKED UP TECH SPEC BASES PAGES CRACWSB 3.7.11B 3.7 PLANT SYSTEMSB 3.7.11 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room and thecontrol room area.The CRACWS consists of two independent and redundant trains thatprovide cooling to the control room and control room area. Each trainconsists of a chiller package, chilled water pump, and air handling unitswith cooling coils. Chilled water is passed through the cooling coils of theair handling unit to cool the air. Electric duct heaters are then used tocontrol the supply air temperature.The CRACWS provides both normal and emergency cooling to thecontrol room and control room area. A single train will provide therequired temperature control to maintain the control room approximately74°F. The CRACWS operation in maintaining the control roomtemperature is discussed in the UFSAR, Section 9.4 (Ref. 1).APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 72°F and 85°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.Th'e CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).Catawba Units 1 and 2 B 3.7.11-1 Revision No. | |||
CRACWSB 3.7.11BASESLCOTwo independent and redundant trains of the CRACWS are required tobe OPERABLE to ensure that at least one is available, assuming a singlefailure disabling the other train. Total system failure could result in theequipment operating temperature exceeding limits in the event of anaccident.The CRACWS is considered to be OPERABLE when the individualcomponents necessary to maintain the control room temperature areOPERABLE in both trains. These components include a chiller package,chilled water pump, and air handling unit. In addition, the CRACWS mustbe OPERABLE to the extent that air circulation can be maintained.The CRACWS is shared between the two units. The system must beOPERABLE for each unit when that unit is in the MODE of Applicability.Additionally, both normal and emergency power must also beOPERABLE because the system is shared. A shutdown unit supplying itsassociated emergency power source (1 EMXG/2EMXH) cannot becredited for OPERABILITY of components supporting the operating unit.If a CRACWS component becomes inoperable, or normal or emergencypower to a CRACWS component becomes inoperable, then the RequiredActions of this LCO must be entered independently for each unit that is inthe MODE of applicability of the LCO.APPLICABILITYIn MODES 1, 2, 3, 4, 5, and 6, and during movement of recentlyirradiated fuel assemblies, the CRACWS must be OPERABLE to ensurethat the control room temperature will not exceed equipment operationalrequirements following a design basis accident. The CRACWS is onlyrequired to be OPERABLE during fuel handling involving handlingrecently irradiated fuel (i.e., fuel that has occupied part of a critical reactorcore within the previous 72 hours) due to radioactive decay.ACTIONSA.__1With one CRACWS train inoperable, action must be taken to restoreOPERABLE status within 30 days. In this Condition, the remainingOPERABLE CRACWS train is adequate to maintain the control roomtemperature within limits. However, the overall reliability is reducedbecause a single failure in the OPERABLE CRACWS train could result inloss of CRACWS function. The 30 day Completion Time is based on thelow probability of an event, the consideration that the remaining train canprovide the required protection, and that alternate safety or nonsafetyrelated cooling means are available.INSERT 2 B.1 and B.2(new paragraph)ICatawba Units 1 and 2B371-2RvsoNOB 3.7.11-2Revision INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored to ensurethat temperature is being maintained low enough that equipment in the control room is notadversely affected and remains habitable. Mitigating actions, such as opening cabinet doors,use of fans, or opening control room doors or ventilation paths, may be used to maintain controlroom temperature. With the control room temperature being maintained within the temperaturelimit, 24 hours is allowed to restore a CRACWS train to OPERABLE status. This CompletionTime is reasonable considering that the control room temperature is being maintained withinlimits and the low probability of an event occurring requiring control room isolation.The condition is modified by a Note stating it is not applicable when the second CRACWS train isintentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time. | |||
CRACWSB 3.7.11BASESACTIONS (continueIIi an C 1asscae Itrain s)/In MODE 1, 2, 3, or 4, if the inoperab .,<RACWS tr cannot berestored to OPERABLE status within the Completion Time, theunit must be placed in a MODE that minimizes the risk. To achieve thisstatus, the unit must be placed in at least MODE 3 within 6 hours, and inMODE 5 within 36 hours. The allowed Completion Times are reasonable,based on operating experience, to reach the required unit conditions fromfull power conditions in an orderly manner and without challenging unitsystems..l and D.In MODE 5 or 6, or during movement of recently irradiated fuel, if theinoperable CRACWS train cannot be restored to OPERABLE statuswithin the required Completion Time, the OPERABLE CRACWS trainmust be placed in operation immediately. This action ensures that theremaining train is OPERABLE, and that active failures will be readilydetected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity. This placesthe unit in a condition that minimizes accident risk. This does notpreclude th-' ma~,,-m-,rt i'f f, ,--I ta =- nn~itiAnI if Required Actions B.1 or B.2 cannot bemet within the required Completion TimesI* IIn MODE 5or 6,or urn moeeto eetyirradiated fuelassemblies, wihtf RCSt'lq ,o~sle, action must be takenimmediately to suspend activities that could result in a release ofradioactivity. This places the unit in a condition that minimizes risk. Thisdoes not preclude the movement of fuel to a safe position.It hnth CRAPW~ trnir.~ ~IIIUperabIlU MODIIEJ~l 1,2, 3, Ul 4', tllr:: rwII Igr..om........ma..not c ....bl cf p6-o-~F tg ,n ftllded ['urLiuunI.Therefore, LCOJ 3.U.3 must be entered Immediately.Catawba Units I and 2B3.113evsoNoB 3.7.11-3Revision CRACWSB 3.7.11BASESSURVEILLANCE SR 3.7.11.1REQUI REMENTSThis SR verifies that the heat removal capability of the system is sufficientto maintain the temperature in the control room at or below 90°F. TheSurveillance Frequency is based on operating experience, equipmentreliability, and plant risk and is controlled under the SurveillanceFrequency Control Program.REFERENCES1. UFSAR, Section 9.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).3. 10 CFR 50.67, Accident source term.4. Regulatory Guide 1.183, Revision 0.Catawba Units 1 and 2 B371- eiinNAB 3.7.11-4Revision No./,3/}} | |||
Revision as of 23:47, 28 May 2018
| ML16029A077 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 01/07/2016 |
| From: | Capps S D Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| MNS-16-002 | |
| Download: ML16029A077 (33) | |
Text
S DUKE Steven D. CappsVice President~ENERG..Y McGuire Nuclear StationDuke EnergyMG01VP I 12700 Hagers Ferry RoadHuntersville, NC 280780: 980.875.4805Seril No MNS16-02 1' 980.875.4809Seril N. MN-16002Steven.Capps@duke-energy.comJanuary 7, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionWashington, D.C. 20555ATTENTION: Document Control Desk
Subject:
Duke Energy Carolinas, LLC (Duke Energy)":McGuire Nuclear Station (MNS), Units 1 and 2,Docket Numbers 50-369 and 50-370, Renewed Facility Operating LicensesNPF-9 and NPF-17Catawba Nuclear Station (CNS), Units 1 and 2Docket Numbers 50-413 and 50-41 4, Renewed Facility Operating LicensesNPF-35 and NPF-52Proposed Technical Specifications (TS) Amendment TS 3.7.10, "Control RoomArea Chilled Water System" (MNS), and TS 3.7.11, "Control Room Area ChilledWater System" (CNS)Pursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the MNS and CNSFacility Operating Licenses and subject Technical Specifications (TS). This proposed licenseamendment request (LAR) modifies the TS by adding a new Action for both trains of ControlRoom Area Chilled Water Systems (CRACWS) inoperable. The new Action allows a finite timeto restore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at or below 90°F.The proposed LAR is modeled after TSTF-477; Rev. 3, "Add Action for Two Inoperable ControlRoom AC Subsystems." This TSTF is specific to the BWR NUREGs 1433 and 1434. DukeEnergy has determined this TSTF is readily adaptable to a NUREG-1 431 Standard TS for aWestinghouse plant. This topic was discussed with the NRC Staff on April 9, 2014. Theproposed amendment is not being submitted under the Consolidated Line Item ImprovementProcess (CLIIP) process.Attachment 1 provides Duke Energy's evaluation of the amendment, which contains adescription of the proposed changes, the technical evaluation, the regulatory analysis, thedetermination that this LAR contains No Significant Hazards Considerations, the basis for thecategorical exclusion from performing an Environmental Assessment/Impact Statement, andprecedent for the LAR.Attachment 2A provides the existing MNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.www.duke-energy.com U.S. Nuclear Regulatory Commission-MNS-1 6-002Page 2Attachment 2B provides the existing CNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.Attachment 3A provides a portion of the existing MNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the MNS Bases Control Program (TS 5.5.14).Attachment 3B provides a portion of the existing CNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the CNS Bases Control Program (TS 5.5.14).This proposed LAR has been reviewed and approved by the MNS and CNS Plant OperationsReview Committees in accordance with the requirements of the Duke Energy Quality AssuranceProgram.In accordance with 10 CFR 50.91, Duke Energy is notifying the applicable state officials of thisapplication for license amendment by transmitting a copy of this letter and its attachments to thedesignated officials.This submittal will not impact the MNS or CNS Updated Final Safety Analysis Reports(UFSARs).Duke Energy requests approval of this submittal within one calendar year of the submittal dateand an implementation period of 60 days from the date of amendment issuance.There are no regulatory commitments contained in this amendment.Please direct any questions you may have in this matter to Lee A. Hentz at (980) 875-41 87.I declare under penalty of perjury that the foregoing is true and correct. Executed on January 7,2016.Sincerely,Steven D. CappsAttachments U.S. Nuclear Regulatory CommissionMNS-1 6-002Page 3xc (with attachments):Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257G.A. Hutto, IllSenior Resident Inspector (Catawba)U.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG. E. Miller (addressee only)NRC Project Manager (Catawba and McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A11555 Rockville PikeRockville, MD 20852-2738S.E. JenkinsManagerRadioactive and Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IllSection ChiefDivision of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 ATTACHMENT 1EVALUATION OF PROPOSED AMENDMENT1.0 SUMMARY DESCRIPTION2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
3.1 TS System Descriptions3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse Plant3.3 Operational Burden3.4 System Reliability Improvements3.5 Control Room Equipment Temperature Limit Validation3.6 Application of Proposed Change
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria4.2 Precedents4.3 No Significant Hazards Consideration4.4 Conclusion
5.0 ENVIRONMENTAL CONSIDERATION
S
6.0 REFERENCES
I ATTACHMENT 11.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the McGuire NuclearStation (MNS) and Catawba Nuclear Station (CNS) Facility Operating Licenses and subjectTechnical Specifications (TS). This proposed license amendment request (LAR) modifies MNSTS 3.7.10, "Control Room Area Chilled Water Systems," and corresponding CNS TS 3.7.11 byadding a new Action for both trains of Control Room Area Chilled Water Systems (CRACWS)inoperable. The new Action allows a finite time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, to restore one train to Operablestatus and requires periodic verification that Control Room temperature is maintained at orbelow 900°F.2.0 DETAILED DESCRIPTIONAs discussed in a meeting with the NRC staff on April 9, 2014, the proposed LAR is modeledafter TSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems." TSTF-477 is applicable only to BWR (General Electric) NUREGs 1433 and 1434, and adoption of thisTSTF is available to BWRs via the Consolidated Line Item Improvement Process (CLIIP). Sincethe CNS and MNS TS are based on the Westinghouse NUREG-1431 Standard TSs, this DukeEnergy LAR is not proposed to be processed via the CLIIP process. TSTF-477 adds aCondition to restore one Control Room AC subsystem within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the event two ControlRoom AC subsystems become inoperable.Since the Duke Energy meeting with the NRC staff, the Technical Specification Task Force hassubmitted a Traveler, TSTF-553, for NRC review. TSTF-553 is similar to TSTF-477 but isapplicable to Westinghouse (NUREG-1 431) and Babcock & Wilcox (NUREG-1 430) plants andprovides a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for both plant types in the event two Control Room ACsubsystems become inoperable. TSTF-553 also includes a note that precludes use of the 24hour allowance when the second train is intentionally made inoperable. Although TSTF-553 hasnot yet been reviewed or approved by the NRC, the LAR proposed by Duke Energy adopts themore conservative 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time and the additional restriction regarding intentionalentry into the Condition.The proposed LAR revises MNS TS 3.7.10 and CNS TS 3.7.11 as follows:a. Add a new Action B. New Action B applies when two CRACWS trains are inoperable.Required Action B.1 requires verification once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> that Control Roomtemperature is less than or equal to 90°F. Required Action B.2 requires restoration ofone CRACWS train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.b. New Condition B is modified by a Note which states, "Not applicable when secondCRACWS train intentionally made inoperable." If the second CRACWS train isintentionally made inoperable, there is no applicable Condition~and immediate entry intoLCO 3.0.3 is required.c. Existing Action B, now renamed Action C, which applies when the Required Action andassociated Completion Time of Condition A (one CRACWS train inoperable) is not metin MODES 1, 2, 3,or 4, is revised to also be applicable when the Required Actions andassociated Completion Times of new Condition B~are not met. Renumbered Condition Crequires being in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.2 ATTACHMENT 1d. Existing Action C, now renamed Action D, remains unchanged.e. For MNS, existing Action 0, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of irradiated fuel assemblies or during corealterations, is revised to be applicable when the Required Actions and associatedCompletion Times of new Condition B are not met.f. For CNS, existing Action D, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of recently irradiated fuel assemblies, is revisedto be applicable when the Required Actions and associated Completion Times of newCondition B are not met.g. Existing Action E, which applied when two CRACWS trains are inoperable in MODE 1,2, 3, or 4, and requires entry into LCO 3.0.3, is no longer needed and deleted (redundantto revised Condition C.).The marked-up TS pages showing the proposed changes above are provided in Attachments2A and 2B.The corresponding TS Bases pages showing the proposed changes are provided inAttachments 3A and 3B. The TS Bases change will be processed after LAR approval under theMNS and CNS Bases Control Program (TS 5.5.14). They are provided in this LAR forinformation only.
3.0 TECHNICAL EVALUATION
3.1 TS System DescriptionsThe CRACWS provides air temperature control for the Control Room, Control Room Area, andSwitchgear Rooms. The Control Room Area (CRA) consists predominately of the Vital Batteryand Equipment Rooms, Motor Control Center (MCC) rooms, and Cable Rooms. TheSwitchgear Rooms contain the essential switchgear. The CRA and Switchgear Rooms are notpart of the Control Room Envelope and not governed by the CRACWS Technical Specifications.The CRACWS consists of two independent and redundant trains. Each train consists of achiller package, chilled water pump, air handling units with cooling coils, instrumentation, andcontrols.The CRACWS is an emergency system, which also operates during normal unit operations. Asingle train will provide the required temperature control to maintain the Control Room atapproximately 75°F for MNS and 74°F for CNS, respectively. The design basis of the CRACWSis to maintain the Control Room temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety related trains. During emergencyoperation, the CRACWS maintains the Control Room temperature between 75°F and 90°F forMNS and between 72°F and 85°F for CNS, respectively. A single active failure of a componentof the CRACWS, with a loss of offsite power, does not impair the ability of the system to performits design function. Redundant detectors and controls are provided for Control Roomtemperature control. The CRACWS is designed in accordance with Seismic Category I3 ATTACHMENT 1requirements. The CRACWS is capable of removing sensible and latent heat loads from theControl Room, which include consideration of equipment heat loads and personnel occupancyrequirements, to ensure equipment operability.Two independent and redundant trains of the CRACWS are required to be operable to ensurethat at least one is available, assuming a single failure disabling the other train. The CRACWSis shared between the two units. The system must be operable for each unit when that unit is inthe Mode of Applicability.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) are governed by separateTechnical Specifications; MNS TS 3.7.9 and CNS TS 3.7.10. The CRAVS is an emergencyredundant system that provides a protected habitable environment for the Control RoomEnvelope from which occupants can control the Units following an uncontrolled release ofradioactivity, hazardous chemicals, or smoke. The CRAVS does not provide a protectedhabitable environment for the Control Room Area or Switchgear Rooms. The inoperability ofCRACWS does not impact the operability of CRAVS.The MNS CRACWS and CRAVS are described in MNS UFSAR Section 6.4. The CNSCRACWS and CRAVS are described in CNS UFSAR Section 9.4.3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse PlantTSTF-477 Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems," was NRCapproved for adoption in 2007. This BWR (GE) specific TSTF allows for two trains of ControlRoom cooling to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as long as the Control Room areatemperature can be maintained (and monitored) within a pre-determined limit, commonly 90°F.The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was deemed reasonable considering that Control Roomtemperature is being maintained within limits and the low probability of an event occurring thatwould require Control Room area isolation. Alternate methods of maintaining control roomtemperature, such as non-safety grade air conditioning systems or fans, can also be used tomaintain control room temperature. As previously stated in Section 2.0, Duke Energy will adoptthe more conservative Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> proposed by TSTF-553.TSTF-477 Rev. 3 is deterministically justified and relies on safety related cabinet equipmentqualification (EQ) temperature limits and Control Room heat-up assumptions. For the GEplants, a GE Topical Report supports the EQ justification. Duke Energy has performed sitespecific confirmations that equipment qualification for Control Room safety relatedinstrumentation and devices remains valid up to 90°F. Note MNS TS 3.7.10 and CNS TS 3.7.11already contain a Surveillance Requirement (SR) that confirms the Control Room is 90°F or lessevery 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.AS precedent; TSTF-477 Rev. 3 references other GE Technical Specifications that currentlyprovide an Action with a finite time to restore one train to operable status when both trains areinoperable. MNS and CNS have similar Technical Specifications:1. MNS and CNS TSs 3.3.3, "Post Accident Monitoring" (7 days).2. MNS TS 3.7.11 and CNS TS 3.7.12, "Auxiliary Building Filtered Ventilation ExhaustSystem" (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).4 ATTACHMENT 1Duke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, Request for AdditionalInformation (RAIs), and the NRC Safety Evaluations (SE) that adopted TSTF-477 Rev. 3.Based on that review, Duke Energy did not identify an issue that could not be addressed at ourplants and did not identify any GE/BWR specific requirements or conditions.3.3 Operational BurdenBoth MNS and CNS have experienced the inoperability of both trains of Control Room cooling.These occurred in 2005 and 2010 at MNS and in 2011 at CNS. With Control Room coolingbeing a shared system, these three events led to the initiation of a two unit shutdown.For the MNS events, one Control Room cooling train was functional but not operable. Notice ofEnforcement Discretion (NOEDs) were submitted and granted for MNS on both occasions toremain at power operation until one cooling train was restored to Operable status.For the CNS event, the "A" cooling train was in planned maintenance when the "B" cooling traintripped due to a chiller controls system micro-processor failure. Both units initiated a shutdownand proceeded to Mode 3 while a NOED was processed to not proceed to Mode 4. The "A"cooling train was restored shortly thereafter.As part of the 2010 NRC approved NOED, MNS committed to submit an LAR to addressoperability requirements of the Control Room cooling Technical Specification.3.4 System Reliability ImprovementsThe 2005 MNS event was caused by a degraded oil pressure switch, which prohibited the "A"cooling train chiller compressor from starting. At the time, the redundant cooling train wasfunctional but administratively inoperable due to support system alignments for refueling outageEngineered Safety Features (ESF) testing. The degraded oil pressure switch was replaced, andthen in 2007, the original chiller controls were replaced with digital controls, which improved thereliability of the oil pressure switch function.For the 2010 MNS event, the loss of the operating train of Control Room cooling was caused byhigh vibration of the hot gas bypass line (HGBP), which led to a breach of the coolant line. Atthe time, the redundant cooling train was in a planned maintenance evolution and temporarilyunavailable.Since 2010, both MNS Control Room cooling trains have been upgraded with new HGBP pipingto reduce vibration interactions, vibration isolators have been installed, corroded and erodedservice water piping has been replaced, small bore piping and tubing has been replaced, andpiping analysis models were developed to identify potential thermal stresses. In addition, thecondenser normal operating head pressure was reduced, which further reduced HGBP pipingvibration.After the 2011 CNS chiller micro-processor failure, significant efforts were made to determinethe cause of the failure and to enable the chiller to be rapidly restarted. The failed micro-processor was sent to the original qualifier of the controls who, in concert with the originalmanufacturer of the controls, investigated the cause of the failure. The manufacturer has manyyears of in-service experience with this type of micro-processor and has experienced very few5 ATTACHMENT 1failures. The failed micro-processor was subject to multiple tests, but the problem did not re-occur.Both companies recommended that failures of this type be addressed by removing andreapplying power to the micro-processor, similar to how many computer related problems areaddressed. This allows rapid re-start of the chiller. CNS has incorporated such actions into thecurrent operating procedures. In addition, CNS maintenance procedures have been enhancedto provide direction on how to replace a micro-processor which can now be done very quickly.Since MNS utilizes the same chiller controls, similar operating and maintenance procedureenhancements were incorporated.3.5 Control Room Equipment Temperature Limit ValidationMNS TS 3.7.10 and CNS TS 3.7.11 currently contain an SR that confirms the Control Room is90°F or less every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As such, the current licensed design temperature of the ControlRoom equipment remains unchanged by the proposed TS changes.Duke Energy has also concluded that the 90°F limit in the new proposed TS Action B remainsunchanged based on a review of design specifications for the respective Control Room safetyrelated instruments and devices. Design specifications for protective equipment in the ControlRoom specify no loss of protective function over the temperature range of 40°F to 90°F and ahumidity range of 15 to 95% relative humidity.Therefore, monitoring of bulk Control Room temperature every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure that ambienttemperature is less than or equal to 90°F would verify that the Control Room temperature is ator below the design limit.3.6 Application of Proposed ChangeThe most likely application of proposed Condition B and the associated Required Actions iswhen both CRACWS trains are inoperable but one train is functional with the ability to cool theControl Room. In this case, the Control Room temperature would remain constant at a normalvalue, and the 90°F limit is not challenged. One CRACWS would need to be restored toOperable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.In the event both CRACWS trains are inoperable and non-functional, MNS and CNS havedeveloped '"Abnormal Procedures" (AP) to mitigate rising temperatures in the Control Room andtake actions to shutdown the affected Units if temperature rises above 90°F, or there areindications of instrumentation malfunctions that have safety significance.4.0. REGULATORY EVALUATION4.1 Applicable Regulatory Requirements/CriteriaGeneral Design Criterion (GDC) 19, "Control Room" states in part:A Control Room shall be provided from which actions can be taken to operate thenuclear power unit safely under normal conditions and to maintain it in a safe condition6 ATTACHMENT 1under accident conditions, including loss-of-coolant accidents. Adequate radiationprotection shall be provided to permit access and occupancy of the control room underaccident conditions without personnel receiving radiation exposures in excess of 5 remwhole body, or its equivalent to any part of the body, for the duration of the accident.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) provide compliance withGDC 19. The CRAVS is an emergency redundant system that provides a protected habitableenvironment for the Control Room Envelope from which occupants can control the Unitsfollowing an uncontrolled release of radioactivity, hazardous chemicals, or smoke. Theproposed changes to the CRACWS TS do not impact the operability of CRAVS.In addition, the operability requirements of the CRACWS have not changed. The regulatoryrequirements do not specifically address Completion Times with inoperable systems. As aresult, the regulatory requirements and criteria are not affected by the proposed change.4.2 PrecedentsDuke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, PAls, and NRC SEsthat recently adopted TSTF-477 Rev. 3. Based on that review, Duke Energy did not identify anissue that could not be addressed at our plants and did not identify any GE/BWR specificrequirements or conditions.*PSEG Hope Creek Generating Station, LAR dated February 28, 2011 (ADAMSAccession No. ML1 10590636); as supplemented by letters dated August 29, 2011(ML1 12420124), December 16, 2011 (ML1 13530205), and January 26, 2012(ML12026A458); NRC SE dated February 8, 2012 (ML120180078).* SNC Edwin I. Hatch Nuclear Plant, LAR dated January 16, 2014, (ADAMS AccessionNo. ML14016A202); as supplemented by letter dated May 2, 2014 (ML14122A339); andNRC SE dated December 10, 2014 (ML14279A261).4.3 No Significant Hazards ConsiderationPursuant to 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes a licenseamendment request (LAR) for the Renewed Facility Operating License (FOL) and TechnicalSpecifications (TS) for McGuire (MNS) and Catawba (CNS) Nuclear Stations, Units I and 2.This proposed LAR modifies MNS TS 3.7.10, "Control Room Area Chilled Water Systems," andcorresponding CNS TS 3.7.11 by adding a new Action for both trains of Control Room AreaChilled Water Systems (CRACWS) inoperable. The new Action allows a finite time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, torestore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at-or below 90°F degrees.- The-proposed LAR is modeled afterTSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems."Duke Energy has concluded that operation of the McGuire and Catawba Nuclear Stations inaccordance with the proposed generic changes to the Technical Specifications does not involvea significant hazards consideration. Duke Energy's conclusion is based on its evaluation, inaccordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c) asdiscussed below:7 ATTACHMENT 11. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?Response: No.The proposed change allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable CRACWS train when both trainsare inoperable provided Control Room temperature is verified to be within the design limitsevery 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The equipment qualification temperature of Control Room equipment is notaffected. The CRACWS is not an initiator of any accident previously evaluated. As a result, theprobability of any accident previously evaluated is not increased.The consequences of an accident during the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time are nodifferent than the consequences of an accident during the existing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Timeprovided in LCO 3.0.3 to prepare for a shutdown. The proposed TS changes do not increase orchange the current Control Room temperature limit. As a result, the consequences of anyaccident previously evaluated are not significantly increased.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?Response: No.No new or different accidents result from utilizing the proposed change. The TS changes do notinvolve a physical alteration of the plant or a change in the methods governing normal plantoperation. In addition, the changes do not impose any new or different requirements. Should thenew Actions not be met, the existing and proposed Actions require a plant shutdown. Thechanges do not alter assumptions made in the safety analysis. The proposed changes areconsistent with the safety analysis assumptions.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: No.The proposed change provides a limited period of time to restore an inoperable CRACWS traininstead of requiring an immediate plant shutdown. A plant shutdown is a transient, which maybe avoided by providing a limited time to make repairs. In addition, the Control RoomtemPerature must be maintained less than a limit set to_ ensure habitability of the Control Roomand the operability of-the equipment cooled by the CRACWS. The potential to avoid a planttransient, in conjunction with maintaining the Control Room temperature and the low probabilityof an event occurring during this time period, offset any risk associated with the limitedCompletion Time.Therefore, the proposed change does not involve a significant reduction in a margin of safety.8 ATTACHMENT 1Based on the above, Duke Energy concludes that the proposed change presents no significanthazards consideration under the standards set forth in 10 CER 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.4.4 ConclusionIn conclusion, based on the considerations discussed above, (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission's regulations,and (3) the approval of the proposed change will not be inimical to the common defense andsecurity or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
SA review has determined that the proposed change would change a requirement with respect toinstallation or use of a facility component located within the restricted area, as defined in 10CER 20, or would change an inspection or surveillance requirement. However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant change in thetypes or significant increase in the amounts of any effluents that may be released offsite, or (iii)a significant increase in individual or cumulative occupational radiation exposure. Accordingly,the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR51 .22(c)(g).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmentalassessment need be prepared in connection with the proposed change.9 ATTACHMENT
16.0 REFERENCES
- 1) TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, datedMarch 26, 2007.2) NRC Letter, Summary of April 9, 2014, Public Teleconference Regarding PotentialSubmission of a License Amendment Request to Implement TSTF-477 for Control Room AirConditioning subsystems, dated April 21, 2014, ADAMS Accession No.ML14101A243.3) TSTF-553, Revision 0, Add Action for Two Inoperable CREA TCS Trains, transmitted forNRC review on October 31, 2015.4) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Units 1and 2, Docket Number 50-369 and 50-370 Notice of Enforcement Discretion RequestTechnical Specification (TS) 3. 7.10, Control Room Area Chilled water System, datedJanuary 14, 2010.5) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Unit 250-370 Notice of Enforcement Discretion Request Technical Specification 3. 7.10, ControlRoom Area Chilled water System (CRACWS), dated October 12, 2005.6) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke Energy) Catawba Nuclear Station,Units I and 2, Docket Number 50-4 13 and 50-4 14 Notice of Enforcement Discretion (NOED)Request Technical Specification (TS) 3. 7.11, "Control Room Area Chilled water System(CRACWS)" TS Limiting condition for Operation (LCO) 3.0.3 dated December 19, 2011.7) PSEG Letter, Hope Creek Generating Station, Facility Operating License No. NPF-57 NRCDocket No. 50-354 Application for Technical Specification Change TSF-4 77, Revision 3,Add Action for Two Inoperable Control Room AC Subsystems to the TechnicalSpecifications Using Consolidated Line Item Improvement Process, dated February 28,2011.8) Southern Nuclear Letter, Edwin I. Hatch Nuclear Plant Application for TechnicalSpecification Change to Revise Action Statements for Inoperable Control Room Airconditioning Subsystems, dated January 16, 2014.10 ATTACHMENT 2AMNS MARKED UP TECH SPEC PAGES CRACWS3.7.103.7 PLANT SYSTEMS3.7.10 Control Room Area Chilled Water System (CRACWS)LCO 3.7.10APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of irradiated fuel assemblies,During CORE ALTERATIONS.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.CAB_,. Required Action and ,B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A not ANDmet in MODE1, 2, Cor.ior 1.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sDRequired Action and ¢.1 Place OPERABLE Immediatelyassociated Completion CRACWS train inTime of Condition A not operation.met in MODE 5 or 6, orduring movement of ORirradiated fuel Dassemblies, or during p.2.1 Suspend CORE ImmediatelyCORE ALTERATIONS. ALTERATIONS.ANDDZ;.2.2 Suspend movement of Immediatelyirradiated fuel assemblies.INSERT 1 New Condition B(continued)McGuire Units 1 and 23.7.10-1Mc~ure nitsI ad 2 .7.0-1Amendment No. 1-84/1t6e CRACWS3.7.10ACTIONS (continued)CONDITION [REQUIRED ACTION COMPLETION TIMEin MODE 5or 6, or duringmovement of irradiatedfuel assemblies, orduring COREALTERATIONS.Efr.1ANDE012Suspend COREALTERATIONS.Suspend movement ofirradiated fuel assemblies.ImmediatelyImmediatelyE. C"RA.\AI trains E.1 E nter !C 3.0.3 ~ vt41efihteySURVEILLANCE REQUIREMENTS _______SURVEILLANCE FREQUENCYSR 3.7.10.1 Verify the control room temperature is < 900F. In accordance withthe SurveillanceFrequency ControlProgramINSERTRequired Action and associated Completion Timeof Condition B not metIIMcGuire Units 1 and 23.7.10-2Mc~ure nits1 ad 2 .7.0-2Amendment No.
INSERT 1 TS 3.7.10 New Condition BCONDITION f REQUIRED ACTION jCOMPLETION TIMENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature _< 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s24 hoursU U ATTACHMENT 2BCNS MARKED UP TECH SPEC PAGES CRACWS3.7.113.7 PLANT SYSTEMS3.7.11 Control Room Area Chilled Water System (CRACWS)LCO 3.7.11APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of recently irradiated fuel assemblies.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.C.-BC. Required Action and B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A bnot ANDmet in MODE 1, 2, 3,\ C 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sor 4. )--- .2 Be in MODE 5.-e;D. Required Action and Place OPERABLE Immediatelyassociated Completion CRACWS train in operation.Time of Condition A notmet in MODE 5or 6,or ORduring movement ofrecently irradiated fuel Suspend movement ofassemblies, recently irradiated fuel Immediatelyassemblies.(continued)INSERT 1 New Condition BCatawba Units 1 and 23.7.11-1Cataba nits1 ad 2 .7.1-1Amendment Nos. 1-98/1-9 CRACWS3.7.11CONDITION REQUIRED ACTION COMPLETION TIME-DE. Two CRA.CWS train-sT... in TnMODE 5or 6, or duringmovement of recentlyirradiated fuelassemblies.DE.1 Suspend movement ofrecently irradiated fuelassemblies.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.7.11.1 Verify the control room temperature is < 90°F. In accordance withthe SurveillanceFrequency ControlProgramNSERT1/4tNSERTRequired Action and associatedCompletion Time of Condition Bmetnotl IICatawba Units 1 and 23.7.11-2Cataba nits1 ad 2 .7.1-2Amendment Nos. 263, 2-59 INSERT 1 TS 3.7.11 New Condition BCONDITION REQUIRED ACTION [COMPLETION TIMEB. --- NOTENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature < 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s24 hoursa a ATTACHMENT 3AMNS MARKED UP TECH SPEC BASES PAGES B 3.7 PLANT SYSTEMSB 3.7.10 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room followingisolation of the control room.The CRACWS consists of two independent and redundant trains thatprovide cooling of recirculated control room air. Each train consists ofcooling coils, instrumentation, and controls to provide for control roomtemperature control. The CRACWS is a subsystem providing airtemperature control for the control room.The CRACWS is an emergency system, parts of which may also operateduring normal unit operations. A single train will provide the requiredtemperature control to maintain the control room at approximately 75°F.The CRACWS operation in maintaining the control room temperature isdiscussed in the UFSAR, Section 6.4 (Ref. 1).There are components that are part of the CRACWS but do not affect theCRAVS. These components are associated with the Control Room AreaAir Handling units, the Switchgear Air Handling units. LCO 3.7.10 doesnot apply if a CRAVS component does not directly impact the CRACWS.APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 75°F and 90°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.The CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).McGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-1Revision No. "I"1-5 CRACWSB 3.7.10BASESLCO Two independent and redundant trains of the CRACWS arerequired to be OPERABLE to ensure that at least one is available,assuming a single failure disabling the other train. Total systemfailure could result in the equipment operating temperatureexceeding limits in the event of an accident.The CRACWS is considered to be OPERABLE when theindividual components necessary to maintain the control roomtemperature are OPERABLE in both trains. These componentsinclude the cooling coils and associated temperature controlinstrumentation. In addition, the CRACWS must be operable tothe extent that air circulation can be maintained.The CRACWS is shared between the two units. The system mustbe OPERABLE for each unit when that unit is in the MODE ofApplicability. Additionally, both normal and emergency powermust also be OPERABLE because the system is shared. If aCRACWS component becomes inoperable, or normal oremergency power to a CRACWS component becomes inoperable,then the Required Actions of this LCO must be enteredindependently for each unit that is in the MODE of applicability ofthe LCO.APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of irradiatedfuel assemblies and during CORE ALTERATIONS, the CRACWSmust be OPERABLE to ensure that the control room temperaturewill not exceed equipment operational requirements followingisolation of the control room.ACTIONS A.1With one CRACWS train inoperable, action must be taken torestore OPERABLE status within 30 days. In this Condition, theremaining OPERABLE CRACWS train is adequate to maintain thecontrol room temperature within limits. However, the overallreliability is reduced because a single failure in the OPERABLECRACWS train could result in loss of CRACWS function. The30 day Completion Time is based on the low probability of anevent requiring control room isolation, the consideration that theremaining train can provide the required protection, and thatalternate safety or nonsafety related cooling means are available.(ew paragraph) anB2Im mMcGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-2Revision No. "I-I-5 INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored toensure that temperature is being maintained low enough that equipment in the control room isnot adversely affected and remains habitable. Mitigating actions, such as opening cabinetdoors, use of fans, or opening control room doors or ventilation paths, may be used to maintaincontrol room temperature. With the control room temperature being maintained within thetemperature limit, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore a CRACWS train to OPERABLE status. ThisCompletion Time is reasonable considering that the control room temperature is beingmaintained within limits and the low probability of an event occurring requiring control roomisolation.The condition is modified by a Note stating it is not applicable when the second CRACWS trainis intentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time.
CRACWSB 3.7.10BASESACTIONS (continued) assocated t ra~nIn MODE 1, 2, 3, or 4, if the inoperable- R:ACWS trafti cannot berestored to OPERABLE status within the Time, the unit must be placed in a MODE that minimizes the risk.To achieve this status, the unit must be placed in at least MODE 3within 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 allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.D D 0[A. 1,X32.1. and [.2.2In MODE 5 or 6, or during movement of irradiated fuel, or duringCORE ALTERATIONS, if the inoperable CRACWS train cannot berestored to OPERABLE status within the required CompletionTime, the OPERABLE CRACWS train must be placed in operationimmediately. This action ensures that the remaining train isOPERABLE, that no failures preventing automatic actuation willoccur, and that active failures will be readily detected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity thatmight require isolation of the control room. This places the unit ina condition that the movement of fuel if Required Actions B.1 or B.2 cannotE be met within the required Completion1 and.2 /TimesIn MODE 5 or 6, or during movement f. irradiated fuel assemblies,or during CORE ALTERATIONS, hiprbe, action must be taken immediately to suspend activities Ithat could result in a release of radioactivity that might requireisolation of the control room. This places the unit in a conditionthat minimizes risk. This does not preclude the movement of fuelto a safe position.If b.,cth ;r,,, ,noop,.rabohl in MODEN: "1. 2. 3. or I the"cotinrrl roomir a y n,,o.. t .,bo. c,, ap...blc ofI pz-^ r- In^g^....... .. .... .. .t".. ,i.,,,,, itSIrIIIdtjlltd lUIiL~, i. I. I 3I.0.3.. III..u l.iat ,b 1 lc.,tcz,McGuire Units 1 and 2B37103RvsoN.1-5B 3.7.10-3Revision No. ffff5 CRACWSB 3.7.10BASESSURVEILLANCE SR 3.7.10.1REQUIREMENTSThis SR verifies that the heat removal capability of the system issufficient to maintain the temperature in the control room at orbelow 90°F. The Surveillance Frequency is based on operatingexperience, equipment reliability, and plant risk and is controlledunder the Surveillance Frequency Control Program.REFERENCES1. UFSAR, Section 6.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).McGuire Units 1 and 2B37104RvsoN.1--B 3.7.10-4Revision No. 4-'1-5 ATTACHMENT 3BONS MARKED UP TECH SPEC BASES PAGES CRACWSB 3.7.11B 3.7 PLANT SYSTEMSB 3.7.11 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room and thecontrol room area.The CRACWS consists of two independent and redundant trains thatprovide cooling to the control room and control room area. Each trainconsists of a chiller package, chilled water pump, and air handling unitswith cooling coils. Chilled water is passed through the cooling coils of theair handling unit to cool the air. Electric duct heaters are then used tocontrol the supply air temperature.The CRACWS provides both normal and emergency cooling to thecontrol room and control room area. A single train will provide therequired temperature control to maintain the control room approximately74°F. The CRACWS operation in maintaining the control roomtemperature is discussed in the UFSAR, Section 9.4 (Ref. 1).APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 72°F and 85°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.Th'e CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).Catawba Units 1 and 2 B 3.7.11-1 Revision No.
CRACWSB 3.7.11BASESLCOTwo independent and redundant trains of the CRACWS are required tobe OPERABLE to ensure that at least one is available, assuming a singlefailure disabling the other train. Total system failure could result in theequipment operating temperature exceeding limits in the event of anaccident.The CRACWS is considered to be OPERABLE when the individualcomponents necessary to maintain the control room temperature areOPERABLE in both trains. These components include a chiller package,chilled water pump, and air handling unit. In addition, the CRACWS mustbe OPERABLE to the extent that air circulation can be maintained.The CRACWS is shared between the two units. The system must beOPERABLE for each unit when that unit is in the MODE of Applicability.Additionally, both normal and emergency power must also beOPERABLE because the system is shared. A shutdown unit supplying itsassociated emergency power source (1 EMXG/2EMXH) cannot becredited for OPERABILITY of components supporting the operating unit.If a CRACWS component becomes inoperable, or normal or emergencypower to a CRACWS component becomes inoperable, then the RequiredActions of this LCO must be entered independently for each unit that is inthe MODE of applicability of the LCO.APPLICABILITYIn MODES 1, 2, 3, 4, 5, and 6, and during movement of recentlyirradiated fuel assemblies, the CRACWS must be OPERABLE to ensurethat the control room temperature will not exceed equipment operationalrequirements following a design basis accident. The CRACWS is onlyrequired to be OPERABLE during fuel handling involving handlingrecently irradiated fuel (i.e., fuel that has occupied part of a critical reactorcore within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) due to radioactive decay.ACTIONSA.__1With one CRACWS train inoperable, action must be taken to restoreOPERABLE status within 30 days. In this Condition, the remainingOPERABLE CRACWS train is adequate to maintain the control roomtemperature within limits. However, the overall reliability is reducedbecause a single failure in the OPERABLE CRACWS train could result inloss of CRACWS function. The 30 day Completion Time is based on thelow probability of an event, the consideration that the remaining train canprovide the required protection, and that alternate safety or nonsafetyrelated cooling means are available.INSERT 2 B.1 and B.2(new paragraph)ICatawba Units 1 and 2B371-2RvsoNOB 3.7.11-2Revision INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored to ensurethat temperature is being maintained low enough that equipment in the control room is notadversely affected and remains habitable. Mitigating actions, such as opening cabinet doors,use of fans, or opening control room doors or ventilation paths, may be used to maintain controlroom temperature. With the control room temperature being maintained within the temperaturelimit, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore a CRACWS train to OPERABLE status. This CompletionTime is reasonable considering that the control room temperature is being maintained withinlimits and the low probability of an event occurring requiring control room isolation.The condition is modified by a Note stating it is not applicable when the second CRACWS train isintentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time.
CRACWSB 3.7.11BASESACTIONS (continueIIi an C 1asscae Itrain s)/In MODE 1, 2, 3, or 4, if the inoperab .,<RACWS tr cannot berestored to OPERABLE status within the Completion Time, theunit must be placed in a MODE that minimizes the risk. To achieve thisstatus, 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 inMODE 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 experience, to reach the required unit conditions fromfull power conditions in an orderly manner and without challenging unitsystems..l and D.In MODE 5 or 6, or during movement of recently irradiated fuel, if theinoperable CRACWS train cannot be restored to OPERABLE statuswithin the required Completion Time, the OPERABLE CRACWS trainmust be placed in operation immediately. This action ensures that theremaining train is OPERABLE, and that active failures will be readilydetected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity. This placesthe unit in a condition that minimizes accident risk. This does notpreclude th-' ma~,,-m-,rt i'f f, ,--I ta =- nn~itiAnI if Required Actions B.1 or B.2 cannot bemet within the required Completion TimesI* IIn MODE 5or 6,or urn moeeto eetyirradiated fuelassemblies, wihtf RCSt'lq ,o~sle, action must be takenimmediately to suspend activities that could result in a release ofradioactivity. This places the unit in a condition that minimizes risk. Thisdoes not preclude the movement of fuel to a safe position.It hnth CRAPW~ trnir.~ ~IIIUperabIlU MODIIEJ~l 1,2, 3, Ul 4', tllr:: rwII Igr..om........ma..not c ....bl cf p6-o-~F tg ,n ftllded ['urLiuunI.Therefore, LCOJ 3.U.3 must be entered Immediately.Catawba Units I and 2B3.113evsoNoB 3.7.11-3Revision CRACWSB 3.7.11BASESSURVEILLANCE SR 3.7.11.1REQUI REMENTSThis SR verifies that the heat removal capability of the system is sufficientto maintain the temperature in the control room at or below 90°F. TheSurveillance Frequency is based on operating experience, equipmentreliability, and plant risk and is controlled under the SurveillanceFrequency Control Program.REFERENCES1. UFSAR, Section 9.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).3. 10 CFR 50.67, Accident source term.4. Regulatory Guide 1.183, Revision 0.Catawba Units 1 and 2 B371- eiinNAB 3.7.11-4Revision No./,3/
S DUKE Steven D. CappsVice President~ENERG..Y McGuire Nuclear StationDuke EnergyMG01VP I 12700 Hagers Ferry RoadHuntersville, NC 280780: 980.875.4805Seril No MNS16-02 1' 980.875.4809Seril N. MN-16002Steven.Capps@duke-energy.comJanuary 7, 2016 10 CFR 50.90U.S. Nuclear Regulatory CommissionWashington, D.C. 20555ATTENTION: Document Control Desk
Subject:
Duke Energy Carolinas, LLC (Duke Energy)":McGuire Nuclear Station (MNS), Units 1 and 2,Docket Numbers 50-369 and 50-370, Renewed Facility Operating LicensesNPF-9 and NPF-17Catawba Nuclear Station (CNS), Units 1 and 2Docket Numbers 50-413 and 50-41 4, Renewed Facility Operating LicensesNPF-35 and NPF-52Proposed Technical Specifications (TS) Amendment TS 3.7.10, "Control RoomArea Chilled Water System" (MNS), and TS 3.7.11, "Control Room Area ChilledWater System" (CNS)Pursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the MNS and CNSFacility Operating Licenses and subject Technical Specifications (TS). This proposed licenseamendment request (LAR) modifies the TS by adding a new Action for both trains of ControlRoom Area Chilled Water Systems (CRACWS) inoperable. The new Action allows a finite timeto restore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at or below 90°F.The proposed LAR is modeled after TSTF-477; Rev. 3, "Add Action for Two Inoperable ControlRoom AC Subsystems." This TSTF is specific to the BWR NUREGs 1433 and 1434. DukeEnergy has determined this TSTF is readily adaptable to a NUREG-1 431 Standard TS for aWestinghouse plant. This topic was discussed with the NRC Staff on April 9, 2014. Theproposed amendment is not being submitted under the Consolidated Line Item ImprovementProcess (CLIIP) process.Attachment 1 provides Duke Energy's evaluation of the amendment, which contains adescription of the proposed changes, the technical evaluation, the regulatory analysis, thedetermination that this LAR contains No Significant Hazards Considerations, the basis for thecategorical exclusion from performing an Environmental Assessment/Impact Statement, andprecedent for the LAR.Attachment 2A provides the existing MNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.www.duke-energy.com U.S. Nuclear Regulatory Commission-MNS-1 6-002Page 2Attachment 2B provides the existing CNS TS pages marked-up to show the proposed changes.The reprinted TS pages will be provided to the NRC upon issuance of the approvedamendment.Attachment 3A provides a portion of the existing MNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the MNS Bases Control Program (TS 5.5.14).Attachment 3B provides a portion of the existing CNS TS Bases pages marked-up to show thecorresponding proposed Bases changes. The TS Bases change will be processed after LARapproval under the CNS Bases Control Program (TS 5.5.14).This proposed LAR has been reviewed and approved by the MNS and CNS Plant OperationsReview Committees in accordance with the requirements of the Duke Energy Quality AssuranceProgram.In accordance with 10 CFR 50.91, Duke Energy is notifying the applicable state officials of thisapplication for license amendment by transmitting a copy of this letter and its attachments to thedesignated officials.This submittal will not impact the MNS or CNS Updated Final Safety Analysis Reports(UFSARs).Duke Energy requests approval of this submittal within one calendar year of the submittal dateand an implementation period of 60 days from the date of amendment issuance.There are no regulatory commitments contained in this amendment.Please direct any questions you may have in this matter to Lee A. Hentz at (980) 875-41 87.I declare under penalty of perjury that the foregoing is true and correct. Executed on January 7,2016.Sincerely,Steven D. CappsAttachments U.S. Nuclear Regulatory CommissionMNS-1 6-002Page 3xc (with attachments):Catherine HaneyRegional AdministratorU.S. Nuclear Regulatory Commission -Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, GA 30303-1257G.A. Hutto, IllSenior Resident Inspector (Catawba)U.S. Nuclear Regulatory CommissionCatawba Nuclear StationJ. ZeilerSenior Resident Inspector (McGuire)U.S. Nuclear Regulatory CommissionMcGuire Nuclear StationG. E. Miller (addressee only)NRC Project Manager (Catawba and McGuire)U.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 8-G9A11555 Rockville PikeRockville, MD 20852-2738S.E. JenkinsManagerRadioactive and Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201W.L. Cox, IllSection ChiefDivision of Environmental HealthRadiation Protection SectionNorth Carolina Department of Environment and Natural Resources1645 Mail Service CenterRaleigh, NC 27699 ATTACHMENT 1EVALUATION OF PROPOSED AMENDMENT1.0 SUMMARY DESCRIPTION2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
3.1 TS System Descriptions3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse Plant3.3 Operational Burden3.4 System Reliability Improvements3.5 Control Room Equipment Temperature Limit Validation3.6 Application of Proposed Change
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria4.2 Precedents4.3 No Significant Hazards Consideration4.4 Conclusion
5.0 ENVIRONMENTAL CONSIDERATION
S
6.0 REFERENCES
I ATTACHMENT 11.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Duke Energy is requesting amendments to the McGuire NuclearStation (MNS) and Catawba Nuclear Station (CNS) Facility Operating Licenses and subjectTechnical Specifications (TS). This proposed license amendment request (LAR) modifies MNSTS 3.7.10, "Control Room Area Chilled Water Systems," and corresponding CNS TS 3.7.11 byadding a new Action for both trains of Control Room Area Chilled Water Systems (CRACWS)inoperable. The new Action allows a finite time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, to restore one train to Operablestatus and requires periodic verification that Control Room temperature is maintained at orbelow 900°F.2.0 DETAILED DESCRIPTIONAs discussed in a meeting with the NRC staff on April 9, 2014, the proposed LAR is modeledafter TSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems." TSTF-477 is applicable only to BWR (General Electric) NUREGs 1433 and 1434, and adoption of thisTSTF is available to BWRs via the Consolidated Line Item Improvement Process (CLIIP). Sincethe CNS and MNS TS are based on the Westinghouse NUREG-1431 Standard TSs, this DukeEnergy LAR is not proposed to be processed via the CLIIP process. TSTF-477 adds aCondition to restore one Control Room AC subsystem within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the event two ControlRoom AC subsystems become inoperable.Since the Duke Energy meeting with the NRC staff, the Technical Specification Task Force hassubmitted a Traveler, TSTF-553, for NRC review. TSTF-553 is similar to TSTF-477 but isapplicable to Westinghouse (NUREG-1 431) and Babcock & Wilcox (NUREG-1 430) plants andprovides a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for both plant types in the event two Control Room ACsubsystems become inoperable. TSTF-553 also includes a note that precludes use of the 24hour allowance when the second train is intentionally made inoperable. Although TSTF-553 hasnot yet been reviewed or approved by the NRC, the LAR proposed by Duke Energy adopts themore conservative 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time and the additional restriction regarding intentionalentry into the Condition.The proposed LAR revises MNS TS 3.7.10 and CNS TS 3.7.11 as follows:a. Add a new Action B. New Action B applies when two CRACWS trains are inoperable.Required Action B.1 requires verification once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> that Control Roomtemperature is less than or equal to 90°F. Required Action B.2 requires restoration ofone CRACWS train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.b. New Condition B is modified by a Note which states, "Not applicable when secondCRACWS train intentionally made inoperable." If the second CRACWS train isintentionally made inoperable, there is no applicable Condition~and immediate entry intoLCO 3.0.3 is required.c. Existing Action B, now renamed Action C, which applies when the Required Action andassociated Completion Time of Condition A (one CRACWS train inoperable) is not metin MODES 1, 2, 3,or 4, is revised to also be applicable when the Required Actions andassociated Completion Times of new Condition B~are not met. Renumbered Condition Crequires being in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.2 ATTACHMENT 1d. Existing Action C, now renamed Action D, remains unchanged.e. For MNS, existing Action 0, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of irradiated fuel assemblies or during corealterations, is revised to be applicable when the Required Actions and associatedCompletion Times of new Condition B are not met.f. For CNS, existing Action D, now renamed Action E, which applies when two CRACWStrains are inoperable during movement of recently irradiated fuel assemblies, is revisedto be applicable when the Required Actions and associated Completion Times of newCondition B are not met.g. Existing Action E, which applied when two CRACWS trains are inoperable in MODE 1,2, 3, or 4, and requires entry into LCO 3.0.3, is no longer needed and deleted (redundantto revised Condition C.).The marked-up TS pages showing the proposed changes above are provided in Attachments2A and 2B.The corresponding TS Bases pages showing the proposed changes are provided inAttachments 3A and 3B. The TS Bases change will be processed after LAR approval under theMNS and CNS Bases Control Program (TS 5.5.14). They are provided in this LAR forinformation only.
3.0 TECHNICAL EVALUATION
3.1 TS System DescriptionsThe CRACWS provides air temperature control for the Control Room, Control Room Area, andSwitchgear Rooms. The Control Room Area (CRA) consists predominately of the Vital Batteryand Equipment Rooms, Motor Control Center (MCC) rooms, and Cable Rooms. TheSwitchgear Rooms contain the essential switchgear. The CRA and Switchgear Rooms are notpart of the Control Room Envelope and not governed by the CRACWS Technical Specifications.The CRACWS consists of two independent and redundant trains. Each train consists of achiller package, chilled water pump, air handling units with cooling coils, instrumentation, andcontrols.The CRACWS is an emergency system, which also operates during normal unit operations. Asingle train will provide the required temperature control to maintain the Control Room atapproximately 75°F for MNS and 74°F for CNS, respectively. The design basis of the CRACWSis to maintain the Control Room temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety related trains. During emergencyoperation, the CRACWS maintains the Control Room temperature between 75°F and 90°F forMNS and between 72°F and 85°F for CNS, respectively. A single active failure of a componentof the CRACWS, with a loss of offsite power, does not impair the ability of the system to performits design function. Redundant detectors and controls are provided for Control Roomtemperature control. The CRACWS is designed in accordance with Seismic Category I3 ATTACHMENT 1requirements. The CRACWS is capable of removing sensible and latent heat loads from theControl Room, which include consideration of equipment heat loads and personnel occupancyrequirements, to ensure equipment operability.Two independent and redundant trains of the CRACWS are required to be operable to ensurethat at least one is available, assuming a single failure disabling the other train. The CRACWSis shared between the two units. The system must be operable for each unit when that unit is inthe Mode of Applicability.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) are governed by separateTechnical Specifications; MNS TS 3.7.9 and CNS TS 3.7.10. The CRAVS is an emergencyredundant system that provides a protected habitable environment for the Control RoomEnvelope from which occupants can control the Units following an uncontrolled release ofradioactivity, hazardous chemicals, or smoke. The CRAVS does not provide a protectedhabitable environment for the Control Room Area or Switchgear Rooms. The inoperability ofCRACWS does not impact the operability of CRAVS.The MNS CRACWS and CRAVS are described in MNS UFSAR Section 6.4. The CNSCRACWS and CRAVS are described in CNS UFSAR Section 9.4.3.2 Adaptability of BWR TSTF-477 Rev.3 to a Westinghouse PlantTSTF-477 Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems," was NRCapproved for adoption in 2007. This BWR (GE) specific TSTF allows for two trains of ControlRoom cooling to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as long as the Control Room areatemperature can be maintained (and monitored) within a pre-determined limit, commonly 90°F.The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was deemed reasonable considering that Control Roomtemperature is being maintained within limits and the low probability of an event occurring thatwould require Control Room area isolation. Alternate methods of maintaining control roomtemperature, such as non-safety grade air conditioning systems or fans, can also be used tomaintain control room temperature. As previously stated in Section 2.0, Duke Energy will adoptthe more conservative Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> proposed by TSTF-553.TSTF-477 Rev. 3 is deterministically justified and relies on safety related cabinet equipmentqualification (EQ) temperature limits and Control Room heat-up assumptions. For the GEplants, a GE Topical Report supports the EQ justification. Duke Energy has performed sitespecific confirmations that equipment qualification for Control Room safety relatedinstrumentation and devices remains valid up to 90°F. Note MNS TS 3.7.10 and CNS TS 3.7.11already contain a Surveillance Requirement (SR) that confirms the Control Room is 90°F or lessevery 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.AS precedent; TSTF-477 Rev. 3 references other GE Technical Specifications that currentlyprovide an Action with a finite time to restore one train to operable status when both trains areinoperable. MNS and CNS have similar Technical Specifications:1. MNS and CNS TSs 3.3.3, "Post Accident Monitoring" (7 days).2. MNS TS 3.7.11 and CNS TS 3.7.12, "Auxiliary Building Filtered Ventilation ExhaustSystem" (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).4 ATTACHMENT 1Duke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, Request for AdditionalInformation (RAIs), and the NRC Safety Evaluations (SE) that adopted TSTF-477 Rev. 3.Based on that review, Duke Energy did not identify an issue that could not be addressed at ourplants and did not identify any GE/BWR specific requirements or conditions.3.3 Operational BurdenBoth MNS and CNS have experienced the inoperability of both trains of Control Room cooling.These occurred in 2005 and 2010 at MNS and in 2011 at CNS. With Control Room coolingbeing a shared system, these three events led to the initiation of a two unit shutdown.For the MNS events, one Control Room cooling train was functional but not operable. Notice ofEnforcement Discretion (NOEDs) were submitted and granted for MNS on both occasions toremain at power operation until one cooling train was restored to Operable status.For the CNS event, the "A" cooling train was in planned maintenance when the "B" cooling traintripped due to a chiller controls system micro-processor failure. Both units initiated a shutdownand proceeded to Mode 3 while a NOED was processed to not proceed to Mode 4. The "A"cooling train was restored shortly thereafter.As part of the 2010 NRC approved NOED, MNS committed to submit an LAR to addressoperability requirements of the Control Room cooling Technical Specification.3.4 System Reliability ImprovementsThe 2005 MNS event was caused by a degraded oil pressure switch, which prohibited the "A"cooling train chiller compressor from starting. At the time, the redundant cooling train wasfunctional but administratively inoperable due to support system alignments for refueling outageEngineered Safety Features (ESF) testing. The degraded oil pressure switch was replaced, andthen in 2007, the original chiller controls were replaced with digital controls, which improved thereliability of the oil pressure switch function.For the 2010 MNS event, the loss of the operating train of Control Room cooling was caused byhigh vibration of the hot gas bypass line (HGBP), which led to a breach of the coolant line. Atthe time, the redundant cooling train was in a planned maintenance evolution and temporarilyunavailable.Since 2010, both MNS Control Room cooling trains have been upgraded with new HGBP pipingto reduce vibration interactions, vibration isolators have been installed, corroded and erodedservice water piping has been replaced, small bore piping and tubing has been replaced, andpiping analysis models were developed to identify potential thermal stresses. In addition, thecondenser normal operating head pressure was reduced, which further reduced HGBP pipingvibration.After the 2011 CNS chiller micro-processor failure, significant efforts were made to determinethe cause of the failure and to enable the chiller to be rapidly restarted. The failed micro-processor was sent to the original qualifier of the controls who, in concert with the originalmanufacturer of the controls, investigated the cause of the failure. The manufacturer has manyyears of in-service experience with this type of micro-processor and has experienced very few5 ATTACHMENT 1failures. The failed micro-processor was subject to multiple tests, but the problem did not re-occur.Both companies recommended that failures of this type be addressed by removing andreapplying power to the micro-processor, similar to how many computer related problems areaddressed. This allows rapid re-start of the chiller. CNS has incorporated such actions into thecurrent operating procedures. In addition, CNS maintenance procedures have been enhancedto provide direction on how to replace a micro-processor which can now be done very quickly.Since MNS utilizes the same chiller controls, similar operating and maintenance procedureenhancements were incorporated.3.5 Control Room Equipment Temperature Limit ValidationMNS TS 3.7.10 and CNS TS 3.7.11 currently contain an SR that confirms the Control Room is90°F or less every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As such, the current licensed design temperature of the ControlRoom equipment remains unchanged by the proposed TS changes.Duke Energy has also concluded that the 90°F limit in the new proposed TS Action B remainsunchanged based on a review of design specifications for the respective Control Room safetyrelated instruments and devices. Design specifications for protective equipment in the ControlRoom specify no loss of protective function over the temperature range of 40°F to 90°F and ahumidity range of 15 to 95% relative humidity.Therefore, monitoring of bulk Control Room temperature every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure that ambienttemperature is less than or equal to 90°F would verify that the Control Room temperature is ator below the design limit.3.6 Application of Proposed ChangeThe most likely application of proposed Condition B and the associated Required Actions iswhen both CRACWS trains are inoperable but one train is functional with the ability to cool theControl Room. In this case, the Control Room temperature would remain constant at a normalvalue, and the 90°F limit is not challenged. One CRACWS would need to be restored toOperable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.In the event both CRACWS trains are inoperable and non-functional, MNS and CNS havedeveloped '"Abnormal Procedures" (AP) to mitigate rising temperatures in the Control Room andtake actions to shutdown the affected Units if temperature rises above 90°F, or there areindications of instrumentation malfunctions that have safety significance.4.0. REGULATORY EVALUATION4.1 Applicable Regulatory Requirements/CriteriaGeneral Design Criterion (GDC) 19, "Control Room" states in part:A Control Room shall be provided from which actions can be taken to operate thenuclear power unit safely under normal conditions and to maintain it in a safe condition6 ATTACHMENT 1under accident conditions, including loss-of-coolant accidents. Adequate radiationprotection shall be provided to permit access and occupancy of the control room underaccident conditions without personnel receiving radiation exposures in excess of 5 remwhole body, or its equivalent to any part of the body, for the duration of the accident.The MNS and CNS Control Room Area Ventilation Systems (CRAVS) provide compliance withGDC 19. The CRAVS is an emergency redundant system that provides a protected habitableenvironment for the Control Room Envelope from which occupants can control the Unitsfollowing an uncontrolled release of radioactivity, hazardous chemicals, or smoke. Theproposed changes to the CRACWS TS do not impact the operability of CRAVS.In addition, the operability requirements of the CRACWS have not changed. The regulatoryrequirements do not specifically address Completion Times with inoperable systems. As aresult, the regulatory requirements and criteria are not affected by the proposed change.4.2 PrecedentsDuke Energy has also reviewed the Hope Creek and Edwin Hatch LARs, PAls, and NRC SEsthat recently adopted TSTF-477 Rev. 3. Based on that review, Duke Energy did not identify anissue that could not be addressed at our plants and did not identify any GE/BWR specificrequirements or conditions.*PSEG Hope Creek Generating Station, LAR dated February 28, 2011 (ADAMSAccession No. ML1 10590636); as supplemented by letters dated August 29, 2011(ML1 12420124), December 16, 2011 (ML1 13530205), and January 26, 2012(ML12026A458); NRC SE dated February 8, 2012 (ML120180078).* SNC Edwin I. Hatch Nuclear Plant, LAR dated January 16, 2014, (ADAMS AccessionNo. ML14016A202); as supplemented by letter dated May 2, 2014 (ML14122A339); andNRC SE dated December 10, 2014 (ML14279A261).4.3 No Significant Hazards ConsiderationPursuant to 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes a licenseamendment request (LAR) for the Renewed Facility Operating License (FOL) and TechnicalSpecifications (TS) for McGuire (MNS) and Catawba (CNS) Nuclear Stations, Units I and 2.This proposed LAR modifies MNS TS 3.7.10, "Control Room Area Chilled Water Systems," andcorresponding CNS TS 3.7.11 by adding a new Action for both trains of Control Room AreaChilled Water Systems (CRACWS) inoperable. The new Action allows a finite time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, torestore one train to Operable status and requires periodic verification that Control Roomtemperature is maintained at-or below 90°F degrees.- The-proposed LAR is modeled afterTSTF-477, Rev. 3, "Add Action for Two Inoperable Control Room AC Subsystems."Duke Energy has concluded that operation of the McGuire and Catawba Nuclear Stations inaccordance with the proposed generic changes to the Technical Specifications does not involvea significant hazards consideration. Duke Energy's conclusion is based on its evaluation, inaccordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c) asdiscussed below:7 ATTACHMENT 11. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?Response: No.The proposed change allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable CRACWS train when both trainsare inoperable provided Control Room temperature is verified to be within the design limitsevery 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The equipment qualification temperature of Control Room equipment is notaffected. The CRACWS is not an initiator of any accident previously evaluated. As a result, theprobability of any accident previously evaluated is not increased.The consequences of an accident during the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time are nodifferent than the consequences of an accident during the existing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Timeprovided in LCO 3.0.3 to prepare for a shutdown. The proposed TS changes do not increase orchange the current Control Room temperature limit. As a result, the consequences of anyaccident previously evaluated are not significantly increased.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?Response: No.No new or different accidents result from utilizing the proposed change. The TS changes do notinvolve a physical alteration of the plant or a change in the methods governing normal plantoperation. In addition, the changes do not impose any new or different requirements. Should thenew Actions not be met, the existing and proposed Actions require a plant shutdown. Thechanges do not alter assumptions made in the safety analysis. The proposed changes areconsistent with the safety analysis assumptions.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: No.The proposed change provides a limited period of time to restore an inoperable CRACWS traininstead of requiring an immediate plant shutdown. A plant shutdown is a transient, which maybe avoided by providing a limited time to make repairs. In addition, the Control RoomtemPerature must be maintained less than a limit set to_ ensure habitability of the Control Roomand the operability of-the equipment cooled by the CRACWS. The potential to avoid a planttransient, in conjunction with maintaining the Control Room temperature and the low probabilityof an event occurring during this time period, offset any risk associated with the limitedCompletion Time.Therefore, the proposed change does not involve a significant reduction in a margin of safety.8 ATTACHMENT 1Based on the above, Duke Energy concludes that the proposed change presents no significanthazards consideration under the standards set forth in 10 CER 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.4.4 ConclusionIn conclusion, based on the considerations discussed above, (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission's regulations,and (3) the approval of the proposed change will not be inimical to the common defense andsecurity or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
SA review has determined that the proposed change would change a requirement with respect toinstallation or use of a facility component located within the restricted area, as defined in 10CER 20, or would change an inspection or surveillance requirement. However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant change in thetypes or significant increase in the amounts of any effluents that may be released offsite, or (iii)a significant increase in individual or cumulative occupational radiation exposure. Accordingly,the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR51 .22(c)(g).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmentalassessment need be prepared in connection with the proposed change.9 ATTACHMENT
16.0 REFERENCES
- 1) TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, datedMarch 26, 2007.2) NRC Letter, Summary of April 9, 2014, Public Teleconference Regarding PotentialSubmission of a License Amendment Request to Implement TSTF-477 for Control Room AirConditioning subsystems, dated April 21, 2014, ADAMS Accession No.ML14101A243.3) TSTF-553, Revision 0, Add Action for Two Inoperable CREA TCS Trains, transmitted forNRC review on October 31, 2015.4) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Units 1and 2, Docket Number 50-369 and 50-370 Notice of Enforcement Discretion RequestTechnical Specification (TS) 3. 7.10, Control Room Area Chilled water System, datedJanuary 14, 2010.5) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke) McGuire Nuclear Station, Unit 250-370 Notice of Enforcement Discretion Request Technical Specification 3. 7.10, ControlRoom Area Chilled water System (CRACWS), dated October 12, 2005.6) Duke Energy Letter, Duke Energy Carolinas, LLC (Duke Energy) Catawba Nuclear Station,Units I and 2, Docket Number 50-4 13 and 50-4 14 Notice of Enforcement Discretion (NOED)Request Technical Specification (TS) 3. 7.11, "Control Room Area Chilled water System(CRACWS)" TS Limiting condition for Operation (LCO) 3.0.3 dated December 19, 2011.7) PSEG Letter, Hope Creek Generating Station, Facility Operating License No. NPF-57 NRCDocket No. 50-354 Application for Technical Specification Change TSF-4 77, Revision 3,Add Action for Two Inoperable Control Room AC Subsystems to the TechnicalSpecifications Using Consolidated Line Item Improvement Process, dated February 28,2011.8) Southern Nuclear Letter, Edwin I. Hatch Nuclear Plant Application for TechnicalSpecification Change to Revise Action Statements for Inoperable Control Room Airconditioning Subsystems, dated January 16, 2014.10 ATTACHMENT 2AMNS MARKED UP TECH SPEC PAGES CRACWS3.7.103.7 PLANT SYSTEMS3.7.10 Control Room Area Chilled Water System (CRACWS)LCO 3.7.10APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of irradiated fuel assemblies,During CORE ALTERATIONS.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.CAB_,. Required Action and ,B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A not ANDmet in MODE1, 2, Cor.ior 1.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sDRequired Action and ¢.1 Place OPERABLE Immediatelyassociated Completion CRACWS train inTime of Condition A not operation.met in MODE 5 or 6, orduring movement of ORirradiated fuel Dassemblies, or during p.2.1 Suspend CORE ImmediatelyCORE ALTERATIONS. ALTERATIONS.ANDDZ;.2.2 Suspend movement of Immediatelyirradiated fuel assemblies.INSERT 1 New Condition B(continued)McGuire Units 1 and 23.7.10-1Mc~ure nitsI ad 2 .7.0-1Amendment No. 1-84/1t6e CRACWS3.7.10ACTIONS (continued)CONDITION [REQUIRED ACTION COMPLETION TIMEin MODE 5or 6, or duringmovement of irradiatedfuel assemblies, orduring COREALTERATIONS.Efr.1ANDE012Suspend COREALTERATIONS.Suspend movement ofirradiated fuel assemblies.ImmediatelyImmediatelyE. C"RA.\AI trains E.1 E nter !C 3.0.3 ~ vt41efihteySURVEILLANCE REQUIREMENTS _______SURVEILLANCE FREQUENCYSR 3.7.10.1 Verify the control room temperature is < 900F. In accordance withthe SurveillanceFrequency ControlProgramINSERTRequired Action and associated Completion Timeof Condition B not metIIMcGuire Units 1 and 23.7.10-2Mc~ure nits1 ad 2 .7.0-2Amendment No.
INSERT 1 TS 3.7.10 New Condition BCONDITION f REQUIRED ACTION jCOMPLETION TIMENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature _< 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s24 hoursU U ATTACHMENT 2BCNS MARKED UP TECH SPEC PAGES CRACWS3.7.113.7 PLANT SYSTEMS3.7.11 Control Room Area Chilled Water System (CRACWS)LCO 3.7.11APPLICABILITY:Two CRACWS trains shall be OPERABLE.MODES 1, 2, 3, 4, 5, and 6,During movement of recently irradiated fuel assemblies.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. One CRACWS train A.1 Restore CRACWS train to 30 daysinoperable. OPERABLE status.C.-BC. Required Action and B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A bnot ANDmet in MODE 1, 2, 3,\ C 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sor 4. )--- .2 Be in MODE 5.-e;D. Required Action and Place OPERABLE Immediatelyassociated Completion CRACWS train in operation.Time of Condition A notmet in MODE 5or 6,or ORduring movement ofrecently irradiated fuel Suspend movement ofassemblies, recently irradiated fuel Immediatelyassemblies.(continued)INSERT 1 New Condition BCatawba Units 1 and 23.7.11-1Cataba nits1 ad 2 .7.1-1Amendment Nos. 1-98/1-9 CRACWS3.7.11CONDITION REQUIRED ACTION COMPLETION TIME-DE. Two CRA.CWS train-sT... in TnMODE 5or 6, or duringmovement of recentlyirradiated fuelassemblies.DE.1 Suspend movement ofrecently irradiated fuelassemblies.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.7.11.1 Verify the control room temperature is < 90°F. In accordance withthe SurveillanceFrequency ControlProgramNSERT1/4tNSERTRequired Action and associatedCompletion Time of Condition Bmetnotl IICatawba Units 1 and 23.7.11-2Cataba nits1 ad 2 .7.1-2Amendment Nos. 263, 2-59 INSERT 1 TS 3.7.11 New Condition BCONDITION REQUIRED ACTION [COMPLETION TIMEB. --- NOTENot applicable whensecond CRACWSintentionally madeinoperable.Two CRACWS trainsinoperable.B. 1 Verify Control roomtemperature < 90°F.ANDB.2 Restore one CRACWStrain to OPERABLEstatus.Once per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s24 hoursa a ATTACHMENT 3AMNS MARKED UP TECH SPEC BASES PAGES B 3.7 PLANT SYSTEMSB 3.7.10 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room followingisolation of the control room.The CRACWS consists of two independent and redundant trains thatprovide cooling of recirculated control room air. Each train consists ofcooling coils, instrumentation, and controls to provide for control roomtemperature control. The CRACWS is a subsystem providing airtemperature control for the control room.The CRACWS is an emergency system, parts of which may also operateduring normal unit operations. A single train will provide the requiredtemperature control to maintain the control room at approximately 75°F.The CRACWS operation in maintaining the control room temperature isdiscussed in the UFSAR, Section 6.4 (Ref. 1).There are components that are part of the CRACWS but do not affect theCRAVS. These components are associated with the Control Room AreaAir Handling units, the Switchgear Air Handling units. LCO 3.7.10 doesnot apply if a CRAVS component does not directly impact the CRACWS.APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 75°F and 90°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.The CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).McGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-1Revision No. "I"1-5 CRACWSB 3.7.10BASESLCO Two independent and redundant trains of the CRACWS arerequired to be OPERABLE to ensure that at least one is available,assuming a single failure disabling the other train. Total systemfailure could result in the equipment operating temperatureexceeding limits in the event of an accident.The CRACWS is considered to be OPERABLE when theindividual components necessary to maintain the control roomtemperature are OPERABLE in both trains. These componentsinclude the cooling coils and associated temperature controlinstrumentation. In addition, the CRACWS must be operable tothe extent that air circulation can be maintained.The CRACWS is shared between the two units. The system mustbe OPERABLE for each unit when that unit is in the MODE ofApplicability. Additionally, both normal and emergency powermust also be OPERABLE because the system is shared. If aCRACWS component becomes inoperable, or normal oremergency power to a CRACWS component becomes inoperable,then the Required Actions of this LCO must be enteredindependently for each unit that is in the MODE of applicability ofthe LCO.APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of irradiatedfuel assemblies and during CORE ALTERATIONS, the CRACWSmust be OPERABLE to ensure that the control room temperaturewill not exceed equipment operational requirements followingisolation of the control room.ACTIONS A.1With one CRACWS train inoperable, action must be taken torestore OPERABLE status within 30 days. In this Condition, theremaining OPERABLE CRACWS train is adequate to maintain thecontrol room temperature within limits. However, the overallreliability is reduced because a single failure in the OPERABLECRACWS train could result in loss of CRACWS function. The30 day Completion Time is based on the low probability of anevent requiring control room isolation, the consideration that theremaining train can provide the required protection, and thatalternate safety or nonsafety related cooling means are available.(ew paragraph) anB2Im mMcGuire Units 1 and 2 B371- eiinN.1-B 3.7.10-2Revision No. "I-I-5 INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored toensure that temperature is being maintained low enough that equipment in the control room isnot adversely affected and remains habitable. Mitigating actions, such as opening cabinetdoors, use of fans, or opening control room doors or ventilation paths, may be used to maintaincontrol room temperature. With the control room temperature being maintained within thetemperature limit, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore a CRACWS train to OPERABLE status. ThisCompletion Time is reasonable considering that the control room temperature is beingmaintained within limits and the low probability of an event occurring requiring control roomisolation.The condition is modified by a Note stating it is not applicable when the second CRACWS trainis intentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time.
CRACWSB 3.7.10BASESACTIONS (continued) assocated t ra~nIn MODE 1, 2, 3, or 4, if the inoperable- R:ACWS trafti cannot berestored to OPERABLE status within the Time, the unit must be placed in a MODE that minimizes the risk.To achieve this status, the unit must be placed in at least MODE 3within 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 allowedCompletion Times are reasonable, based on operatingexperience, to reach the required unit conditions from full powerconditions in an orderly manner and without challenging unitsystems.D D 0[A. 1,X32.1. and [.2.2In MODE 5 or 6, or during movement of irradiated fuel, or duringCORE ALTERATIONS, if the inoperable CRACWS train cannot berestored to OPERABLE status within the required CompletionTime, the OPERABLE CRACWS train must be placed in operationimmediately. This action ensures that the remaining train isOPERABLE, that no failures preventing automatic actuation willoccur, and that active failures will be readily detected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity thatmight require isolation of the control room. This places the unit ina condition that the movement of fuel if Required Actions B.1 or B.2 cannotE be met within the required Completion1 and.2 /TimesIn MODE 5 or 6, or during movement f. irradiated fuel assemblies,or during CORE ALTERATIONS, hiprbe, action must be taken immediately to suspend activities Ithat could result in a release of radioactivity that might requireisolation of the control room. This places the unit in a conditionthat minimizes risk. This does not preclude the movement of fuelto a safe position.If b.,cth ;r,,, ,noop,.rabohl in MODEN: "1. 2. 3. or I the"cotinrrl roomir a y n,,o.. t .,bo. c,, ap...blc ofI pz-^ r- In^g^....... .. .... .. .t".. ,i.,,,,, itSIrIIIdtjlltd lUIiL~, i. I. I 3I.0.3.. III..u l.iat ,b 1 lc.,tcz,McGuire Units 1 and 2B37103RvsoN.1-5B 3.7.10-3Revision No. ffff5 CRACWSB 3.7.10BASESSURVEILLANCE SR 3.7.10.1REQUIREMENTSThis SR verifies that the heat removal capability of the system issufficient to maintain the temperature in the control room at orbelow 90°F. The Surveillance Frequency is based on operatingexperience, equipment reliability, and plant risk and is controlledunder the Surveillance Frequency Control Program.REFERENCES1. UFSAR, Section 6.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).McGuire Units 1 and 2B37104RvsoN.1--B 3.7.10-4Revision No. 4-'1-5 ATTACHMENT 3BONS MARKED UP TECH SPEC BASES PAGES CRACWSB 3.7.11B 3.7 PLANT SYSTEMSB 3.7.11 Control Room Area Chilled Water System (CRACWS)BASESBACKGROUND The CRACWS provides temperature control for the control room and thecontrol room area.The CRACWS consists of two independent and redundant trains thatprovide cooling to the control room and control room area. Each trainconsists of a chiller package, chilled water pump, and air handling unitswith cooling coils. Chilled water is passed through the cooling coils of theair handling unit to cool the air. Electric duct heaters are then used tocontrol the supply air temperature.The CRACWS provides both normal and emergency cooling to thecontrol room and control room area. A single train will provide therequired temperature control to maintain the control room approximately74°F. The CRACWS operation in maintaining the control roomtemperature is discussed in the UFSAR, Section 9.4 (Ref. 1).APPLICABLE The design basis of the CRACWS is to maintain the control roomSAFETY ANALYSES temperature for 30 days of continuous occupancy.The CRACWS components are arranged in redundant, safety relatedtrains. During emergency operation, the CRACWS maintains thetemperature between 72°F and 85°F. A single active failure of acomponent of the CRACWS, with a loss of offsite power, does not impairthe ability of the system to perform its design function. Redundantdetectors and controls are provided for control room temperature control.The CRACWS is designed in accordance with Seismic Category Irequirements. The CRACWS is capable of removing sensible and latentheat loads from the control room, which include consideration ofequipment heat loads and personnel occupancy requirements, to ensureequipment OPERABILITY.Th'e CRACWS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 2).Catawba Units 1 and 2 B 3.7.11-1 Revision No.
CRACWSB 3.7.11BASESLCOTwo independent and redundant trains of the CRACWS are required tobe OPERABLE to ensure that at least one is available, assuming a singlefailure disabling the other train. Total system failure could result in theequipment operating temperature exceeding limits in the event of anaccident.The CRACWS is considered to be OPERABLE when the individualcomponents necessary to maintain the control room temperature areOPERABLE in both trains. These components include a chiller package,chilled water pump, and air handling unit. In addition, the CRACWS mustbe OPERABLE to the extent that air circulation can be maintained.The CRACWS is shared between the two units. The system must beOPERABLE for each unit when that unit is in the MODE of Applicability.Additionally, both normal and emergency power must also beOPERABLE because the system is shared. A shutdown unit supplying itsassociated emergency power source (1 EMXG/2EMXH) cannot becredited for OPERABILITY of components supporting the operating unit.If a CRACWS component becomes inoperable, or normal or emergencypower to a CRACWS component becomes inoperable, then the RequiredActions of this LCO must be entered independently for each unit that is inthe MODE of applicability of the LCO.APPLICABILITYIn MODES 1, 2, 3, 4, 5, and 6, and during movement of recentlyirradiated fuel assemblies, the CRACWS must be OPERABLE to ensurethat the control room temperature will not exceed equipment operationalrequirements following a design basis accident. The CRACWS is onlyrequired to be OPERABLE during fuel handling involving handlingrecently irradiated fuel (i.e., fuel that has occupied part of a critical reactorcore within the previous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) due to radioactive decay.ACTIONSA.__1With one CRACWS train inoperable, action must be taken to restoreOPERABLE status within 30 days. In this Condition, the remainingOPERABLE CRACWS train is adequate to maintain the control roomtemperature within limits. However, the overall reliability is reducedbecause a single failure in the OPERABLE CRACWS train could result inloss of CRACWS function. The 30 day Completion Time is based on thelow probability of an event, the consideration that the remaining train canprovide the required protection, and that alternate safety or nonsafetyrelated cooling means are available.INSERT 2 B.1 and B.2(new paragraph)ICatawba Units 1 and 2B371-2RvsoNOB 3.7.11-2Revision INSERT 2 Bases B.1 and B.2 (new paragraph)B.1 and B.2If both CRACWS trains are inoperable, the CRACWS may not be capable of performing itsintended function. Therefore, the control room temperature is required to be monitored to ensurethat temperature is being maintained low enough that equipment in the control room is notadversely affected and remains habitable. Mitigating actions, such as opening cabinet doors,use of fans, or opening control room doors or ventilation paths, may be used to maintain controlroom temperature. With the control room temperature being maintained within the temperaturelimit, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to restore a CRACWS train to OPERABLE status. This CompletionTime is reasonable considering that the control room temperature is being maintained withinlimits and the low probability of an event occurring requiring control room isolation.The condition is modified by a Note stating it is not applicable when the second CRACWS train isintentionally made inoperable. This Required Action is not intended for voluntary removal ofredundant systems or components from service. The Required Action is only applicable if oneCRACWS train is inoperable for any reason and a second CRACWS train is found to beinoperable, or if two CRACWS trains are found to be inoperable at the same time.
CRACWSB 3.7.11BASESACTIONS (continueIIi an C 1asscae Itrain s)/In MODE 1, 2, 3, or 4, if the inoperab .,<RACWS tr cannot berestored to OPERABLE status within the Completion Time, theunit must be placed in a MODE that minimizes the risk. To achieve thisstatus, 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 inMODE 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 experience, to reach the required unit conditions fromfull power conditions in an orderly manner and without challenging unitsystems..l and D.In MODE 5 or 6, or during movement of recently irradiated fuel, if theinoperable CRACWS train cannot be restored to OPERABLE statuswithin the required Completion Time, the OPERABLE CRACWS trainmust be placed in operation immediately. This action ensures that theremaining train is OPERABLE, and that active failures will be readilydetected.An alternative to Required Action is to immediately suspendactivities that present a potential for releasing radioactivity. This placesthe unit in a condition that minimizes accident risk. This does notpreclude th-' ma~,,-m-,rt i'f f, ,--I ta =- nn~itiAnI if Required Actions B.1 or B.2 cannot bemet within the required Completion TimesI* IIn MODE 5or 6,or urn moeeto eetyirradiated fuelassemblies, wihtf RCSt'lq ,o~sle, action must be takenimmediately to suspend activities that could result in a release ofradioactivity. This places the unit in a condition that minimizes risk. Thisdoes not preclude the movement of fuel to a safe position.It hnth CRAPW~ trnir.~ ~IIIUperabIlU MODIIEJ~l 1,2, 3, Ul 4', tllr:: rwII Igr..om........ma..not c ....bl cf p6-o-~F tg ,n ftllded ['urLiuunI.Therefore, LCOJ 3.U.3 must be entered Immediately.Catawba Units I and 2B3.113evsoNoB 3.7.11-3Revision CRACWSB 3.7.11BASESSURVEILLANCE SR 3.7.11.1REQUI REMENTSThis SR verifies that the heat removal capability of the system is sufficientto maintain the temperature in the control room at or below 90°F. TheSurveillance Frequency is based on operating experience, equipmentreliability, and plant risk and is controlled under the SurveillanceFrequency Control Program.REFERENCES1. UFSAR, Section 9.4.2. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).3. 10 CFR 50.67, Accident source term.4. Regulatory Guide 1.183, Revision 0.Catawba Units 1 and 2 B371- eiinNAB 3.7.11-4Revision No./,3/