Text

License Amendment Request for Technical Specification 3.3.2, Engineered Safety Features Actuation System Instrumentation
	ML042380481
Person / Time
Site:	McGuire, Mcguire
Issue date:	08/18/2004
From:	Gordon Peterson; Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML042380481 (21)
	v • d • e

i Pk Duke (WPowere A Duke Energy Company GARY R. PETERSON Vice President McGuire Nuclear Station Duke Power MGOIVP/ 12700 Hagers Ferry Road Huntersvile, NC 28078-9340 704 875 5333 704 875 4809 fax grpeters@duke-energy.com August 18, 2004 U. S. Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Corporation McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 License Amendment Request for Technical Specification 3.3.2, Engineered Safety Features Actuation System Instrumentation Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Duke Energy Corporation (Duke) is requesting a License Amendment Request (LAR) to the McGuire Nuclear Station Facility Operating Licenses and Technical Specifications (TS).

As described below, this LAR will correct an inadvertent TS change omission made by Duke during the submittal of LARs associated with TS Amendment 182/164 and Amendment 184/166.

Duke LAR dated October 6, 1997, as supplemented by letter dated August 24, 1998 (the first LAR), included two versions of TSs, one for former TS 3/4.3.2, and one for Standardized TS (STS) 3.3.2.

The first LAR was for deleting all references to the Safety Injection Steam Line Pressure-Low function.

This function was deleted due to redundant Safety Injection signals being available during design basis accidents.

In the first LAR, all concerned references were correctly deleted from former TS 3/4.3.2 but were not correctly deleted from STS 3.3.2.

Specifically, the concerned reference was not deleted from Footnote (c) to STS Table 3.3.2-1 and from the Bases of STS 3.3.2 Function 4.d.(1).

The NRC approved the changes to former TS 3/4.3.2 in the first LAR by TS Amendment 182/164 dated September 22, 1998.

Duke LAR dated May 27, 1997, as supplemented by letters dated March 9, March 20, April 20, June 3, June 24, July 7, July 21, August 5, September 8 and September 15, 1998 (the second LAR), proposed full conversion from former TSs to STSs.

The changes to STS 3.3.2, as proposed in the first LAR, were similarly proposed in the second LAR.

The NRC approved the second LAR by TS Amendment 184/166 dated September 30, 1998.

As a result of the omission in the 0-N www. duke-energy. corn

U.S. Nuclear Regulatory Commission Page 2 August 18, 2004 first LAR for STS 3.3.2, TS Amendment 184/166 contained the same omission for STS 3.3.2. provides a marked copy of the affected TS and TS Bases showing the proposed changes.

These changes were inadvertently omitted in the previously mentioned LARs. provides reprinted pages of the affected TS and TS Bases with the proposed changes incorporated. provides a description of the proposed changes and justifications., pursuant to 10 CFR 50.92, provides the determination that this LAR contains No Significant Hazards Consideration., pursuant to 10 CFR 51.22, provides the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement.

Implementation of this LAR will not impact the McGuire Updated Final Safety Analysis Report (UFSAR).

Duke is requesting NRC review and approval of this LAR at its earliest convenience so that the identified TS and TS Bases may be corrected.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, this LAR has been reviewed and approved by the McGuire Plant Operations Review Committee Chairman and the Duke Corporate Nuclear Safety Review Board Director.

Pursuant to 10 CFR 50.91, a copy of this LAR is being forwarded to the appropriate North Carolina State officials.

Inquiries on this matter should be directed to P. T. Vu at 704-875-4302.

Sinc ely, G. R. Peterson Attachments

U.S. Nuclear Regulatory Commission Page 3 August 18, 2004 xc:

w/attachments W. D. Travers Regional Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center, 23T85 61 Forsyth Street, SW Atlanta, GA 30303 J. J. Shea Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop 0-8H12 Washington, D.C.

20555 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station B. 0. Hall Section Chief Division of Radiation Section 1645 Mail Service Center Raleigh, NC 27699

U.S. Nuclear Regulatory Commission Page 4 August 18, 2004 OATH AND AFFIRMATION G. R. Peterson affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

G. R. Peterson, Site Vice President AMU-5

/8, do'O Subscribed and sworn to me:

J Date nov-ty C/--

P Notary Public My commission expires:

Date

ATTACHMEINT 1 MARKED PAGES OF AFFECTED TECHNICAL SPECIFICATION AND BASES

ESFAS Instrumentation 3.3.2

'r9 o

('Ct 4. o ^t( 1.

Table 3.3.2-1 (page 1 of 5)

Engineered Safety Feature Actuation System Instrumentation I

APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REOUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQU1REMENTS VALUE SETPOINT

1.

Safety Injection

a.

Manual Initiation

b.

Automatic Actuation Logic and Actuation Relays 1.2.3,4 1,2,3.4 2

2 trains B

SR 3.3.2.7 C

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 NA NA NA NA

c.

Containment Pressure - High 1,2.3 3

D SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9 D

SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9 S 1.2 psig 1.1 psig

> 1835 psig 1845 psig

d.

Pressurizer Pressure - Low Low 4

2.

Containment Spray

a.

Manual Initiation

b.

Automatic Actuation Logic and Actuation Relays

c.

Containment Pressure - High High 1.2,3,4 1,2,3,4 1 per train, 2 trains 2 trains B

SR 3.3.2.7 C

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 NA NA NA NA 1,2,3 4

E SR 3.3.2.1 -

SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9 S 3.0 psig 2.9 psig

3.

Containment Isolation

a.

Phase A Isolation (1) Manual Initiation (2) Automatic Actuation Logic and Actuation Relays 1,2,3,4 1,2,3,4 2

2 trains B

SR 3.3.2.7 C

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 NA NA NA NA (continued)

(a)

Above the P-11 (Pressurizer Pressure) interlock.

McGuire Units 1 and 2 3.3.2-1 0 Amendment Nos. 220/202

ESFAS Instrumentation 3.3.2

,,9.

Table 3.3.2-1 (page 2 of 5)

Engineered Safety Feature Actuation System Instrumentation I

APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

3.

Containment Isolation (continued)

(3) Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

b.

Phase B Isolation (1) Manual Initiation (2) Automatic Actuation Logic and Actuation Relays 1,2,3.4 1,2,3,4 1 per train, 2 trains 2 trains B

SR 3.3.2.7 C

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 NA NA NA NA (3)

Containment Pressure -

High High 1,2,3 4

E SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 S 3.0 psig 2.9 psig

4.

Steam Line Isolation

a.

Manual Initiation (1) System (2) Individual 1,2(b),3(b) t,2(b),3(b)

b.

Automatic Actuation Logic and Actuation Relays

c.

Containment Pressure - High High 2 trains 1 per line 2 trains 4

F SR 3.3.2.7 G

SR 3.3.2.7 H

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 E

SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9 NA NA NA 3.0 psig NA NA NA 2.9 psig 1,2(b), 3(b)

d.

Steam Line Pressure (1) Low 1,2(b), 3(a)(b) 3 per steam line D

SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9

> 755 psig 775 psig (continued)

(a) Above the P-t I (Pressurizer Pressure) interlock.

(b) Except when all MSIVs are dosed and de-activated.

McGuire Units 1 and 2 3.3.2-1 1 Amendment Nos. 220/202

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 5) f Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4.

Steam Line Isolation (continued)

(2) *Negative Rate - High 3(b)(c) 3 per steam line D

SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9

512(d) 1 ps i O(d) psi

5.

Turbine Trip and Feedwater Isolation

a.

Turbine Trip (I) Automatic Actuation Logic and Actuation Relays (2) SGWater Level-High High (P-14) 1,2 1.2 2 trains 3perSG I

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 J

SR 3.3.2.1 SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.8 SR 3.3.2.9 NA NA 7;,

)

(

S 85.6%

83.9%

(

K

)

(3) Safety Refer to Function 1 (Safety Injection) for all Initiation functions and requirements. See Item Injection 5.a.(1) for Applicable MODES.

b.

Feedwater Isolation (1) Automatic Actuation Logic and Actuation Relays (2) SG Water Level-High High (P-14) 1,2(e). 3(e) 1,2(e), 3(e) 2 trains 3 per SG H

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 D

SR 3.3.2.1 SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.8 SR 3.3.2.9 NA

< 85.6 NA 83.9%

(continued) 7;,

)

2

)

(b)

Except when all MSIVs are dosed and de-activated.

(c)

Tnr function automatically blocked above P-11 (Pressurizer Pressure) interlock and may be blocked below P-1I when O

)

fiectigmiteamn Line Pressure-Low is not blocked.

(d) f Im E~stant utilized In the rate/lag controller Is > 50 seconds.

(e)

Except when all MFIVs, MFCVs, and associated bypass valves are dosed and de-activated or isolated by a closed manual valve.

McGuire Units 1 and 2 3.3.2-12 Amendment Nos.lIO/22l

ESFAS Instrumentation e

B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Phase B containment isolation. There also is adequate time for the operator to evaluate unit conditions and manually actuate individual isolation valves in response to abnormal or accident conditions.

(3)

Phase B Isolation-Containment Pressure - High High The basis for containment pressure MODE applicability is as discussed for ESFAS Function 2.c above.

4.

Steam Line Isolation Isolation of the main steam lines provides protection in the event of an SLB inside or outside containment. Rapid isolation of the steam lines will limit the steam break accident to the blowdown from one SG, at most. For an SLB upstream of the main steam isolation valves (MSIVs), inside or outside of containment, closure of the MSIVs limits the accident to the blowdown from only the affected SG. For an SLB downstream of the MSIVs, closure of the MSIVs terminates the accident as soon as the steam lines depressurize.

Steam Line Isolation also mitigates the effects of a feed line break and ensures a source of steam for the turbine driven AFW pump during a feed line break.

a.

Steam Line Isolation-Manual Initiation Manual initiation of Steam Line Isolation can be accomplished from the control room. There are two system level switches in the control room and either switch can initiate action to immediately close all MSIVs. The LCO requires two channels to be OPERABLE. Individual valves may also be closed using individual hand switches in the control room. The LCO requires four individual channels to be OPERABLE.

b.

Steam Line Isolation-Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.

McGuire Units 1 and 2 B 3.3.2-1 5 Revision No. 55

ESFAS Instrumentation

$14.

btA(y B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Manual and automatic initiation of steam line isolation must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the RCS and SGs to have an SLB or other accident. This could result in the release of significant quantities of energy and cause a cooldown of the primary system. The Steam Line Isolation Function is required in MODES 2 and 3 unless all MSIVs are closed and de-activated. In MODES 4, 5, and 6, there is insufficient energy in the RCS and SGs to experience an SLB or other accident releasing significant quantities of energy.

c.

Steam Line Isolation-Containment Pressure-High High This Function actuates closure of the MSIVs in the event of a LOCA or an SLB inside containment to maintain three unfaulted SGs as a heat sink for the reactor, and to limit the mass and energy release to containment. The Containment Pressure - High High function is described in ESFAS Function 2.C.

Containment Pressure-High High must be OPERABLE in MODES 1, 2, and 3, when there is sufficient energy in the primary and secondary side to pressurize the containment following a pipe break. This would cause a significant increase in the containment pressure, thus allowing detection and closure of the MSIVs. The Steam Line Isolation Function remains OPERABLE in MODES 2 and 3 unless all MSIVs are closed and de-activated. In MODES 4, 5, and 6, there is not enough energy in the primary and secondary sides to pressurize the containment to the Containment Pressure-High High setpoint.

d.

Steam Line Isolation-Steam Line Pressure (1)

Steam Line Pressure-Low Steam Line Pressure-Low provides closure of the MSIVs in the event of an SLB to maintain three unfaulted SGs as a heat sink for the reactor, and to limit the mass and energy release to containment.

This Function provides closure of the MSIVs in the event of a feed line break to ensure a supply of steam for the turbine driven AFW pump.

McGuire Units 1 and 2 B 3.3.2-1 6 Revision No. 55

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Steam Line Pressure-Low Function must be OPERABLE in MODES 1, 2, and 3 (above P-11), with any main steam valve open, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines.

This signal may be manually blocked by the operator below the P-1 1 setpoint. Below P-1 1, an inside containment SLB will be terminated by automatic actuation via Containment Pressure-High High. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line Lw.-Ls Ws I

&~

L, l

e Pressure-Negative Rate-High signal for Steam Line Isolation

-c wre -

below P-il wheihas been manually blocked. The Steam Line Isolation Function is required in MODES 2 and 3 unless Low all MSIVs are closed and de-activated. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.

(2)

Steam Line Pressure-Negative Rate-High Steam Line Pressure-Negative Rate-High provides closure of the MSIVs for an SLB when less than the P-1 1 setpoint, to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. When the operator manually blocks the Steam Line Pressure-Low main steam isolation signal when less than the P-1 1 setpoint, the Steam Line Pressure-Negative Rate-High signal is automatically enabled. Steam Line Pressure-Negative Rate-High provides no input to any control functions.

Thus, three OPERABLE channels are sufficient to satisfy requirements with a two-out-of-three logic on each steam line.

Steam Line Pressure-Negative Rate-High must be OPERABLE in MODE 3 when less than the P-i1 setpoint, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). In MODES 1 and 2, and in MODE 3, when above the P-1i1 setpoint, this signal is automatically disabled and the Steam Line Pressure-Low signal is automatically enabled. The Steam Line Isolation Function is required to be OPERABLE in McGuire Units 1 and 2 B 3.3.2-17 Revision No

ATTACHMENT 2 REPRINTED PAGES OF AFFECTED TECHNICAL SPECIFICATION AND BASES

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 5)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4.

Steam Une Isolation (continued)

(2)

Negative Rate - High 3 (b)(c) 3 per steam line D

SR 3.3.2.1 SR 3.3.2.5 SR 3.3.2.8 SR 3.3.2.9 s 120(d) psi 100(d) psi

5.

Turbine Trip and Feedwater Isolation

a.

Turbine Trip (1) Automatic Actuation Logic and Actuation Relays (2) SG Water Level-High High (P-14) 1,2 1,2 2 trains 3 per SG I

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 J

SR 3.3.2.1 SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.8 SR 3.3.2.9 NA

< 85.6%

NA 83.9%

(3) Safety Refer to Function 1 (Safety Injection) for all Initiation functions and requirements. See item Injection 5.a.(1) for Applicable MODES.

b.

Feedwater Isolation (1) Automatic Actuation Logic and Actuation Relays (2) SG Water Level-High High (P-14) 1,2(e), 3(e) 1,2 (e), 3(e) 2 trains 3 per SG H

SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6 D

SR 3.3.2.1 SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.8 SR 3.3.2.9 NA 5 85.6 NA 83.9%

(continued)

(b)

(c)

(d)

(e)

Except when all MSIVs are closed and de-activated.

Trip function automatically blocked above P-1I (Pressurizer Pressure) interlock and may be blocked below P-11 when Steam Une Isolation Steam Une Pressure-Low Is not blocked.

I Time constant utilized In the rate/lag controller Is > 50 seconds.

Except when all MFIVs, MFCVs, and associated bypass valves are dosed and de-activated or Isolated by a closed manual valve.

McGuire Units 1 and 2 3.3.2-1 2 Amendment Nos.

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

Steam Line Pressure-Low Function must be OPERABLE in MODES 1, 2, and 3 (above P-1 1), with any main steam valve open, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This signal may be manually blocked by the operator below the P-11 setpoint. Below P-1 1, an inside containment SLB will be terminated by automatic actuation via Containment Pressure-High High. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line Pressure-Negative Rate-High signal for Steam Line Isolation below P-1 1 when Steam Line Isolation Steam Line Pressure-Low has been manually blocked. The Steam Line Isolation Function is required in MODES 2 and 3 unless all MSIVs are closed and de-activated. This Function is not required to be OPERABLE in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident.

(2)

Steam Line Pressure-Negative Rate-High Steam Line Pressure-Negative Rate-High provides closure of the MSIVs for an SLB when less than the P-1 1 setpoint, to maintain at least one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. When the operator manually blocks the Steam Line Pressure-Low main steam isolation signal when less than the P-1 1 setpoint, the Steam Line Pressure-Negative Rate-High signal is automatically enabled. Steam Line Pressure-Negative Rate-High provides no input to any control functions.

Thus, three OPERABLE channels are sufficient to satisfy requirements with a two-out-of-three logic on each steam line.

Steam Line Pressure-Negative Rate-High must be OPERABLE in MODE 3 when less than the P-1 1 setpoint, when a secondary side break or stuck open valve could result in the rapid depressurization of the steam line(s). In MODES 1 and 2, and in MODE 3, when above the P-i 1 setpoint, this signal is automatically disabled and the Steam Line Pressure-Low signal is automatically enabled. The Steam Line Isolation Function is required to be OPERABLE in McGuire Units 1 and 2 B 3.3.2-17 Revision No.

ATTACHME11T 3 DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION

U.S. Nuclear Regulatory Commission August 18, 2004 Page 1 of 1 DESCRIPTION OF PROPOSED CHANGES AND JUSTIFICATIONS TECHNICAL SPECIFICATION (TS) 3.3.2 AND BASES, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION This License Amendment Request (LAR) will correct an inadvertent TS change omission made by Duke during the submittal of LARs associated with TS Amendment 182/164 and Amendment 184/166.