RA-18-0015, Supplement to License Amendment Request Proposing Changes to Catawba and McGuire Technical Specification 3.8.1, AC Sources - Operating.

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Supplement to License Amendment Request Proposing Changes to Catawba and McGuire Technical Specification 3.8.1, AC Sources - Operating.
ML18191A500
Person / Time
Site: Mcguire, McGuire  Duke energy icon.png
Issue date: 07/10/2018
From: Capps S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18192A002 List:
References
RA-18-0015
Download: ML18191A500 (41)


Text

( ~ DUKE StEM!lrn CclpRJS

~ ENERGY. 526 S. Chum:h Sllreet OtaJtotte. NC 28202 Manr:ng Address:

IE001H II l?.O. Box 1000 Ctrarlotte. NC 28202 960.373.1295 Saeirn.caws@duke-energy.com Serial: RA-18-0015 10 CFR 50.90 July 10, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 MCGUIRE NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-369 AND 50-370 RENEWED LICENSE NOS. NPF-9 AND NPF-17

SUBJECT:

SUPPLEMENT TO LICENSE AMENDMENT REQUEST PROPOSING CHANGES TO CATAWBA AND MCGUIRE TECHNICAL SPECIFICATION 3.8.1, "AC SOURCES - OPERATING"

REFERENCES:

1. Duke Energy letter, License Amendment Request Proposing Changes to Catawba and McGuire Technical Specification 3.8.1, AC Sources - Operating", dated May 2, 2017

{ADAMS Accession No. ML17122A116).

2. Nuclear Regulatory Commission letter, McGuire Nuclear Station, Units 1 and 2 and Catawba Nuclear Station, Units 1 and 2 - Supplemental Information Needed for Acceptance of Requested Licensing Action RE: License Amendment Request Proposing Changes to Technical Specification 3.8.1, AC Sources - Operating" (GAG Nos. MF9667 through MF9674, dated June 30, 2017 {ADAMS Accession No. ML17167A317).
3. Duke Energy letter, Supplement to License Amendment Request Proposing Changes to Catawba and McGuire Technical Specification 3.8.1, AC Sources - Operating", dated July 20, 2017 {ADAMS Accession No. ML172010132).
4. Nuclear Regulatory Commission letter, Catawba/McGuire - Acceptance of Requested Licensing Action Re: EOG AOT Extension/Shared Systems LAR (CACs MF9667 through MF9974), dated August 10, 2017 {ADAMS Accession No. ML17226A002).
5. Duke Energy letter, Supplement to License Amendment Request Proposing Changes to Catawba and McGuire Technical Specification 3.8.1, AC Sources - Operating", dated November 21, 2017 {ADAMS Accession No. ML17325A588).

U.S. Nuclear Regulatory Commission RA-18-0015 Page 2

6. Nuclear Regulatory Commission letter, Catawba/McGuire - Regulatory Audit to Support Commission Approval of Proposed Amendments for Changes to Technical Specifications 3.8.1, "AC Sources - Operating" and 3. 7.8, "Nuclear Service Water System" (CAC Nos. MF9667, MF9668, MF9671, MF9672, MG0245, and MG0246),

dated May 2, 2017 (ADAMS Accession No. ML18117A187).

Ladies and Gentlemen:

By letter dated May 2, 2017 (Reference 1), Duke Energy Carolinas, LLC (Duke Energy) submitted a License Amendment Request (LAR) for Catawba Nuclear Station (CNS), Units 1 and 2 and McGuire Nuclear Station (MNS), Units 1 and 2. The proposed change would extend the Completion Time for an inoperable diesel generator in Technical Specification {TS) 3.8.1, "AC Sources - Operating" at both stations. The proposed change would also alter the AC power source operability requirements for the Nuclear Service Water System (NSWS), Control Room Area Ventilation System (CRAVS), Control Room Area Chilled Water System (CRACWS) and Auxiliary Building Filtered Ventilation Exhaust System (ABFVES) (i.e., shared systems).

By letter dated June 30, 2017 (Reference 2), the Nuclear Regulatory Commission (NRC) requested supplemental information from Duke Energy. By letter dated July 20, 2017 (Reference 3), Duke Energy provided responses to the supplemental information request. The NRC concluded that Duke Energy did provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment by letter dated August 10, 2017 (Reference 4).

Subsequent to a public meeting on September 20, 2017 held between Duke Energy and the NRC staff to discuss the proposed change, Duke Energy provided a supplement to the LAR with revisions to the portion of the proposed change associated with AC power source operability requirements for shared systems (Reference 5). Specifically, two new Limiting Conditions for Operation (LCO) were proposed to be added to CNS and MNS TS 3.8.1. As a result of discussions between Duke Energy and the NRC staff during an audit of the subject LAR for CNS and MNS, Duke Energy is further supplementing the LAR in the Enclosure to this letter to revise the proposed TS 3.8.1 LCOs and corresponding Conditions (MNS only) to adequately reflect the equipment required to be operable. Additionally, this supplement addresses the Requests for Additional Information (RAI) questions discussed during the audit (Reference 6),

applicable to MNS only. A supplement addressing the CNS RAI questions will be provided separately.

Attachment 1 provides revised TS markups for MNS to reflect the proposed change.

Attachment 2 provides MNS TS Bases pages marked up (for information only). The TS Bases changes will be processed after LAR approval under the TS Bases Control Program for MNS.

Attachment 3 provides the Duke Energy responses to the MNS NRC RAls. Since one regulatory commitment is being added to support the proposed change, Attachment 4 provides the comprehensive list of regulatory commitments that are associated with the subject LAR.

U.S. Nuclear Regulatory Commission RA-18-0015 Page 3 The conclusions of the original Significant Hazards Consideration Determination and Environmental Considerations contained in the May 2, 2017 LAR (Reference 1) are unaffected as a result of this LAR supplement.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba at 980-373-2062.

,o, I declare under penalty of ~rjury that the foregoing is true and correct. Executed on

~\~ aor~ .

Sincerely, Steven Capps Senior Vice President, Nuclear Corporate

Enclosure:

License Amendment Request Supplemental Information Attachments:

1. Revised McGuire Technical Specification Marked Up Pages
2. Revised McGuire Technical Specification 3.8.1 Bases Marked Up Pages (For Information Only)
3. Response to NRC Request for Additional Information (MNS only)
4. Regulatory Commitments

U.S. Nuclear Regulatory Commission RA-18-0015 Page4 cc:

C. Haney, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 M. Mahoney, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 G.A. Hutto NRC Senior Resident Inspector McGuire Nuclear Station W .L. Cox, Ill, Section Chief Div. of Environmental Health, RP Section NC Dept. of Env. & Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 1 of 15 Enclosure License Amendment Request Supplemental Information

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 2 of 15

1. DESCRIPTION OF THE PROPOSED CHANGE (REVISED)

The proposed change submitted November 21, 2017 (ADAMS Accession No. ML17325A588) to modify Catawba (CNS) and McGuire Nuclear Station (MNS) Technical Specification (TS) 3.8.1, "AC Sources - Operating," is being revised in the following sections, for MNS only, to reflect the sufficient amount of AC sources that are required to be operable at each station in order to mitigate a design basis accident (i.e., Loss of Coolant Accident on one unit and a dual-unit Loss of Offsite Power). The corresponding Conditions are also proposed to be revised for MNS. The changes that are presented in this Enclosure and that are also reflected in Attachment 1, supersede the requested MNS TS 3.8.1 changes from the November 21, 2017 License Amendment Request supplement submittal entirely.

As noted in the November 21, 2017 submittal, the TS revisions presented below for MNS are still similar in content and structure to TS 3.8.1, "AC Sources - Operating" for Calvert Cliffs Nuclear Power Plant.

Note: The requirement for shared systems to have both an operable normal and emergency power supply in order to be considered operable is still proposed to be deleted from the MNS TS Bases.

1.1 McGuire Technical Specification 3.8.1 Change Request contains MNS TS 3.8.1 markups that reflect the proposed change and will be revised as follows:

A new LCO 3.8.1.c is added that states: "The qualified circuit(s) between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System necessary to supply power to the Nuclear Service Water System (NSWS), Control Room Area Ventilation System (CRAVS), Control Room Area Chilled Water System (CRACWS) and Auxiliary Building Filtered Ventilation Exhaust System (ABFVES); and" A new LCO 3.8.1.d is added that states: "The DG(s) from the opposite unit necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES;"

A Note is added to the APPLICABILITY that states: "The opposite unit electrical power sources in LCO 3.8.1.c and LCO 3.8.1.d are not required to be OPERABLE when the associated shared systems are inoperable."

Condition A is revised to state: "One LCO 3.8.1.a offsite circuit inoperable."

Required Action A.1 is revised to state: "Perform SR 3.8.1.1 for required OPERABLE offsite circuit(s)."

The Completion Time (CT} for existing RA A.3 is revised to state:

"72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 3 of 15 17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.1.b" Condition B is revised to state: "One LCO 3.8.1.b DG inoperable."

A new RA B.1 with an "AND" connector and associated CT are inserted as follows:

B.1 Verify LCO 3.8.1.d DG(s) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OPERABLE.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter The existing RA B.1 is renamed "B.2" and is revised to state: "Perform SR 3.8.1.1 for the required offsite circuit(s)."

The existing RA B.2 is renamed "B.3."

The existing RA B.3.1 is renamed "B.4.1" and is revised to state: "Determine OPERABLE DG(s) is not inoperable due to common cause failure."

The existing RA B.3.2 is renamed "B.4.2" and is revised to state: "Perform SR 3.8.1.2 for OPERABLE DG(s)."

A new RA B.5 with an "AND" connector and associated CT are inserted as follows:

B.5 Ensure availability of Prior to entering the Emergency Supplemental extended Completion Power Source (ESPS). Time of ACTION B.6 Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 4 of 15 The existing RA 8.4 is renamed "8.6." The associated CT is revised to state:

"72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from discovery of unavailable ESPS**

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of unavailable ESPS when in extended Completion Time 14 days 17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.1.b" New Condition C and associated RAs and CT is added as follows:

c. Required Action and C.1.1 Restore LCO 3.8.1.d DG to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> associated Completion OPERABLE status.

Time of Required Action 8.1 not met. OR C.1.2 Restore LCO 3.8.1.b DG to OPERABLE status.

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 5 of 15 New Condition D and associated RAs and CTs is added as follows:

D. One LCO 3.8.1.c offsite -----NOTE-----

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems-Operating," when Condition Dis entered with no AC power source to a train.

D.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND D.2 Declare NSWS, CRAVS, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from CRACWS or ABFVES with discovery of no no offsite power available offsite power to one inoperable when the train concurrent with redundant NSWS, CRAVS, inoperability of CRACWS or ABFVES is redundant required inoperable. feature(s)

AND D.3 Declare NSWS, CRAVS, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CRACWS and ABFVES supported by the inoperable offsite circuit inoperable.

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 6 of 15 New Condition E and associated RAs and CTs is added as follows:

E. One LCO 3.8.1.d DG ----NOTE----

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems-Operating," when Condition Eis entered with no AC power source to a train.

E.1 Verify both LCO 3.8.1.b 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> DGs OPERABLE and ESPS available.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND E.2 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND E.3 Declare NSWS, CRAVS, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from CRACWS or ABFVES discovery of supported by the Condition E inoperable DG inoperable concurrent with when the redundant inoperability of NSWS, CRAVS, CRACWS redundant required or ABFVES is inoperable. feature(s)

AND

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 7 of 15 E. (continued) E.4.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG( s) is not inoperable due to common cause failures.

E.4.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DG(s).

E.5 Declare NSWS, CRAVS, 14 days CRACWS and ABFVES supported by the inoperable DG inoperable.

New Condition F and associated RAs and CT is added as follows:

F. Required Action and F .1.1 Restore both LCO 3.8.1.b 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> associated Completion DGs to OPERABLE status Time of Required Action and ESPS to available E.1 not met. status.

OR F.1.2 Restore LCO 3.8.1.d DG to OPERABLE status.

OR F .1.3 Declare NSWS, CRAVS, CRACWS and ABFVES supported by the inoperable DG inoperable.

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 8 of 15 Existing Condition C is renamed "G" and is revised to state:

"Two LCO 3.8.1.a offsite circuits inoperable.

One LCO 3.8.1.a offsite circuit that provides power to the NSWS, CRAVS, CRACWS and ABFVES inoperable and one LCO 3.8.1.c offsite circuit inoperable.

OR Two LCO 3.8.1.c offsite circuits inoperable."

Existing RA C.1 is renamed "G.1" and the associated CT is revised to state: "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of Condition G concurrent with inoperability of redundant required features" Existing RA C.2 is renamed "G.2."

Existing Condition D is renamed "H" and is revised to state:

"One LCO 3.8.1.a offsite circuit inoperable.

One LCO 3.8.1.b DG inoperable."

The Note above existing RA D.1 is revised to state: "Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating," when Condition H is entered with no AC power source to any train."

Existing RA D.1 is renamed "H.1" and existing RA D.2 is renamed "H.2."

Existing Condition E is renamed "I" and is revised to state:

"Two LCO 3.8.1.b DGs inoperable.

OR LCO 3.8.1.b DG that provides power to the NSWS, CRAVS, CRACWS and ABFVES inoperable and one LCO 3.8.1.d DG inoperable.

OR Two LCO 3.8.1.d DGs inoperable."

Existing RA E.1 is renamed "1.1."

Existing Condition Fis renamed "J." Existing RA F.1 is renamed "J.1."

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 9 of 15 Existing Condition G is renamed "K" and is revised to state:

"Required Action and associated Completion Time of Condition A, C, F, G, H, I, or J not met.

OR Required Action and associated Completion Time of Required Action B.2, B.3, B.4.1, B.4.2, or 8.6 not met.

OR Required Action and associated Completion Time of Required Action E.2, E.3, E.4.1, E.4.2, or E.5 not met."

Existing RA G.1 is renamed "K.1." Existing RA G.2 is renamed "K.2."

Existing Condition H is renamed "L" and is revised to state:

"Three or more LCO 3.8.1.a and LCO 3.8.1.b AC sources inoperable.

OR Three or more LCO 3.8.1.c and LCO 3.8.1.d AC sources inoperable."

Existing RA H.1 is renamed "L.1."

A new NOTE is added at the beginning of the SURVEILLANCE REQUIREMENTS section of TS 3.8.1 which states: "SR 3.8.1.1 through SR 3.8.1.20 are only applicable to LCO 3.8.1.a and LCO 3.8.1.b AC sources. SR 3.8.1.21 is only applicable to LCO 3.8.1.c and LCO 3.8.1.d AC sources."

SR 3.8.1.21 For the LCO 3.8.1.c and LCO 3.8.1.d AC electrical In accordance with sources, SR 3.8.1.1, SR 3.8.1.2, SR 3.8.1.4, SR 3.8.1.5, the Surveillance and SR 3.8.1.6 are required to be met. Frequency Control Program

2. TECHNICAL EVALUATION 2.1 McGuire Evaluation of the TS 3.8.1 Change Request In order to continue to meet Criterion 3 of 10 CFR 50.36 with the removal of the requirement from the MNS TS Bases to maintain both normal and emergency power for operability of the shared systems (NSWS, CRAVS, CRACWS and ABFVES}, the opposite unit's AC power

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 10 of 15 sources that are necessary to support the NSWS, CRAVS, CRACWS and ABFVES are incorporated into TS 3.8.1 within new LCOs 3.8.1.c and 3.8.1.d. Each train of NSWS, CRAVS, CRACWS and ABFVES is connected to an onsite Class 1E electrical power distribution subsystem from either unit. The word "necessary" used in LCO 3.8.1.c and LCO 3.8.1.d clarifies that the respective AC power source is aligned to the opposite unit Onsite Essential Auxiliary Power System that is supplying power to a train of shared systems. For example, in a normal alignment at MNS, Unit 1 Essential Bus 1ETA supplies Train A of shared systems and Unit 2 Essential Bus 2ETB supplies Train B of shared systems. Thus for this normal plant configuration, the 2B offsite circuit and 2B DG, both of which supply power to 2ETB, would be LCO 3.8.1.c and LCO 3.8.1.d AC sources for Unit 1 TS 3.8.1. Similarly, the 1A offsite circuit and 1A DG, both of which supply power to 1ETA, would be LCO 3.8.1.c and LCO 3.8.1.d AC sources for Unit 2 TS 3.8.1. However, since the 2A offsite circuit and 2A DG are not necessary to supply power to a train of shared systems in the normal plant configuration, they would not be LCO 3.8.1.c and LCO 3.8.1.d AC sources. And since the 1B offsite circuit and 1B DG are not necessary to supply power to a train of shared systems in the normal plant configuration, they would not be LCO 3.8.1.c and LCO 3.8.1.d AC sources. It is important to note that if desired or required to maintain operability, Train A shared equipment can be swapped to receive power from Unit 2 Essential Bus 2ETA. Similarly, Train B shared equipment can be swapped to receive power from Unit 1 Essential Bus 1ETB.

Another example using an off-normal plant configuration also demonstrates how the requirements of 10 CFR 50.36 are satisfied for the proposed TS 3.8.1. When Unit 1 Essential Bus 1ETA supplies Train A shared systems and Unit 1 Essential Bus 1ETB supplies Train B shared systems, the 1A offsite circuit and 1B offsite circuit would both be LCO 3.8.1.c AC sources for Unit 2 TS 3.8.1. The 1A DG and 1B DG would both be LCO 3.8.1.d AC sources for Unit 2 TS 3.8.1. Similarly, when Unit 2 Essential Bus 2ETA supplies Train A shared systems and Unit 2 Essential Bus 2ETB supplies Train B shared systems, the 2A offsite circuit and 2B offsite circuit would both be LCO 3.8.1.c AC sources for Unit 1 TS 3.8.1. The 2A DG and 2B DG would both be LCO 3.8.1.d AC sources for Unit 1 TS 3.8.1.

The Note that is added to the Applicability section takes exception to the requirements for the required AC sources in LCO 3.8.1.c and LCO 3.8.1.d provided the associated shared systems are inoperable. This exception is intended to allow declaring the shared systems supported by the opposite unit inoperable either in lieu of declaring the LCO 3.8.1.c and LCO 3.8.1.d AC sources inoperable, or at any time subsequent to entering ACTIONS for an inoperable LCO 3.8.1.c or LCO 3.8.1.d AC source. This exception is acceptable since, with the shared systems supported by the opposite unit inoperable and the associated ACTIONS entered, the LCO 3.8.1.c and LCO 3.8.1.d AC sources provide no additional assurance that acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of abnormal transients and also provide no additional assurance that adequate core cooling is provided and containment operability and other vital functions are maintained in the event of a postulated design basis accident (OBA).

The primary need for the Note is during Engineered Safeguards Features (ESF) testing. The testing is performed when one unit is in Modes 1 through 4 and the other unit is shutdown. A single train of shared systems (NSWS, CRAVS, CRACWS and ABFVES) is aligned to the outage unit. In this instance, the outage unit AC sources cannot support operability of the train of shared systems for the online unit. The Applicability Note allows McGuire to declare the entire train of shared systems (NSWS, CRAVS, CRACWS and ABFES) inoperable in lieu of applying proposed LCOs 3.8.1.c and 3.8.1.d for the online unit.

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 11 of 15 Adding "LCO 3.8.1.a" to Condition A clarifies that the Condition pertains to a qualified circuit between the offsite transmission network and the Onsite Essential Auxiliary Power System rather than a qualified circuit between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System.

Changing "OPERABLE offsite circuit" to "required OPERABLE offsite circuit(s)" in RA A.1 reflects that it could be necessary to verify the operability of more than one offsite circuit when a LCO 3.8.1.a offsite circuit is inoperable, since an offsite circuit may be aligned to the opposite unit On.site Essential Auxiliary Power System that is supplying power to a train of the NSWS, CRAVS, CRACWS and ABFVES (i.e., a LCO 3.8.1.c offsite circuit).

The proposed maximum CT of 17 days for RA A.3 limits the total time that LCO 3.8.1.a or LCO 3.8.1.b is not met while concurrently or simultaneously in Conditions A and B. The existing CT is the sum of the CT for RA A.3 (i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and existing RA B.4 (i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). MNS is proposing to increase the CT for existing RA B.4 to 14 days; thus the maximum CT for RA A.3 will be increased from 6 days to 17 days.

Adding "LCO 3.8.1.b" to Condition B clarifies that the Condition pertains to a unit-specific DG rather than a DG from the opposite unit necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES.

New RA B.1 provides assurance that the LCO 3.8.1.d DG is operable when a LCO 3.8.1.b DG is inoperable.

Renaming RAs B.1, B.2, B.3.1, B.3.2 and B.4 are administrative changes.

"OPERABLE DG" is changed to "OPERABLE DG(s)" in new RAs B.4.1 and B.4.2 to reflect that the RAs are to be performed for a LCO 3.8.1.d DG in addition to the OPERABLE LCO 3.8.1.b DG.

New RA B.5 is added as a prerequisite for entering the extended CT of new RA B.6 (i.e., 14 days). As specified in the TS Bases markups (Attachment 2), Emergency Supplemental Power Source (ESPS) availability requires that:

1. The load test has been performed within 30 days of entry into the extended CT.
2. The ESPS fuel tank is verified locally to be greater than or equal to a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> supply.
3. The ESPS supporting system parameters for starting and operating are verified to be within limits for functional availability (e.g., battery state of charge).

The CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from discovery of unavailable ESPS of new RA 8.6 (formerly RA 8.4) is based on the existing CT for an inoperable DG. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT of new RA B.6 is based on Branch Technical Position 8-8 and indicates that if the ESPS unavailability occurs sometime after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of continuous DG inoperability (i.e., after entering the extended CT for an inoperable DG), then the remaining time to restore the ESPS to available status or restore the DG to operable status is limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 14 day CT of new RA B.6 is in accordance with Branch Technical Position 8-8, which indicates that operation may continue when a DG is inoperable for a period that should not exceed 14 days, provided a supplemental AC power source is available. The ESPS is the supplemental AC power source for MNS. The 17 day CT of new RA B.6 limits the total time that LCO 3.8.1.a or LCO 3.8.1.b is not met while concurrently or simultaneously in Conditions A and B. The existing CT is the sum of the CT for RA A.3 (i.e.,

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and existing RA B.4 (i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). MNS is proposing to increase the CT for existing

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 12 of 15 RA 8.4 to 14 days; thus the maximum CT for new RA 8.6 will be increased from 6 days to 17 days.

New Condition C reflects that with a LCO 3.8.1.d DG inoperable, the remaining operable unit-specific DG and the required offsite circuits are adequate to supply power to the onsite Class 1E Distribution System. The CT of new RAs C.1.1 and C.1.2 are in accordance with Regulatory Guide 1.93, which indicates operation may continue in this condition for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT takes into account the capacity and capability of the remaining AC power sources, a reasonable time for repairs and the low probability of a DBA occurring during the period.

New Condition D is added for one inoperable qualified circuit between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES. The Note above new RA D.1 indicates that when Condition D is entered with no AC source to a train, the Conditions and RAs for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows new Condition D to provide requirements for the loss of a LCO 3.8.1.c offsite circuit and LCO 3.8.1.d DG without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

New RA D.1 ensures a highly reliable power source remains with the one necessary LCO 3.8.1.c offsite circuit ("necessary" only when the offsite circuit is aligned to the opposite unit Onsite Essential Auxiliary Power System that is supplying power to a train of the NSWS, CRAVS, CRACWS and ABFVES) inoperable by verifying the operability of the remaining required offsite circuits. The CT for new RA D.1 is consistent with NUREG-1431 and the CT for existing RA A.1.

New RA D.2 only applies if the train cannot be powered from an offsite source and is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function for the NSWS, CRAVS, CRACWS or the ABFVES.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT for new RA D.2 is considered acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining operable offsite circuits and DGs are adequate in this condition to supply power to the Class 1E Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT also takes into account the component operability of the redundant counterpart to the inoperable NSWS, CRAVS, CRACWS or ABFVES, the capacity and capability of the remaining AC sources, a reasonable time for repairs and the low probability of a DBA occurring during this period.

New RA D.3 reflects that if the inoperable qualified circuit between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES cannot be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then the NSWS, CRAVS, CRACWS and ABFVES components associated with the inoperable offsite circuit must be declared inoperable. The ACTIONS associated with the LCOs for those shared systems will ensure that appropriate action is taken. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT for new RA D.3 takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs and the low probability of a DBA occurring during this period.

  • New Condition E is added for one opposite unit DG necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES inoperable. The Note above new RA E.1 indicates that when Condition E is entered with no AC source to a train, the Conditions and RAs for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows new Condition E

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 13 of 15 to provide requirements for the loss of a LCO 3.8.1.c offsite circuit and LCO 3.8.1.d DG without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

The new RA E.1 to verify both unit-specific DGs are operable and the ESPS is available forms the basis for the 14 day CT of new RA E.5. The verification in this RA provides assurance that the LCO 3.8.1.b safety-related DGs and the ESPS are capable of supplying the Class 1E AC Electrical Power Distribution System.

New RA E.2 ensures a highly reliable power source remains with the one necessary LCO 3.8.1.d DG ("necessary" only when the DG is aligned to the opposite unit Onsite Essential Auxiliary Power System that is supplying power to a train of the NSWS, CRAVS, CRACWS and ABFVES) inoperable by verifying the operability of the remaining required offsite circuits. The CT for new RA E.2 is consistent with NUREG-1431 and the CT for existing RA A.1.

New RA E.3 is intended to provide assurance that a loss of offsite power, during the period a LCO 3.8.1.d DG is inoperable, does not result in a complete loss of safety function for the NSWS, CRAVS, CRACWS or the ABFVES. Four hours (i.e., the CT for new RA E.3) from discovering the LCO 3.8.1.d DG inoperable coincident with one train of NSWS, CRAVS, CRACWS or ABFVES inoperable that is associated with the other train that has emergency power is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The four hour CT also takes into account the capacity and capability of the remaining NSWS, CRAVS, CRACWS and ABFVES train, a realistic time for repairs and the low probability of a OBA occurring during this period.

The remaining operable DGs and offsite circuits are adequate in this condition to supply electrical power to the onsite Class 1E Distribution System.

New RA E.4.1 provides an allowance to avoid unnecessary testing of operable DGs. If it can be determined that the cause of the inoperable LCO 3.8.1.d DG (opposite unit DG necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES) does not exist on the operable DGs, then SR 3.8.1.2 does not have to be performed. In accordance with new RA E.4.2, if the cause of the initial inoperable LCO 3.8.1.d DG cannot be confirmed not to exist on the remaining DGs, then performance of SR 3.8.1.2 suffices to provide assurance of continued operability of the DGs. According to Generic Letter 84-15, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT is reasonable to confirm that the operable DGs are not affected by the same problem as the inoperable LCO 3.8.1.d DG.

New RA E.5 reflects that if the opposite unit DG that is needed to supply power to the NSWS, CRAVS, CRACWS and ABFVES cannot be restored to operable status within 14 days, then the NSWS, CRAVS, CRACWS and ABFVES components associated with the inoperable DG must be declared inoperable. The Actions associated with the NSWS, CRAVS, CRACWS and ABFVES will ensure the appropriate actions are taken. The CT of 14 days is justified by new RA E.1 (verify both unit-specific DGs are operable and the ESPS is available). The 14 day CT is also consistent with the proposed CT in ACTION B when ESPS is available.

New Condition F is added to indicate that with an additional LCO 3.8.1.b safety-related DG inoperable or the ESPS unavailable, the remaining operable LCO 3.8.1.b DG and qualified circuits are adequate to supply electrical power to the onsite Class 1E Distribution System.

New RA F.1.1 is provided to restore both of the unit-specific DGs to operable and the ESPS to available. New RA F.1.2 is provided to restore the LCO 3.8.1.d DG to operable. Either of the

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 14 of 15 new RAs F.1.1 and F .1.2 must be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT for RAs F .1.1 and F .1.2 is consistent with Regulatory Guide 1.93. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT also takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs and the low probability of a DBA occurring during the period.

New RA F .1.3 reflects that if the opposite unit DG that is necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES cannot be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then the NSWS, CRAVS, CRACWS and ABFVES components associated with the inoperable DG must be declared inoperable. The ACTIONS associated with the LCOs for those shared systems will ensure that appropriate action is taken. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT for new RA F.1.3 takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs and the low probability of a DBA occurring during this period.

Renaming Condition C to Condition G is an administrative change. Adding "LCO 3.8.1.a" to new Condition G clarifies that the portion of the Condition pertains to the qualified circuits between the offsite transmission network and the Onsite Essential Auxiliary Power System rather than a qualified circuit between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System. The second part of Condition G after the "OR" connector is added to reflect when the offsite circuit required by LCO 3.8.1.c and one offsite circuit required by LCO 3.8.1.a are concurrently inoperable, if the LCO 3.8.1.a offsite circuit is credited with providing power to the NSWS, CRAVS, CRACWS and ABFVES. The third part of Condition G after the "OR" connector is added to reflect when two offsite circuits required by LCO 3.8.1.c are inoperable. Two offsite circuits are required by LCO 3.8.1.c when both Train A shared systems and Train B shared systems are aligned to receive power from the same unit.

Renaming RAs C.1 and C.2 to G.1 and G.2 is an administrative change. Changing "Condition C" to "Condition G" in the CT for new RA G.1 is an administrative change.

Renaming Condition D to Condition H is an administrative change. Adding "LCO 3.8.1.a" and "LCO 3.8.1.b" to new Condition H clarifies that the Condition pertains to a qualified circuit between the offsite transmission network and the Onsite Essential Auxiliary Power System (rather than a qualified circuit between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System) and to a DG capable of supplying the Onsite Essential Auxiliary Power Systems (rather than a DG from the opposite unit necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES).

Changing "Condition D" to "Condition H" in the NOTE above new RA H.1 is an administrative change. Renaming RAs D.1 and D.2 to H.1. and H.2 is an administrative change.

Renaming Condition E to Condition I is administrative change. Adding "LCO 3.8.1.b" to new Condition I clarifies that the portion of the Condition pertains to the unit-specific DGs rather than a DG from the opposite unit necessary to supply power to the NSWS, CRAVS, CRACWS and ABFVES. The second part of Condition I after the "OR" connector is added to reflect that with one LCO 3.8.1.d DG inoperable and the LCO 3.8.1.b DG that provides power to the NSWS, CRAVS, CRACWS and ABFVES inoperable, there are no remaining standby AC sources to the NSWS, CRAVS, CRACWS and ABFVES. The third part of Condition I after the "OR" connector is added to reflect that with two DGs required by LCO 3.8.1.d inoperable, there are no remai.ning standby AC sources to the shared portions of the NSWS, CRAVS, CRACWS and ABFVES.

Two DGs are required by LCO 3.8.1.d when both Train A shared systems and Train B shared systems are aligned to receive power from the same unit.

U.S. Nuclear Regulatory Commission RA-18-0015, Enclosure Page 15 of 15 Renaming RA E.1 to 1.1 is an administrative change.

Renaming Condition F to Condition J is an administrative change. Renaming RA F .1 to J.1 is an administrative change.

Renaming Condition G to Condition K is an administrative change. All of the proposed revisions to new Condition K reflect instances where the RA and associated CT of a Condition ( or RA) are not met.

Renaming RAs G.1 and G.2 to K.1 and K.2 is an administrative change.

Renaming Condition H to Condition L is an administrative change. Adding "LCO 3.8.1.a and LCO 3.8.1.b" to new Condition L clarifies that the Condition corresponds to a level of degradation in which all redundancy in the unit-specific (i.e., LCO 3.8.1.a and LCO 3.8.1.b) AC electrical power supplies has been lost. The second part of Condition L after the "OR" connector is added to reflect that the Condition corresponds to a level of degradation in which all redundancy in LCO 3.8.1.c and LCO 3.8.1.d AC electrical power supplies has been lost.

Renaming RA H.1 to L.1 is an administrative change.

The new NOTE added to the SURVEILLANCE REQUIREMENTS section of MNS TS 3.8.1 clarifies that not all of the SRs are applicable to all the components described in the LCO.

New SR 3.8.1.21 lists the SRs that are applicable to new LCO 3.8.1.c and new LCO 3.8.1.d.

These SRs are 3.8.1.1, 3.8.1.2, 3.8.1.4, 3.8.1.5 and 3.8.1.6. The Frequency of new SR 3.8.1.21 is to be in accordance with the MNS Surveillance Frequency Control Program.

RA-18-0015 Attachment 1 McGuire Technical Specification Marked Up Pages

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

a. Two qualified circuits between the offsite transmission network and the Onsite Essential Auxiliary Power System; and
b. Two diesel generators (DGs) capable of supplying the Onsite Essential Auxiliary Power Systems; and

£=. The qualified circuit(s) between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System necessary to supply power to the Nuclear Service Water System (NSWS), Control Room Area Ventilation System (CRA VS), Control Room Area Chilled Water System (CRACWS) and Auxiliary Building Filtered Ventilation Exhaust System (ABFVES): and

d. The DG(s) from the opposite unit necessary to supply power to the NSWS, CRAVS, CRACWS and ABfVES:

The automatic load sequencers for Train A and Train B shall be OPERABLE.

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


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

The opposite unit electrical power sources in LCO 3.8.1.c and LCO 3.8.1.d are not required to be OPERABLE when the associated shared systems are inoperable.

McGuire Units 1 and 2 3.8.1-1 Amendment No. 221/20a

AC Sources - Operating 3.8.1 ACTIONS


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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One LCO 3.8.1.a offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> circuit inoperable. required OPERABLE offsite circuit.{§}. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from A.2 Declare required feature(s) discovery of no with no offsite power offsite power to one available inoperable when train concurrent with its redundant required inoperability of feature(s) is inoperable. redundant required feature(s)

A.3 Restore offsite circuit to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

G17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.1.b McGuire Units 1 and 2 3.8.1-2 Amendment No. 221/203

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One LCO 3.8.1.b DG B.~ Verifv tLCO 3.8.1.d DG(s} 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable OPERABLE.

AND Once 12er 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND BA-l Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND B.2~ Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature( s) is inoperability of inoperable. redundant required feature(s)

B.~ .1 Determine OPERABLE 24 h,ours DG{fil_is not inoperable due to common cause failure.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B.~ .2 Perform SR 3.8.1.2 for OPERABLE DG.(fil.

(continued)

McGuire Units 1 and 2 3.8.1-3 Amendment No. 184/166

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.5 Ensure availability of Prior to entering the Emergency Supplemental extended Completion Power Source (ESPS). Time of ACTION 8.6 Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter MB.6 Restore DG to OPERABLE 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from status. discovery of unavailable IESPS **

6 days from diSGO\<ery of fail~re to meet LCO 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of unavailable ESPS when in extended Completion Time 14 days 17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.1.b McGuire Units 1 and 2 3.8.1-4 Amendment No. 308/287

AC Sources - Operating 3.8.1 ACTIONS

c. Required Action and C.1.1 Restore LCO 3.8.1.d DG to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> associated Completion OPERABLE status.

Time of Required Action B.1 not met. OR C.1.2 Restore LCO 3.8.1.b DG to OPERABLE status.

D. One LCO 3.8.1.c offsite ----NOTE-----

circuit inoperable. Enter applicable Conditions and Required Actionis of LCO 3.8.9, "Distribution Systems - Operating,"

whem Condition D is entered with no AC power source to a train.

D.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reguired offsite circuit(s).

AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND 0.2 Declare NSWS, CRAVS, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from CRACWS or ABFVES with discover:v of no no offsite power available offsite power to one inoperable when the train concurrent with redundant NSWS 1 CRAVS, inoperability of CRACWS or ABFVES is redundant reguired inoperable. feature(s)

AND D.3 Declare NSWS, CRAVS, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CRACWS and ABFVES supported by the inoperable offsite circuit inoperable.

McGuire Units 1 and 2 3.8.1-5 Amendment No. 308/287

AC Sources - Operating 3.8.1 ACTIONS E. One LCO 3.8.1.d DG -----NOTE-----

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9.

"Distribution Systems - Operating."

when Condition E is entered with no AC power source to a train.

E.1 Verify both LCO 3.8.1 .b

  • Gs OPE~BLE and ESPS available.

Once per 12 h ours thereafter E.2 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required offsite circuit{s).

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND E.3 Declare NSWS. CRAVS. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from CRACWS or ABFVES discovery of supported by the Condition E inoperable DG inoperable concurrent with when the redundant inoperability of NSWS, CRAVS. CRACWS redundant required or ABFVES is inoperable. feature{s)

{continued)

McGuire Units 1 and 2 3.8.1-6 Amendment No. 308/287

AC Sources - Operating 3.8.1 ACTIONS E. (continued) E.4.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DG(s) is not inoperable due to common cause failures.

OR E.4.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE DG(s).

E.5 Declare NSWS, CRAVS, 14 days CRACWS and ABFVES supported by the inoperable DG inoperable.

F. Required Action and F.1.1 Restore both LCO 3.8.1.b 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> associated Completion DGs to OPERABLE status Time of Required Action and IESPS to available E.1 not met. status.

OR F.1.2 Restore LCO 3.8.1.d DG to OPERABLE status.

OR F.1.3 Declare NSWS, CRAVS, CRACWS and ABFVES supported by the inoperable DG inoperable.

McGuire Units 1 and 2 3.8.1-7 Amendment No. 308/287

AC Sources - Operating 3.8.1 ACTIONS GG. Two LCO 3.8.1.a offsite GG.1 Declare required feature(s) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from circuits inoperable. inoperable when its discovery of redundant required Condition GG feature(s) is inoperable. concurrent with inoperability of One LCO 3.8.1.a offsite redundant required circuit that provides feature(s) power to the NSWS.

CRAVS. CRACWS and ABFVES inoperable and one LCO 3.8.1.c offsite GG.2 Restore one offsite circuit 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> circuit inoperable. to OPERABLE status.

OR Two LOO 3.8.1.c offsite circuits imoperable.

( continued)

    • 'A' Train EDGs are allowed to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activUy, or by March 31, 2019, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures as described in MNS LAR submittal correspondence letter MNS-17-031.

McGuire Units 1 and 2 3.8.1-8 Amendment No. 308/287

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME GH. One LCO 3.8.1.a offsite NOTE circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems -

Operating," when Condition GH is One LCO 3.8.1.b DG entered with no AC power source inoperable. to any train.

GH. 1 Restore offsite circuit to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OPERABLE status.

OR DH.2 Restore DG to OPERABLE 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> status.

!. Two LCO 3.8.1.b DGs  !.1 Restore one DG to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Inoperable. OPERABLE status.

OR LCO .3.8.1.b DG that Qrovides Qower to the NSWSI CRAVSI CRACWS and ABFVES inoQerable and one LCO 3.8.1.d DG inoQerable.

OR Two LCO 3.8.1.d DGs inoQerable.

~- One automatic load F4.1 Restore automatic load 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> sequencer inoperable. sequencer to OPERABLE status.

McGuire Units 1 and 2 3.8.1-9 Amendment No. 184/166

AC Sources - Operating 3.8.1 ACTIONS (continued)

G!S. Required Action and G!S.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, 8,- AND C, D, E, or~ F . G. H. 1.

or J not met. G}S.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Reguired Action and associated Com1;2letion liirme of Reguired Action B.'2 1 8.3. 8.4.1.

18.4.2. or lB.6 not met.

OR IReguired Action and associated Com1;2letion T1ime of Heguired Action E.2. lE.3.

E.4.1. E.4.2. or E.5 not met.

tt,b. Three or more LCO W,b. 1 Enter LCO 3.0.3. Immediately 3.8.1.a and LCO 3.8.1.b AC sources inoperable.

OR Three or more LCO 3.8.1.c and LCO 3.8.1.d AC sources ino1;2erable.

McGuire Units 1 and 2 3.8.1-10 Amendment No. 184/166

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS


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

SR 3.8.1 .1 through SR 3.8.1.20 are only applicable to LCO 3.8.1.a and LCO 3.8.1.b AC sources. SR 3.8.1.21 is only applicable to LCO 3.8.1.c and LCO 3.8.1 .d AC sources.

SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 -------NOTES------

1. Performance of SR 3.8.1. 7 satisfies this SR.
2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.

When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1. 7 must be met.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage ~ 3740 V and s 4580 V, the Surveillance and frequency~ 58.8 Hz and s 61 .2 Hz. Frequency Control Program (continued)

McGuire Units 1 and 2 3.8.1-11 Amendment No. 261/241

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 --------NOTE~----------

1. DG loadings may include gradual loading as recommended by the manufacturer.
2. Momentary transients outside the load range do not invalidate this test.
3. This Surveillance shall be conducted on only one DG at a time.
4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded and operates In accordance with for ~ 60 minutes at a load ~ 3600 kW and :S 4000 kW. the Surveillance Frequency Control ProQram SR 3.8.1.4 Verify each day tank contains ~ 39 inches of fuel oil. In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each day In accordance with tank. the Surveillance .

Frequency Control ProQram SR 3.8.1.6 Verify the fuel oil transfer system operates to In accordance with automatically transfer fuel oil from storage tank to the day the Surveillance tank. Frequency Control Program (continued)

McGuire Units 1 and 2 3.8.1-12 Amendment No. 261/241

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.7 --------NOTE~--------

AII DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and In accordance with achieves in ::;; 11 seconds voltage of ~ 3740 V and the Surveillance frequency of ~ 57 Hz and maintains steady state voltage Frequency Control

~ 37 40 V and ::;; 4580 V, and frequency~ 58.8 Hz and Program

61.2 Hz.

SR 3.8.1.8 - - - - - - - N O T E . , __ _ _ _ _ __

This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify automatic and manual transfer of AC power In accordance with sources from the normal offsite circuit to each alternate the Surveillance offsite circuit. Frequency Control Pro ram

( continued)

McGuire Units 1 and 2 3.8.1-13 Amendment No. 300/279

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 Verify each DG, when connected to its bus in parallel with In accordance with offsite power and operating with maximum kVAR loading the Surveillance that offsite power conditions permit, rejects a load greater Frequency Control than or equal to its associated single largest post- Program accident load, and:

a. Following load rejection, the frequency is~ 63 Hz;
b. Within 3 seconds following load rejection, the voltage is ~ 3740 V and ~ 4580 V; and
c. Within 3 seconds following load rejection, the frequency is ~ 58.8 Hz and ~ 61.2 Hz.

SR 3.8.1.10 Verify each DG does not trip and voltage is maintained In accordance with

~ 4 784 V during and following a load rejection of the Surveillance

~ 3600 kW and ~ 4000 kW. Frequency Control Program (continued)

McGuire Units 1 and 2 3.8.1-14 Amendment No. 261/241

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.11 --------NOTE-----------

1. AII DG starts may be preceded by an engine prelube period.
2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power In accordance with signal: the Surveillance Frequency Control

a. De-energization of emergency buses; Program
b. Load shedding from emergency buses;
c. DG auto-starts from standby condition and:
1. energizes the emergency bus in
11 seconds,
2. energizes auto-connected blackout loads through automatic load sequencer.,
3. maintains steady state voltage

~ 3740 Vand:::;; 4580 V,

4. maintains steady state frequency

~ 58.8 Hz and :::;; 61.2 Hz, and

5. supplies auto-connected blackout loads for

~ 5 minutes.

(continued)

McGuire Units 1 and 2 3.8.1-15 Amendment No. 300/279

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.12 --------NOTE~--------

AII DG starts may be preceded by prelube period.

Verify on an actual or simulated Engineered Safety In accordance with Feature (ESF) actuation signal each DG auto-starts from the Surveillance standby condition and: Frequency Control Program

a. In ~ 11 seconds after auto-start signal achieves voltage of ;?: 37 40 and during tests, achieves steady state voltage ;?: 3740 V and ~ 4580 V;
b. In ~ 11 seconds after auto-start signal achieves frequency of;?: 57 Hz and during tests, achieves steady state frequency;?: 58.8 Hz and ~ 61.2 Hz;
c. Operates for ;?: 5 minutes; and
d. The emergency bus remains energized from the offsite power system.

(continued)

McGuire Units 1 and 2 3.8.1-16 Amendment No. 261/241

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 Verify each DG's non-emergency automatic trips are In accordance with bypassed on actual or simulated loss of voltage signal on the Surveillance the emergency bus concurrent with an actual or Frequency Control simulated ESF actuation signal.:. Program SR 3.8.1.14 - - - - - - - - N O T E ~ - - - - - - - -

1. Momentary transients outside the load range do not invalidate this test.
2. DG loadings may include gradual loading as recommended by the manufacturer.

Verify each DG, when connected to its bus in parallel with In accordance with offsite power and operating with maximum kVAR loading the Surveillance that offsite power conditions permit, operates for Frequency Control

~ 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: Program

a. For~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded ~ 4200 kW and ~ 4400 kW; and
b. For the remaining hours of the test loaded

~ 3600 kW and ~ 4000 kW.

(continued)

McGuire Units 1 and 2 3.8.1-17 Amendment No. 261/241

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.15 - - - - - - - - N O T E : " " l - - - - - - - - -

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded ~ 3600 kW and

$ 4000 kW.

Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves, in $ 11 seconds, In accordance with voltage ~ 3740 V, and frequency ~ 57 Hz and maintains the Surveillance steady state voltage ~ 3740 V and $ 4580 V and Frequency Control frequency~ 58.8 Hz and $ 61.2 Hz. Program SR 3.8.1.16 - - - - - - - N O T E S , - - - - - - - -

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that s~tisfy this SR.

Verify each DG: In accordance with the Surveillance

a. Synchronizes with offsite power source while Frequency Control loaded with emergency loads upon a simulated Program restoration of offsite power;
b. Transfers loads to offsite power source; and
c. Returns to standby operation.

(continued)

McGuire Units 1 and 2 3.8.1-18 Amendment No. 300/279

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.17 --------NOTE.:--,--------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode and connected In accordance with to its bus, an actual or simulated ESF actuation signal the Surveillance overrides the test mode by: Frequency Control Program

a. Returning DG to standby operation; and
b. Automatically energizing the emergency load from offsite power.

SR 3.8.1.18 Verify interval between each sequenced load block is In accordance with within design interval for each automatic load sequencer. the Surveillance Frequency Control Pro ram (continued)

McGuire Units 1 and 2 3.8.1-19 Amendment No. 300/279

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.19 - - - - - - - N O T E , , __ _ _ _ _ __

1. All DG starts may be preceded by an engine prelube period.
2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite power In accordance with signal in conjunction with an actual or simulated ESF the Surveillance actuation signal: Frequency Control Program

a. De-energization of emergency buses;
b. Load shedding from emergency buses; and
c. DG auto-starts from standby condition and:
1. energizes the emergency bus in ::;; 11 seconds,
2. energizes auto-connected emergency loads through load sequencer,
3. achieves steady state voltage ~ 3740 V and::;; 4580 V,
4. achieves steady state frequency~ 58.8 Hz and ::;; 61.2 Hz, and
5. supplies auto-connected emergency loads for ~ 5 minutes.

(continued)

McGuire Units 1 and 2 3.8.1-20 Amendment No. 300/279

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.20 - - - - - - - N O T E S - - - - - - - -

AII DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby In accordance with condition, each DG achieves, in ~ 11 seconds, voltage of the Surveillance

~ 3740 V and frequency of ~ 57 Hz and maintains steady Frequency Control state voltage ~ 3740 V and ~ 4580 V, and frequency Program

~ 58.8 Hz and ~ 61.2 Hz.

SR 3.8.1.21 For the LCO 3.8.1.c and LCO 3.8.1 .d AC electrical In accordance with sources, SR 3.8.1.1, SR 3.8.1.2, SR 3.8.1.4, SR 3.8. ~ .5, the Surveillance and SR 3.8.1.6 are regu*ired to be met. Frequency Control Program McGuire Units 1 and 2 3.8.1-21 Amendment No. 261/241