ML20199J312

Forwards RAI on Section 3.6 Containment Sys.Response Requested within 45 Days

ML20199J312
Person / Time
Site:	Mcguire, Catawba, McGuire
Issue date:	01/30/1998
From:	Tam P NRC (Affiliation Not Assigned)
To:	Tuckman M DUKE POWER CO.
References
TAC-M95298, TAC-M95299, TAC-M98964, TAC-M98965, NUDOCS 9802050280
Download: ML20199J312 (33)

Text

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43 January 30; 1998 SUM, [.; u h;.4 4, f*

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Mr. Mi Si Tuckmen1 C'

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SUBJECT:

CATAWBA AND MCGUIRE NUCLEAR STATIONS - REQUEST FOR "' 5 4

ADDITIONAL INFCF,MATION ON THE PROPOSED IMPROVE) TECHNICAL'

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SPECIFICATIONS (TAC NOS, M95298, M95299, M98964 AND M98965),

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Dear Mr. Tuckman:

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By two separate letters dated May 27,1997, Duke Energy Corporation (formerly Duke Power Company) sut,mitted proposed amendments to revise the Catawba and McGuire Technical E

Specifications to be consistent with the improved Standard Technical Specifications (ISTS)

- conveyed by NUREG-1431 (dated April 1995). By letter dated January 16,1998, we issued a request for additional information (RAI) on Sections 3.1 and 3.2.

. Enclosed is an RAI on Section 3.6, Containment Systems. Please provide your response within

' 45 days of receipt of this letter. Contact me at (301) 415-1451 or Frank Rinaldi F (301) 415 -

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' 1447 if you have any questions regarding this RAl.

Sincerely, ORIGINAL SIGNED BY:

Peter S. Tam, Senior Project Manager p_

Project Directorate ll 2

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L Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation L

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- Docket Nos. 50-413, 50-4i4, 50-369, and 50-370 I

Enclosure:

As stated cc w/ encl: See next page H

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Mr. M. S. Tuckman Senior Vice President Nuclear Generation Duke Energy Corporation P. O. Box 1006 Charlotte, NC 28201 1

SUBJECT:

CATAWBA AND MCGUIRE NUCLEAR STATIONS - REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED IMPROVEO TECHNICAL SPECIFICATIONS (TAC NOS, M95298, M95299, M98964 AND M98965)

Dear Mr. Tuckman:

By two separete letters dated May 27,1997, Duke Energy Corporation (formerly Duke Power Company) submitted proposed amendments to revise the Catawba and McGuire Technical Specifications to be consistent with the traprove.d Gtandard Technical Specifications (ISTS) conveyed by NUREG-1431 (dated April 1995). By letter dated January 16,1998, we issued a request for additional information (RAl) on Sections 3.1 and 3.2.

Enclosed is an RAI on Section 3.6, Containment Systems. Please provide your response within 45 days of receipt of this letter. Contact me at (301) 415-1451 or Frank Ririaldi at (301) 415-1447 if you have any questions regarding this RAl.

Sincerely, rY M

hi e r S. Tam, Senior Project Manager -

Project Directorate ll-2 Division of Reactor Projects -l/II Office of Nuclear Reactor Regulation Docket Nos. 50-413, 50-414, 50-369, and 50 370

Enclosure:

As stated cc w/ encl: See next page

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McGuiro Nuciar Station Catawba Nuclear Station k

cc:

Mr. Paul R. Newton Mr. Richard M. Fry, Director Legal Department (F OSE)

Division of Radiation Protection Duke Energy Corporation North Carolina Department of 422 South Church Peeet Environment, Health, and

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Chariotte, North Carclina 28242 0001 Natural Resources 3825 Barrett Drive County Manager of Mecklenburg County Raleigh, North Carolina 27609-7721 720 East Fourth 5treet Charlotte, North Carolina 28202 Ms. Karen E. Long Assistant Attomey General Mr. Michael T. Cash No'th Carolina Department of g

Regulat:ry Compliance Manager Justice Duke Energy Corporation P. O. Box 629

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McGuire Nuclear Site Raleigh, North Carolina 27602 12700 Hagers Feiry Road Huntersville, North Carolina 28078 L. A. Keller Manager-Nuclear Regulatory J. Michael McGarry, Ill, Esquire Licensing Winston and Strawn Duke Energy Corporation 1400 L Street, NW, 526 South Church Street Washington, DC 20005 Charlotte, North Carolina 28242-0001 Cenior Resident inspector Regional Administrator, Region ll clo U. S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Atlanta Federal Center 12700 Hagers Ferry Road 61 Forsyth Street, S.W., Suite 23T85 Huntersville, North Carolina 28078 Atlanta, Georgia 30303 Mr. Peter R. Harden, IV Elaine Wathen Account Sales Manager Lead REP Planner Westinghouse Electric Corporation Division of Emergency Management Power Systems Field Sales 116 West Jones Street P. O. Box 7288 Raleigh, North Carolina 27603-1335 Charlotte, North Carolina 2824 i Mr. T. Richard Puryear Dr. Jchn M. Barry Owners Group (NCEMC)

Mecklenbur0 County Duke Energy Corporation Depart.nent of Environmental 4800 Concord Road Protection York, South Carolina 29745 700 N. Tryon Street Charlotte, North Carolina 28202

McGuire Nuclear Station Catawba Nuclear Station cc:

Mr. M. S. Kitlan Norin Carolina tsvetric Membership Regulatory Compliance Manager Corporation Duke Energy Corporation P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident inspector North Carolina Municipal Power 4830 Concord Road Agency Number 1 York, South Carolina 29745 1427 Meadowwood Boulevard P. O. Box 29513 Mr. G. R. Peterson Rale!gh, North Carolina 27626-0513 Site Vice President Catawbr Nuclear Station County Manager of York County Duke Energy Corporation York County Courthouse 4800 Concord Road York, South Carolina 29745 York, South Carolina 29745 Piedmont Municipal Power Agency Mr. H. D. Barron i

121 Village Drive Vice President, McGuire Site Greer, South Cerolina 29651 Duke Energy Corporation l

12700 Hagers Ferry Road Salud1 River Electric Huntersville, Noith Carolina 28078 P. O. Box 929 Laurens, South Carolina 29360 -

l Max Batam, Chief Bureau of.;' adiological Health South Carohna Department of Health and Environmental Control 26Cf., Bull Street Columbia, South Carolina 29201

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4; McGuire & Catawba improved TS Review Comments

).

ITS Section 3.6, Catainment Systems

3.6.1 - Containment 3.6.1 1' DOC A.3.

(McGuire Onlyr DOC A.33 CTS 3.6.1.1 ACTION CTS 3.6.1.1 requires Containment Integrity be maintained. ITS LCO 3.6.1 changes Centainment Integrity be maintained to containment shall be OPERABLE. ' This change is

, designated DOC A.3 throughout the CTS markup of ITS 3.6.1 However, this change made to CTS 3.6.1.1 ACTION for McGuire Unit 1 is desierated DOC A.33 while for Unit 2 and Catawba the change is designated DOC A.3. DOC A 33 is listed in the justifications as "Not Used." Comment: Correct this discrepancy in the McGuire Unit 1 CTS markup.

DEC Response:

3.6.1 2 DOC A.3 DOC LA.1 JFD 6~

JFD Bases 6 CTS 4.6.1.1.c CTS 3.6.1.2.e, b, and c

. CTS 4.6.1.2.d CTS 4.6.1.2 d. 3)

CTS 4.6.1.2.e, h, and I.

CTS 4.6.1.6 STS SR 3.6.1.1 ITS SR 3,6.1.1 -

ITS B3.6.1 Bases CTS 4.6.1.1.c, 3.6.1.2, 3.6.1.2 ACTIONS, 4.6.1.2 and 4.6.1.2c, d, e, f, g, h and i specify various leak rate testing requirements and criteria for containment. -- CTS 4.6.1.6 specifies visual examinations to be performed on the containment vesse! STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 ~ Appendix J'as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to TSTF 52. The STS is based on 10 CFR 50 Appendix J Option A while the ITS is based on 10 CFR 50 Appendix J Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher 1. Grimes to Mr. David J. Modeen, NEl dated 11/2/95 and TSTF 52 as modified by staff comments.

The ITS chenges are not in conformance with the letter and TSTF 52 as modified by staff comments. In particular, Amendments 173 and 155 for P.1cGuire Units 1 and 2

. respectively and Amendments 144 and 138 for Catawba Units 1 and 2 respectively only approved 10 CFR 50 Appendix J Option for the Type A tests only. The Type B and C MC2_CR_3.6.

'3.6-1 January 28,1998

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McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems tests must still be done in accordance with Option A. Thus, only those leakage tests associated with Option B Type A test may be relocated to the Containment Leakage Rate Testing Program. This includes CTS 3.6.1.2.a, CTS 3.6.1.2 ACTION a, 4.6.1.2, 4.6.1.2.c and 4.6.1.2.1 with regards to Type A tests only. All other CTS requirements specified above including CTS 4.6.1.2.1 must be retained in the ITS as SRs or Notes to the SRs.

Comment: Licensee to update submittal with regards to 11/2/95 letter, TSTF 52 as modified by staff comments and the above comments or provide additional justification for deviations.

DEC Response:

3.6.1 3 DOC A.5 (ITS 1.0)

DOC LA.1 JFD Bases 1 JfD Bases 2 (McGuire only)

CTS 1.7 CTS 4.6.1.2.d.3)

CTS 4.6.1.2.h 4

STS B3.6.1 Bases BACKGROUND ITS B3.6.1 Bases BACKGROUND 4

i CTS 1.7 provides the definition for Containment integrity and is justified by DOC A.5 as deleted in the CTS Markup of ITS 1.0. This is incorrect. The definition is part of the technical specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.7 should be included in the CTS Markup of ITS 3.6.1,3.6.2 and 3.6.3. In particular, all of CTS 1.7 (a through e, except d, is relocated to ITS B3.6.1 Bases - BACKGROUND. This change would be considered as e Less Restrictive (LA) change. In addition, ITS B3.6.1 Bases BACKGROUND shows that STS B3.6.1 Bases -

BACKGROUND item d has been deleted. Based on CTS 1.7.e,4.6.1.2.d.3), and 4.6.1.2.h, this item cannot be deleted. Furthermore, CTS 1.7a, c and e should also indicate that they are associed with other ITS 3.6.1, 3.6.2, and 3.6.3 SRs which are Administrative

_ changes. (See Comment Numbers 3.6.2-1 and 3.6.31) Comment: Revise the CTS markup of ITS 3.6.1 to include a merkup of CTS 1.7 and revise ITS B3.6.1 Bases BACKGROUND, accordingly. Provide additional discussion and justifications for the above Less Restrictive (LA) and Administrative changes.

DEC Response:

1 MC2_CR_3.S 3.6 2 January 28,1998

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McGuire & Catawba improved TS Review Comments

-lTS Section 3.6, Containment Systems 3.6.2 Containment Air Locks 3.6.2 1 DOC A.5 (ITS 1.0)

CTS 1.7 See Comment Number 3.6.13. Comment: Revise the CTS Markup of ITS 3.6.2 to include a markup of CTS 1.7. Provide additional discussions and justifications for the Administrative changes.

DEC Response:

3.6.2 2 DOC A.9 DOC LA.3 DOC LA.4 JFD 6 JFD Bases 6 CTS 3.6.1.3.b l

CTS 4.6.1.3a, b. and d.

ITS SR 3.6.2.1 ITS B3.6.2 Basee See Comment Number 3.6.1-2.

Comment: See Comment Number 3.6.12.

DEC Response:

3.6.2 3-DOC L.2 ITS 3.6.2 Condition A, Required Action Note 2 STS 3.6.2 ACTION A, Required Action Note 2 states that entry and exit is permissible for 7 days under administrative controlif both air locks are inoperable. This Note has been adopted in ITS 3.6.2 ACTION A. The proposed change has been categorized as a Less Restrictive change. DOC L.2 does not address the proposed change's impact on safety and why the safety impact is acceptable. Comment: Revise the submittal to strengthen the justification for this Less Restrictive change.

DEC Response:

MC2_CR_3.6 3.6-3 January 28,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.0.2-4 DC C L.6 JFD 10 JFD Bases 10 g

CTS 4.6.1.3.c STS SR 3.6.2.2 ITS SR 3.6.2.2 and Associated Bases CTS 4.6.1.3.c and STS SR 3.6.2.2 require verifying only one door in the air lock will open at a time at 6 month intervals. The interval is modified in the ITS from 6 months to 18 months. The justification (DOC L.6) used states that the 6 month frequency was selected to coincide with the frequency of the overall air lock leakage test, which was specified in 10 CFR 50 Appendix J Option A, as once per 6 months. In justifying the increase from 6 months to 18 months, justification DOC L.6 refers to the allowance to increase the frequency interval given by 10 CFR 50 Appendix J Option B. This portion of the justification is not applicable to McGuire/ Catawba since f.ppendix J Option B was not approved for airlock leakage testing. (See Comment Numbers 3.6.1-2 and 3.6.2 2). Also, DOC L.6 states that the frequency change to 18 months is consistent v'ith TSTF 17. This is incorrect. TSTF-17 approved a change in frequenc/ for STS SR 3.b.2.2 from 6 months 1

to 24 months, in addition, the modifications made to ITS B3.6.2 Bases SR 3.6.2.2 are not in accordance with TSTF-17. Ccmment: Licensee to update submittal to be in accordance with TSTF-17 and provide additional discussions and justifications for the increase in SR frequency as well as the deviations from TSTF-17.

DEC Response:

3.6.2 5 JFD Bases 2 (McGuire only)

STS B3.6.2 Bases - ACTIONS ITS B3.6.2 Bases - ACTIONS STS B3.6.2 Ba:;as - ACTIONS first paragraph states the following: "If the outer door is inoperable, t%n it may be easily accessed for most repairs. It is preferred that the airlock..." ITS B3.6.2 Bases - ACTIONS modifies these sentences as follows: "If the omer door...for most repairs. If the inner door is inoperable it is preferred..." The addition of the words "if the inner door is inoperable" changes the meaning of the sentence. The STS words apply to both the inner and outer doors inoperable while the change would restrict access only if the inner door is inoperable, in addition, this change was not made in the cor..>sponding Catawba ITS, is considered by the staff as generic and is beyond the scope of review for this conversion. Comment: Delete this generic change.

DEC Response:

MC2_CR_3.6 3.6-4 January 28,1998

_s McGrire & Catawba improved TS Review Comments

!TS Section 3.6, Containment Systems 3.6.2 6 JFD Bases 2 STS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 ITS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 STS B3.6.2 Bases - RA A.1, A.2, and A.3 states in the description for Note 2 the

- following: "This Note is not intended to preclude other activities (i.e., non TS required activities)...to perform an allowed activity listed above." ITS B3.6.2 Bases - Required Actions A.1, A.2 and A.3 modifies this statement to restrict the " allowed activity listed above" to "TS required allowed activities listed above". This change changes the meaning of the discussion and negates the previous Base statements which allows preventive maintenance to TS required equipment and repairs to non TS support equipment would not be allowed as is stated in the Ba.es discussion for Note 2. The staff also considers this change to be potentially generic. Comment:. Delete this change.

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DEC Respor,se:

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3.6.3 Containment isolation Valves

-3.6.3 1 DOC A.5 (ITS 1.0)

CTS 1.7 See Comment 3.6.1-3. Comment: Revise the CTS markup of ITS 3.6.3 to include a markup of CTS 1.7.< Provide additioral discussions and justifiestions for the /..'ministrative changes.

DEC Response:

'3.6.3 2

= DOC A.1 JFD 1

. JFD Bases 1 CTS 4.6.1.2.e (Cs.tawba)-

CTS 4.6.1.2.f (McGuire)

ITS SR 3.6,0.7 and Associated Bases ITS B3.6.3 Bases SR 3.6.3.5 CTS'4.6.1.2.1 specifies that the combined bypass leakage rate shall be determined "during each Type A test"..This material has not been retained in ITS SR 3.6.3.7. The proposed change has bsen categorized as a reformatting, renumbering, or rewording type change.

As a result of the discussion in Comment Number 3.6.1-2, this phrase cannot be deleted, but must be included in some form in the frequency for ITS SR 3.6.3.7. In addition, the Bases for ITS SR 3.6.3.5 and SR 3.6.3.7 need to be modified in cccordance with Comment Number 3.6.1-2. Comment: See Comment Number 3.6.1-2.

MC2_CR_3.6 3.6-5 January 28,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems DEC Response:

3 3.6.3 3 DOC A.10 JFD 2 CTS 3.6.3 Insert 6 STS 3.6.3 ACTIONS Note 4 ITS 3.6.3 ACTIONS Note 4 g

STS 3.6.3 ACTIONS Note 4 requires entry into " Applicable Conditions and Required Actions of LCO 3.6.1 " Containment", when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria." ITS 3.6.3 ACTIONS Note 4 deletes the STS words " acceptance criteria," based on editorial change for clarity. The staff finds the change is not an editorial change and considers the change to be generic which is beyond the scopo of review for this conversion. Comment: Delete this generic change.

DEC Response:

3.6.3-4 DOC A.10 (McGuire Only)

DOC L.8 CTS 4.6.1.1.a, " Footnote ITS 3.6.3 ACTION Note 1 CTS 4.6.1.1.a, seems to limit the containment isolation valves allowed to be opened under administrative control to those listed in the " footnote. This footnote has not been retained in ITS 3.6.3 and its deletion is justified by DOC L.8. ITS 3.6.3 ACTION Note 1 added by DOC. A.10 allows all containment isolation valves except the purge valves to be opened intermittently under administrative control. Because of the " footnote to CTS 4.6.1.1.a, the addition of ITS 3.6.3 ACTION Note 1 is a Less Restrictive change, not an Administrative change. In addition, DOC L.8 does not discuss the deletion of the *

• footnote, nor why this deletion is a Less Restrictive change. Comment: Revise the submittal to classify the addition of ITS 3.6.3 ACTION Note 1 as a Less Restrictive change and provide additional discussion and justification for the Less Restrictive changes of the addition of ITS 3.6.3 ACTION Note 1 and the deletion of CTS 4.6.1.1.a, ' footnote.

DEC Response:

MC2_CR_3.6 3.6-6 January 28,1998 i

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McGuire & Catawba improved TS Review Comments ITS Section 3.8, Containment Systems 3.6.3 5 DOC A.18 e

JFD 11

-JFD Bases 5 CTS 4.6.1.1.a CTS 4.6.3.2 ITS SR 3.6.3.2 and Associated Bases ITS SR 3.6.3.3 and Associated Bases ITS SR 3.6.3.6 and Associated Bases i

CTS 4.6.3.2 is revised to include a clarification that valves which are locked, sealed, or.

otherwise secured in their' required safety position are not required to be tested. -. CTS :

.4.6.1.1.a requires verifying that all penetration not capable of being closed by an OPERABLE automatic isolation valve and required to be closed during act;ident conditions are closed.. CTS 4.6.1.1.a becomes ITS SR 3.6.3.2 and ITS SR 3.6.3.3. Both of these ITS SRs and their associated Bases are revised per TSTF 45 to include a clarification that -

l valves which are locked, sealed or otherwise securing in their safety position are not

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required to be verified closed. The CTS does not contain this provision. Therefore CTS 4.6.1.1.a needs to be revised to include this provision and the change designated DOC 4

A.18. See Comment Number 3.6.3-6. Comment: Revise the CTS markup of CTS 4.6.1.1.a to include this Administrative change and revise DOC A.18 to discuss and justify this 'chenge to CTS 4.6.1.1.a.

CiC Response:

4=

'3.6.3 8 DOC A.18 JFD 11.

JFD Bases 5 l

CTS 4.6.1.1.a STS SR 3.6.3.3 and Associated Bases t

-STS SR 3.6.3.4 and Associated Bases ITS SR 3.6.3.2 and Associated Bases 4

ITS SR 3.6.3.3 and Associated Bases STS SR 3.6.3.3 and SR 3.6.3.4 verify the position of containment isolation manual valves and blind flanges outside and inside containment respectively. The SRs are modified to include a clarification that valves which are locked, sealed or otherwise secured in their required safety position are not required to be verified in their closed position. This

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modification is in accordance with TSTF-45 which is acceptable. However, the Bases changas are not in accordance with TSTF-45. Comment: Licensee to update submittal to be in accordance with TSTF-45 or provide addlSonsi justification for the deviations.

I DEC Response:

MC2_CR_3.6 3.6-7 January 28,1998 I

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McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.3 7 DOC A.20 CTS 3.6.1.9 ACTION c ITS 3.6.3 RA E.1 CTS 3.6.1.9 ACTION c requires restoring the inoperable valves to OPERABLE status. RA E.1 specifies isolating the affected penetration flow path by use of at least one closed and decctivated automatic valve, closed manual valve, or blind flange. The proposed change has been categorized as an Administrative change. The proposed chaa.ge is a Less Restrictive change in that the CTS only allowed valve restoration to OPERABLE status, not penetration isolation. Comment: Revise the CTS markup to show this change as a Less Restrictive change and provide the appropriate discussion and justification.

DEC Response:

1 3.6.3 8 DOC L.7 JFD 4 JFD Bases 4 (McGuire)

JFD Bases 5 (Catawba)

CTS 3.6.3 ACTION c 4

STS 3.S.3 RA A.1 ITS 3.6.3 RA A.1 and Associated Bases CTS 3.6.3 ACTION c is revised to add an additional method of isolating an affected penetration by allov"ing the use of a check valve inside containment with flow through the valve secured. This change is incorporated into ITS 3.6.3 RA A.1, No justification is provided as to why it is limited to check valves inside containment. STS 3.6.3 RA A.1

'does not impose this limitaticn. This change could be considered a potential generic change which would be beyond scope of review itemfor this conversion. Comment:

Delete this change or provide additional discussion and justification to support his Less Restrictive change based on current licensing bacis, system design or operational

. constraints.

DEC Response:

MC2_CR_3.6 3.6-8 January 28,1998

- McGuire & Catawba 'mproved TS Review Comments i

ITS Section 3.0, Containment Systems 3.6.3 9 DOC L.9' JFD 13 '

JFD Bases 3 (McGuire)

JFD Bases 5 (Catawba)

STS 3.6.3.2 and Associated Bases.

CTS 3.6.1.9.b for McGuire requires the containment purge valves for the upper -

containment be closed except for up to 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per calender year provided no m)re than

- one pair are open at a time. CTS 3.6.1.9.b for Catawba requires the containment air release and addition system purge valves to be closed except for up to 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> per calendar year for pressure control, for ALARA, and respirable air quality considerations for

- personnel entry and for surveillance tests that require the valve to be ~open. CTS 3.6.1.9 ACTION b and 4.6.1.9.2 are the associated remedial measures and surveillance for this -

LCO. None of these requirements is retained in the ITS, and the deletion is justified by DOC L.9. The staff finds this unacceptable. CTS 4.6.1.9.2 for both McGuire and Catawba verifies that these particular purge valves are closed by verifying the cumulative tim 6 the valves are open on a 7 day frequency. The staff finds that for CTS 4.6.1.9.2i STS SR-3.6.3.2 is the equivalent ITS SR for these valves, and that STS/ITS ACTION A.1 is the equivalent remedial measure to take when the CTS requirements are not met. Also see Comment Numbers 3.6.1-3 and 3.6.31. Comment: Revise the ITS submittal to include STS SR 3.6.3.2 or a revised STS SR 3.6.3.2 that conforms to the CTS requirements.

Revise the CTS submittal accordingly. Provide the appropriate discussions and justification to support these changes.

DEC Response:

3.6.3-10 DOC L.10 CTS 3.6.1.2 ACTION CTS 3.6.1.2 ACTION requires the combined bypass leakage rate to be within limits prior to increasing the RCS temperature above 2OO*F. Justification DOC L.10 states that no ACTIONS are specified if the unit is discovered outside the limits in MODES 1,2,3 or 4.

' This is not entirely correct. The actions to take in this situation is CTS 3.0.3. ITS 3.6.3 ACTION D is still considered a Less Restrictive (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> versus 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowed outage time)-

change. Comment: Revise DOC L.10 to address this aspect of this Less Restrictive change.

DEC Response:

MC2_CR_3.6 3.6-9 January 28,1998 i

o

McGuire & Catawba Improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.3 11 JFD Bases 4 STS B3.6.3 Bases - RA A.1 and A.2 STS B3.6.3 Bases RA E.1, E.2 and E.3 STS B3.6.3 Bases - SR 3.6.3,3 ITS B3.6.3 Bases - RA A.1 and A.2 ITS B3.6.3 Bases - RA E.1, E.2 and E.3 ITS B3.6.3 Bases - SR 3.6.3.2 STS B3.6.3 Bases for RA A.1 and A.2, RA E.1, E.2 and E.3 and SR 3.6.3.3 describe how the verification of the correct position of the containment isolation valves is to be performed. This verification is performed via a system walkdown. The ITS modifies these Bases sections to state that the verification is "through administrative controls such as a system walkdown or computer status indication." The proposed change is unacceptabie and changes the intent of the verification. The first part of the change (" administrative controls such as") would not limit the means of verification to only a system walkdown or computer status indication; a paper verification would be allowed by this change. This is unacceptable to the staff, in addition, no discussion or justification is provided to describe what is meant by computer status lndication and why it is equivalent to a system walkdown; it is assumed that the computer status indication is merely a status listing (paper verification) which would be unacceptable. Comment: Delete both parts of this change, or provide additional discussion and justification to show that the computer status l

Indication is the equivalent of a system walkdcwn.

l DEC Response:

3.6'3 12 CTS 4.6.1.9.1 ITS SR 3.6.3.1 and Associated Dases CTS 4.6.1.9.1 requires verifying that each containment purge valve for the lower compartment and instrument room (McGuire and Catawba), and the upper compartment and the hydrogen purge system (Catawba only) are sealed closed. ITS SR 3.6.3.1 verifies that these valves are sealed closed but provides an exception to open one purge valve in a penetration flow path while in Condition E of ITS 3.6.3 to perform repairs. This exception could not be found in the CTS markup and no justification was provided for this Less Restrictive change. Comment: Revise the CTS markup to show this exception and provide the appropriate discussion and justification for this Less Restrictive change.

DEC Response:

MC2_CR_3.6 3.6-10 January 28,1998 i

i McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 1

3.6.3 13 ITS B3.6.3 Bases LCO I

(Catawba only) i The first line of the fourth paragraph of ITS B3.6.3 Bases LCO refers to " secondary containment". This should be changed to " reactor building" to be consistent with the rest

' of the ITS Comment: Correct this discrepancy.

DEC Response:

3.6.3 14 ITS B3.6.3 Bases - ACTIONS (Catawba only)

The discussion for ACTION Note 4 in ITS B3.6.3 Bases ACTIONS states the following: "In the event the air lock leakage...". This statement is incorrect. The statement should read per EDIT-17: "In the event the containment isolation valve leakage...". Comment: Correct this error.

DEC Response:

3.6.5 Containment Air Temperature 3.6.5-1 DOC LA.8 (Catawba only)

CTS 4.6.1.5.1 l

CTS 4.6.1.6.2 Catawba justification' DOC LA.8, states the following: " CTS 4.G.1.5.1, 4.6.1.5.2 and the associated footnote contain descriptiva information on measurement locations und on how 4

the average containment temperature is weighted." These are the same words that are -

uted in justification DOC LA.8 for McGuire. McGuire CTS 4.6.1.5 has an associated footnote and the containment air temperature is a weighted average. Catawoa CTS ~

4.6.1.5 does not have an associated footnote and the containment air temperature is the

- arithmetical average of the ambient air monitoring stations which is different than a weighted average. - Thus, the above DOC LA.8 statement is incorrect for Catawba.

Comment: Revise the justification and discussion for DOC LA.8 in the Catawba submittal to correctly reflect the Catawba CTS requirements.

DEC Response:

MC2_CR_3.6 3.6-11 January 28,1998 l

i McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.5 2 JFD Bases 3 (Catawba)

JFD Bases 4 (McGuire)

STS B3.6.5 Bases - SR 3.6.5.1 and SR 3.6.5.2 ITS B3.6.5 Bases SR 3.6.5.1 and SR 3.6.5.2 STS B3.6.5 Bases - SR 3.6.5.1 and SR 3.6.5.2 states that "The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency for these SRs is considered acceptable based on observing slow rates of temperature increase within containment as a result of environmental heat sources (due to the large volume of the containment)." This material has not been adopted in the Bases for ITS B3.6.5.

Justification JFD Bases 3 (Catawba) and JFD Bases 4 (McGuire) do not specifically address this proposed deletion, and give different justifications for the same change Comment:

Provide additional discussion and justification to show why this STS statement is not applicable to McGuire and Catawba and revise the ITS Bases markup accordingly.

DEC Response:

3.6.6 Containment Spray System 3.6.6 1 DOC A.18 CTS 4.6.2.c ITS SR 3.6.6.3 ITS SR 3.6.6.4 CTS 4.6.2.c is revised to include a clarification that valves which are locked, sealed, or otherwise secured in their required safety position are not required to be verified that it actuates to its correct position on an actuation signal. This change is designated as DOC A.18 in the CTS markup. Tha justification and discussion for DOC A.18 states that this change is retained in ITS SR 3.6.6.3 and SR 3.6.6.4. ITS SR 3.6.6.4 deals with verifying pump actuation not valve actuation. Thus DOC A.18 is not applicable to ITS SR 3.6.6.4.

See Comment Number 3.6.3 6 for additional comments on DOC A.18. Comment: Revise justification DOC A.18 to delete the reference to ITS SR 3.6.6.4. See Comment Number 3.6.36.

DEC Response:

MC2_CR_3.6 3.6-12 January 28,1998

_a

A-McGuire & Catawba improved TS Review Comments ITS Section 3.0, Containment S estems-

- 3.6.6 2 DOC LA.9 -

-JFD Bases 3

- JFD Bases 4 CTS 3.6.2 ITS B3.6.6 Bases - BACKGROUND ITS B3.6.6 Bases - LCO CTS 3.6.2 states that the Containment Spray System shall be capable of taking suction from the refueling water storage tank and transferring suction to the containment sump.

This LCO statement implies that the transfer is automatic. This information is being relocated to the Bases by DOC LA.9 which is acceptable. However, the Bases statements in ITS B3.6.6 Bases - BACKGROUND and LCO sections which discuss this transfer -

mechanism state that the transfer is done manually. The discussion associated with DOC LA.9 does not describe this change from an automatic transfer to manual transfer.

Comment: Provide additional discussion and justification to show that the change from the CTS setomatic transfer requirement to the ITS manual transfer requirement is appropriate -

based on current licensing basis, system design cr operational constraints.

DEC Response:

3.6.63 JFD Bases 4 ITS B3.6.6 Bases BACKGROUND The discussion for ITS B3.6.6 Bases-BACKGROUND states in the insert on Page B3.6 87 that the ph of the sump solution is raised to at least 8.0 within one hour of the caset of the LOCA. The insert material also states that the chemical mixing tank and the charging pumps are used to accomplish this but it does not iescribe how this accomplished.

- Comment:. Revise.lTS B3.6.6 Bases BACKGROUND insert discussion to address this issue.

DEC Response:

! 3.6.6 4.

JFD Bases 4 STS B3.6.6 Bases SR 3.6.6.1 ITS B3.6.6 Bases - SR 3.6.6.1 STS/ITS SR 3.6.6.1 verifies that each containment spray manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position

.is in the correct position. STS t13.6.6C Bases SR 3.6.6C.1 states that this verification is to be accomplished oy a system walkdown for those valves outside containment. ITS B3.6.6 Bases - SR 3.6.6.1 modifies the STS wording to allow Administrative controls to be used MC2_CR_3.6 3.6-13 January 28,1998 l

McGuire & Catawba improved TS Review Comments

-ITS Section 3.6, Containment Systems for the verification. The Administrative controls would include a system walkdown, but would also allow a paper verification, a computer status indication or any other administrative means of verifying valve position. This change significantly modifies the intent of the SR. See Comment Number 3.6.311. Comment: See Comment Number 3.6.3-11.

DEC Response:

STS 3.6.7 Spray Additive System (McGuire Only) 83.6.7 1 JFD - None

. STS 3.6.7 and Associated Bases STS 3.6.7 " Spray Additive System" is not included in the McGuire ITS. No justification is provided to justify its deletion from the McGuire ITS. Comment: Provide a discussion a justification for the deletion of this specification from the McGuire ITS Wevise the ITS markup appropriately.

DEC Response:

3.6.7,, irogen Recombiners 3.6.7-1 DOC A.1 CTS 4.6.4.2.a ITS SR 3.6.7.1 CTS 4.6.4.2.a for McGuire Units 1 and 2 is modified to convert this surveillance into the 4

ITS format.- The modification changes the CTS words " verify during" to the ITS word

" performing." This chants is designated DOC A.1. This change is not shown in the CTS markups for Catawba Uni 41 and 2. Comment: Revise the Catawba Units 1 and 2 CTS markups of CTS 4.6.4.2.i to be consistent with the McGuire Units 1 and 2 CTS markups.

DEC Response:

3.6.7-2 DOC A.1 CTS 4.6.4.2.b.3 ITS SR 3.6.7.3 CTS 4.6.4.2.b.3 for McGuire Unit 1 is modified to convert this surveillance into the ITS format. The modification deletes the words " Verifying the integrity of" and rearranges the other words to conform to the ITS wording for SR 3.6.7.3. This change is designated DOC 4

A.1. This change is not shown in the CTS markups for McGuire Unit 2 and Catawba Units MC2_CR_3.6 3.6-14 January 28,1998 e

~ _ - -

..;c McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems c

1 and 2. Comment: Revise the McGuire Unit 2 and Catawba Units 1 and 2 CTS markups t

- of CTS 4.6.4.2.b.3 to be consistent with the McGuire Unit 1 CTS markup..

DEC Response:

f

.3.6.7 3 JFD 3 JFD Base 2 (McGuire)

{-

JFD Bases 3 (McGuire)

F JFD Bases 5 (Catawba)

STS 3.6.8 ACTION B and associated Baser ITS 3.6.7 ACTIONS -

STS 3,6.8 ACTION B provides the remedial actions for two hydrogen recombiners i.

. inoperable. These requirements have not been adopted in ITS 3.6.7._ The justification JFD

3 states that these requirements are not applicable to this facility. Based on the STS Bases 4

discussion for ACTION B and the inclusion of ITS 3.6.8 " Hydrogen Skimmer System" and ITS 3.6.0 "Hydrogsn !gnition System" (Catawba); " Hydrogen Mitigation System"

-(McGuire), it:would seem that STS 3.6.8 ACTION B would be applicable for use at i

Catawba and McGuire. See Comment Number 3.6.8-2. Comment: Provide additional -

discussion and justification as to why STS 3.6.8 ACTION B is not applicable at McGuireL g

and Catawba. See Comment Number 3.6.8-2.

Cec Response:

l 3.6.8 Hydrogen Skimmer System -

4 3.6.9-1 DOC A.1 DOC A.22-h CTS 4.6.5.6.1.f ITS SR 3.6.8.3 CTS 4.6.5.6.1.f verifies that the motor operated valve in the hydrogen skimmer suction line opens automatically and the hydrogen skimmer fans receive a start permissive signal. In-converting to ITS SR 3.6.8.3 changes are made to CTS 4.6.5.6.1.f to define that the permissive signalis from the Containmont Pressure Control System. In McGuire Units 1 and 2 this change is designated DOC A.1; In Catawba Units 1 and 2 this change is -

designated AOC A.22. The DOC A.1 derignation in the McGuire marku,s is the incorrect

[

- justification for this change: DOC A.22 is the correct justification. In both the McGuire and

- Catawba markupr DOC A.22 writeup does not discuss CTS 4.6.5.6.1.f. ' Comment:

b Revise the McGuire CTS markup of CTS 4.6.5.6.1.f to show the change as DOC A.22.

j

_ Revise DOC A.22 for both McGuire and Catawba to reference the changes made to CTS L

4.6.5.6.1.f.

4

]-

MC2_CR_3.6 3.6-15 January 28,1998-1

McGuire & Catawba improved TS Review Comments ITS Section 3 8, Containment Systems DEC Response:

3.6.8 2 JFD 3 JFD Bases 3 JFD Bases 4 (McGuire)

STS 3.6.9 ACTION B and Associated Bases ITS 3.6.8 ACTIONS STS 3.6.9 ACTION B provides the remedial actions for two Hydrogen Skimmer Systems inoperable. The discussion in Comment Number 3.6.7 3 also applies here only the ITSs involved are ITS 3.6.7 " Hydrogen Recombiners" and ITS 3.6.9.- Comment:- See Comment Number 3.6.7-3.

- DEC Response:

3.6.9 Hydrogen Mitigation System (McGuire only)-

3.6.9 1 DOC M.8 (Catawba)

' CTS 3.6.4.3 ACTIONS I-ITS 3.6.9 ACTION C CTS 3.6.4.3 ' ACTIONS provide the remedial measures to be taken for one train of the Hydrogen Mitigation System inoperable, if these remedial measures cannot be satisfied, CTS 3.0.3 must be entered which recuires action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or shutdown to MODE 3 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.6.9 reqaires that if the same remedial measures (RA A.1 and RA A.2) cannot be met the plant must be placed in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This same -

type of change in Catawba was characterized as a More Restrictive (M.8) change which was found acceptable. Comment: Revise t'.e McGuire CTS markup to show the change as More Restrictive and provide the appropriate justification and discussion.

DEC Response:

3.6.10 Annulus Venti!ation System (AVS!

MC 2_CR_3.6 3.6-16 January 28,1998 1

McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.8.10 1-DOC A.1 DOC A.5 (Section 1.0)

CTS 1.27 ITS 3.6.10 CTS _'1.27 provides the definition for Reactor Building integrity, and is justified by DOC A.5 -

as deleted on the CTS markup of ITS 1.0. This is incorrect. The definition is part of the technical specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.27 should be included in the CTS markup of ITS 3.6.10. CTSo 1.27.a and 1.27.c become part of ITS 3.6.1.6 and is considered an Administrative change (DOC A.1). -(See Comment Numbers 3.6.161 and 3.6.16 2) CTS 1.27 b becomes ITS LCO 3.6.10 and la an Administrative change (DOC A.1) Comment: Revise the CTS markup of ITS 3.6.10 to include an appropriate markup of CTS-_1.27 and provide any additional discussion and justification for thuse Administrative changes. See Comment Numbers 3.6.161 and 3.6,16 2.

DEC Response:

-3.8.10 2-DOC A.25 -

(Catawba only) DOC L.28 J

CTS 4.6.1.8.d.2 ITS SR 3.6.10.3 CTS 4.6.1.8.d.2 verifies that the AVS starts automatically on any safety injection test -

signal.-- The CTS is revised to state that an actual as well as a simulated test signal may be

used in performing this surveillance in the ITS (ITS SR 3.6.10.3). The change in the CTS markup is designated DOC L.28. The justification DOC L.28 describes this change, in addition, DOC A.25 describes this change to CTS 4.6.1.8.d.2, but the markup of CTS

= 4.6.1.8.d.2 does not show an A.25. The staff considers this change to be a Less Restnetive change rather than an Administrative change. Comment: Delete justification DOC A.25.

DEC Response: -

3.6.10-3 DOC LA.13 (Catawba only)

CTS 4.6.1.8 d.3 11S SR 3.6.10.4 and Associated Bases CTS 4.6.1.8.d.3 requires verifying that the AVS filter cooling electric motor-operated bypass valves can be manually opened.- The term " manually" has not been retained in ITS SR 3.6.10.4. DOC LA.13 states that the term " manually" will be placed in the Bases for MC2_CR_3.6 3.6-17 January 28,1998

l McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems ITS 3.6.10. The term " manually" or reference to manual bypass valve operation could not -

be found in the Bases for ITS 3.6.10. Comment: Revise the Bases to adopt the term manually" or provide additional discussion justifying the deletion of the word, b

DEC Response:

3.6.10-4 JFD 9 JFD Bases 5 CTS 4.6.1.8.b.3 STS SR 3.6.13.5 and Associated Bases CTS 4.6.1.8.b.3 verifles each AVS train flow rate is 8000 cfm i 10% during system operation. STS SR 3.6.13.5 performs this same surveillance. ITS 3.6.10 does not include STS SR 3.6.13.5 based on the justification (JFD 9) that the flow test is covered by ITS SR 3.6.10.2. ITS SR 3.6.14.2 only tests the filter trains, it does not test the system as a whole. The staff finds the deletion of STS SR 3.6.13.5 from the ITS as unacceptable, and is considered as a generic change which is beyond the scope of review for this conversion.

Comment: Delete this generic change.

DEC Comment:

3.6.12 Ice Bed 3.6.12 1 DOC L.26 (McGuire only)

JFD 1 JFD Bases 1 CTS 4.6.5.1.b.1 ITS SR 3.6.12.5 and Associated Bases CTS 4.6.5.1.b.1 requires a chemical analyses of the stored ice to verify boron concentration and ph at least once per 9 months. The CTS markup indicates a proposed change of frequency from 9 to 18 months in conformance nith the STS. DOC L.26 provides the justification for the proposed change which is acceptable. The markup for corresponding ITS SR 3.6.12.5 shows the Frequency as 9 months. The Bases and " clean" ITS versions show the Frt,quency to be 18 months. See Comment Number 3.6.12-2.

Comment

• Correct this discrepancy. See Comment Number 3.6.12-2.

DEC Response:

MC2,CR_3.6 3.6-18 January 28,1998

McGuire & Catawba improved TS Review Comments iTS Section 3.6, Containment Systems

?.6.12 2 DOC L.26 J JFD 1 =

JFD Bases 1 -

JFD Bases 3 (Catawba)

- CTS 4.6.5.1.b.1 ITS SR 3.6.12.5 and ^ asociated Bases CTS 4.6.5.1.b.1 requires a chemical analyses of the stored ice to verify boron concentration and ph at least once per 9 months. The Catawba CTS markup does not change this frequency to 18 months but retains the 9 month frequency in ITS SR 3.6.10.3.

The same surveillance in the McGuire ITS (SR 3.6.12.5) has a frequency of 18 months

- (See Comment Number 3.6.121). The Justification provided in the McGuire CTS markup -

(DOC L.26) for the frequency change would seem to apply as well to Catawba. Comment:

Provide additional discussion and juctification to show why the frequency c' enge for CTS 4.6.5.1.b.1 only applies to McGuire and not to Catawba as well. The diset. dion should-include any design differences or characteristics between McGuire and Catawba which would either allow the change to be implemented at Catawba, or require McGuire to retain the CTS frequency of 9 months.

DEC Response:

l t

3.6.12 3 DOC LA.14 CTS 4.6.5.1.b 2 (McGuire)

CTS 4.6.5.1.c (Catawba)

ITS SR 3.6.12.2, SR 3.6.12.3 and Associated Bases (McGuire).

ITS SR 3.6.12.4, SR 3.6.12.5 and Associated Bases (Catawba)

- CTS 4.6.5.1.b.2 (McGuire) and CTS 4.6.5.1.c (Catawba) require verifying that the minimum average ice weight of a repretentative sample of ice baskets shall not be less -

than 1081 (McGuire)/1273_ (Catawba) pounds per basket at a 95% level of confidence.

- The CTS markup indicates that "at a 95% level of confidence" was not retained in corresponding ITS SR 3.6.12.2.s and SR 3.632.iil for UlcGuire and SR 3.6.12.4.a for

~

~

Catawba but instead was relocated to the Bases. However, "at a 95% level of confidence

" was in fact retained in corresponding ITS SR 3.6.12.2a, and SR 3.6.12.3 for MCGuire and SR 3.6.12.4.a and SR 3.6.12.5 for Catawba. The CTS markup is in error. Comment:

Revise the submittal to correct the CTS markup.

DEC Response:

MC2_CR_3.6 3.6-19 January 28,1998 1

I o

Moduire & Catawba Improved TS Review Comments ITS Section 3.6, Contalnment Systems 3.6.12-4 DOC LA.14 CTS 4.6.5.b.1 ITS B3.6.12 Bases SR 3.6.12.5 (McGuire)

ITS B3.6.12 Bases SR 3.6.12.3 (Catawba).

CTS 4.6.5.b.1 requires verifying that the stored ice has a ph of 9.0 to 9.5 at 20*C "at 25' C for Catawba). The CTS markup proposes to place " at 20' C" ("at 25'C" for Catawba) in the Bases. Howaver, "at 20*C" ("at 25'C" for Catawba) could not be fotnd in the Basas for ITS SR 3.6.12.5 (SR 3.6.12.3 for Catawba). Comment: Revise the Bases to include this temperature limit or provide additional discussion and justification with regards to its dele' ion.

DEC Response:

3.6.12 5 CTS 4.6.5.1.c (McGuire)

CTS 4.6.5.1.d (Catawba)

ITS SR 3.6.12.6 and Associated Bases CTS 4.6.5.1.c (McGuire)/ CTS 4.6.5.1.d (Catawba) requires visually inspectinq the

" accessible portions" of at least two ice baskets. The phrase " access!ble portions" has not ' ~

been adopted in ITS SR 3.6.12.6 or its Associated Bases. No justification has been provided for the proposed change. The deletion of this phrase would make ITS SR 3.6 5 2.6 More P.estrictive that the CTS; while relocating it to the Bases would make the change Less Restrictive (LA). Comment: Revise the CTS markup and provide the appropriate discussion and justification for this More/Less Restrictive change.

DEC Response:

3.6.13 Ice Condenser Doors 3.6.13 1 DQC A.1 CTS 4.6.5.3.2.a ITS SR 3.6.13.2 CTS 4.6.5.3.2.a requires verifying that the intermediate deck doors are free of frost accumulation. ITS SR 3.6.13.2 requires verifying that the doors are not impaired by ice, frost, or debria. The proposed change has been categorized as an Administrative format change (DOC A.1). Thc proposed change is not an Administrative change but a More Restrictive change since it adds requirements (ice and debris). Comment: Revise the CTS markup and provide the appropriate discussion and juntification for this More Restrictive change. Revise the CTS markup and provide the appropriate discussion and justification for this More Restrictive change.

MC2_CR_3.6 3.6-20 January 28,1998

McGuire & Catawba improved TS Review Comments ITS Section 3.6, Contelnment Systems DEC Response:

3.6.13 2 DOC A.1 CTS 4.6.5.3.3.b iTS GR 3.6.13.3.b (McGuire)

ITS SR 3.6.13.7 (Catawba)

CTS 4.6.5.3.3.b requires verifying that no condensation, frost, or ice has formed on the top deck doors or blankets. ITS SR 3.6.13.3 b (McGt,lre)/SR 3.6.13.7 (Catawba) only i

addresses the do!,rs; it does not address the b!snkets. The proposed change has been categorized as an Administrative format change (DOC A.1). The proposed change is not an Administrative change but a Less Restrictive change. Comment: Revisa the CTS markup and provide the tppropriate discussion and justification for '.is Less Restrictive change.

DEC Response:

3.6.13 3 A.28 CTS 4.6.5.3.1.a ITS SR 3.6.13.1 4

CTS 4.6.5.3.1.s rsquires that the ice condenser inlet doors be continuously monitored and determined closed by the inlet door position monitoring system. ITS SR 3.6.13.1 requires verifying allinlet doors incllcate closed by the inlet Door Monitoring System with a frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed change has been categorized as an Administrative change (DOC A.28). The proposed change is not an Administrative change but a Less Restrictive change (Continuous to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). Comment: Revise the CTS markup and provide the appropriate discussion and Justification for this Less Restrictive change.

DEC nesponse:

3.6.13 4 DOC M 4 CTS 3.6.5.3 ACTION b ITS 3.6.13 ACTION D CTS 3.6.5.3 ACTION b requires that vilth one or more ice condenser doors inoperable (not capable of automatic opening) and not restored to OPERAGLE status, that the unit be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.6.13 only requires the unit to be 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 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The requirement to be in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the commencement of a shutdown has been delsted. The justification (DOC M.4) used states that the deletion is a MC.? CR_3.6 3.6 21 January 28,1998 0

~

~

O

• ~*

Mooulte & Catawba improved 78 Review Comments -

ITS Section 3.8, Containment Systems More Restrictive change. This is incorrect. The change is Less Restrictive, since the ITS does not specify a time limit in which to reach MODE 4. Comment: Revise the CTS merkup and provide additional discussion and justification for this Less Restrict!ve change.

DEC Response: -

3.8.13 5

'JFD Base 4 -

ITS 83.6.13 Bases SR 3.6.13.2 ITS B3.6.13 Bases SR 3.6.13.2 has an insert which references ITS SR 3.5.13.7. The correct reference appears to be ITS SR 3.6.13.6. Note: Resolution of this item is dependent on resolution of Comment Number 3.6.13 8. Commer.t: Correct this d6screpancy. See Comment Number 3.6.13 8.

- DEC Response:--

3.6.13 6 JFD Bases 11 STS B3.6.16 Bases RA B.1 and B.2 and RA C.1 ITS B3.6.16 Bases RA B.1 and B.2 and RA C.1 The last senteice in STS B3.6.16 Bases -~ RA B.1 and B.2 states the following: "If this -

verification is not m&de Required Actions D.1 and D.2 not: Required Action C.1 must be taken." In addition, the last sentence in STS B3.6.16 Dases RA C.1 states the following:

" Condition C is entered from Condition B only when the Completion Tirne of Required Action B.2 is not met'or when the ice bed temperature has not been verified at the required -

frequency." Both of these statements have been ueleted from ITS B3.6.16 B9ses RA B.1 and B.2 and RA C.1 respectively.= The justification for this deletion (JFD Bases 11) states that the Bases de cussions are not consistent with the specification nor with the rules of

' Completion Times an' defined in NUREG Section 1.3. The staff believes thst the two statements are correct and need to remain. The staff's interpretation of the statements is

- that if the ice bed temperature is not surveilled in accordann with the frequet.cy limitation specifiod in ITS SR 3.0.2.iue to forgetfulness ~ or inattention to ACTION requirements, rather than inability to perform surveillance, a shutdown is required, rather than allowing an

additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the ice condenser door to OPERABLE status, in addition, the i

- staff considers the change to be generic and beyond tha scope of rev!sw for this

- conversion. Comment: Delete this generlc change.

DEC Response:

MC2,,CR_3.6

- 3.C 22 January 28,1998

)

i McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.13 7

- CTS 3.6.5,3 ACTION b ITS 3.6.13 Condition A i

CTS 3.6.5.3 ACTION b states that *With one or more ice condenser doors inoperable (not capable of opening automatically), restore all doors to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />."

The CTS markup shows this statement being converted to ITS 3.6.13 ACTION A. ITS i

3.6.13 Condition A only applies to Ice condsneer inlet doors while CTS 3.6.5.3 ACTION b applies to all ice condenser dorc e No justification is provided for this Less Restrictive change the other doors encompassed by CTS 3.6.5.3 ACTION b would fall under ITS l

3.6.13 ACTION B. Comment: Revise the CTS markup and provide additional discussion and justification for this Less Restrictive change.

DEC Response:

3.6.13 8-ITS SRs 3.6.13.3,4,5,6 and 7 and associated Bases

-(Catawba only)

ITS SR 3.6.13.7 has a frequency of 92 days. ITS SR 3.6.13.3 through SR 3.6.13.6 have a frequency of 18 months. ITS SR 3.6.13.7 is !n the incorrect position per the requirement

.of the writer's guide. The McGuire ITS has these SRs in the correct order. Comment:

Renumber the SRs in ITS 3.6.13 to conform to the writer's guide. See Comment Numoer 3.6.13 5.

DEC Response:

3.6.14 Divid:t Barrier 1.veertty 3.6.14 1 DOC A.1 -

CTS 3.6.5.5 I

CTS 3.6.5.9 lTS LCO 3.6.14 and Associated Bases CTS 3.0.5.5 specifies that the personnel access doors and equipment hatches between the containment's upper and lower compartments shall be OPERABLE and closed. CTS 3.6.5.9 specifies that the divider barrier seal shall bo OPERABLE. These requirements have not been retained in corresponding ITS LCO 3.6.14, but instead have been placed in the Bases

- BACKGROUND discussion for ITS 33.6.14. The proposed changes have been ategorized as en Administrative change. The proposed changes are Less Restrictive (LA) changes.

Comment: Revise the submittal and provide the appropriate discussion and justification for

= these Less Restrictive changes.-

- DEC Response:

MC2_CR_3.6 3.6 23 January 28,1998

. +.

McGuire & Catawba improved 78 Review Comments I

l ITS Section 3.8, Containment Systems 3.8.14 2-DOC A.29 t

CTS 3.6.5.5 ACTION (McGuire)-

j CTS 3.6.5.0 ACTION c (Catawba)

ITS 3.6.1.4 Condition A Note CTS 3.6.5.5 ACTION (McGuire) and ACT;0N a (Catawba) provide the.w. 'rements in the event that a personnel access door or equipment hatch is inoporrsble or e+a except for l

personnel transit entry. The CTS markup indicates that this is ITS 3.6.14 ACTION A. The Note for ITS 3.6.14 Condition A states that

• separate Condition entry is allowed for each -

personnel access door or equipment hatch." The proposed change has been categorized as an Administrative change. TN. Is incorrect. The wording of the CTS 3.6.5.5 ACTIONS do not indicate that a separate condition entry is allowed in the CTS, as would be allowed in j

the containment isolation vo:ve CTS. In this case, if more than one access door or hatch is INDPERABLE, CTS 3.0.3 is entered. Thus, the proposed change is Less Restrictive.

-Comment: Revise the submittal and provide the appropriate discussion and justification for

(

this Less Restrictive change.

DEC Response:

3.8.14 3-JFD Bases 4

- STF, B3.6.17 Bases APPLICABLE SAFETY ANALYSES l

ITS B3.6.14 Bases - APPLICABLE SAFETY ANALYSES ITS B3.6.14 Bases - APPLICABLE SAFETY ANALYSES makes a number of changes tothe second paragraph of STS B3.6.17 Bases APPLICABLE SAFETY ANALYSES based on the plant :'scific design. The changes made to Catawba ITS Bases are identical to the l

McGuire ITS Bases changes except in one spot. In the second sentence of the,,econd

-l l paragraph, the STS states the following: "...Inoperability of one train in both Containment Spray System..."' in McGuire the word *both" is deleted while in Catawba it is retained.

Comment: Correct this discrepancy between the plants or provide additional discussion to

. Justify this difference.

DEC Response:

3.8.18 Containment Recirculation Drains i

MC2,,CR_3.6 3.6 24 January 28,1998 l -

I

j i

i i

i McGuire & Catem be improved TS Review Comments

. lTS Sectio i 3.8, Containment Systems

)

3.8.15 1 DOC M.6 l

CTS 4.6.5.8 (McGuire Unit 2)

The CTS markup of CTS 4.5.6.8 in McGuire Unit 2 shows a change of "once per g2 days"

)

i being added. The change is designated as DOC M.6. This change does not seem to be associated with any ITS 3.6.15 item nor is it shown in the CTS markups of McGuire Unit 1 i

or Catas 4a Units 1 and 2 which have the same specification. The justification associated with DOC M.6 is "Not used." Comment: Correct this discrepancy and provide the appropriate discussion and justification for this change.

j _

DEC Rosesponse:

4 l

l l

3.6.15 2 JFD Bases 5 (McGuire)

ITS SR 3.6.15.1 i

STS B3.6.18 Bases LCO

(

i.

ITS B3.6.15 Bases LCO.

I r

STS B3.6.18 Bases LCO states the following: "The refueling canal dr ia ns mush have their

^

plugs removed and remain clear to ensure...". ITS B3.6.15 Bases LCO for McGuire changes this statement to conform to the plant specific changes made in ITS SR 3.6.15.1 1

to read as follows: "The refueling canal drain valves must be locked open and remain clear to ensure...".-- This change is acceptable. However, this Bases change has not been i -

incorporated into ITS B3.6.15 Bases LCO for Catawba. Since the same plant specific changes that were made to ITS SR 3.6.15.1 for McGuire arc made to ITS SR 3.6.15.1 for Catawba, the changes made to ITS 83.6.15 Bases LCO for McGuire should De made to -

1 ITS D3.6.15 Bases LCO for Catawba Comment: Revise the ITS B3.6.15 Bases LCO for -

Catawba to conform to ITS B3.6.15 Bases LCO for McGuire or provide appropriate discussion and justification to show why they should not be the same. See Comment Number 3.6.15 3.

4f DEC Response:

i 3.8.15 3 JFD Bases 5 ITS SR 3.6.15.1

~

STS B3.6.18 Bases SR 3.6.18.1

-lTS B3.6.15 Bases - SR 3.6.15.1 and SR 3.6.15.2 l

STS B3.6.18 Bases - SR 3.6.18.1 states the following in the fourth sentence:. "SR-.

3.6.18.1 must be performed...from MODE 5 after every filling of the canal to ensure that

- the plugs have been removed and that..." ITS B3.6.15 Bases SR 3.6.15.1 and SR 13.6.15.2 for McGuire modifies this statement to conform to plant specific changes made to t

MC2iCR_3.6 3.6 25 January 28,1998 1

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McGuire Si Catawba improved TS Review Comments ITS Sectlen 3.0, Containment Systems i

i (TS SR 3.6.15.1 to the following:

...from MODE 5 after every filling of the canal to ensure that the valves have been lucked open and that...". The same sentence in ITS 83.6.15 Bases SR 3.6.15.1 and SR 3.6.15.2 for Catawba has not been modified; yet the 1-same plant specific changes made to ITS SR 3.6.15.1 in McGuire hav6 been made in ITS SR 3.6.15.1 in Catawba as well as other plant specific changes made to the Dases for both i

l Cataba and McGuire that change " plugs" to " valves." Comment: Revise the Catawba u

ITS B3.6.15 Etaes SR 3.6.15.1 and SR 3.6.15.2 to conform to tha McGuire Bases. See t

[

Comment Number 3.6.15 2.

l i

[

DEC Response:

s 4

3.6.16 Reactor Buildine 3.8.18 1 DOC A.5 (ITS 1.0) i CTS 1.27 y

ITS 3.6.16 and Associated Basea

. CTS 1.27 ptovides the definition for Reactor Building Integrity, and is justified by DOC A.5

[

as deleted in the CTS markup of ITS 1.0. This is incorrect. The definition is part of the -

Technical Specifications and as such delineates CTS requirements. Therefore, an appropriate markup of CTS 1.27 shnuld be included in the CTS markup of ITS 3.6.16. CTS 1.27.a becomes ITS SR 3.6.16.1 (See Comment Number 3.6.16 2) and is an Administrative change. - CTS 1.27.b becomes ITS LCO 3.6.10 and is an Administrative -

t change (DOC A.1) (See Comment Number 3.6.10.1). CTS 1.27.c as a minimum would be I

relocated to the Bases of ITS 3.6.16 and would be a Less Restrictive (LA) change.

+

4 Comment: Revise the CTS markup of ITS 3.6.16 to include an appropriate markup of CTS 1.27 and provide the appropriate discussions and justifications for these Administrative and Less Restrictive (LA) chances. See Cnmment Numbers 3.6.10-1 and 3.6.16 2.

DEC Response:

d 3.6.18 2 DOC A.5 (Section 1.0):

DOC M.7 JFD 3 JFD Bases 2 JFD Base 3 CTS 1.27.a _.

STS SR 3.6.1.g.2 ITS SR 3.6.16.1'and Associated Bases g

CTS 1.27 provides the definition for Reactor Building integrity and is justified by DOC A 5 l

as deleted in the CTS roarkup of ITS 1.0. This is incorrect. The definition is part of the

{

MC2_CR_3.6 3.6 26 January 28,1998 i

_ _... _..... _ _. _, _. _.. _,i..__..;__....,_.___._._...____.;,._.______.-.___

._.,.,m_-_

G McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems technical specifications and as such delineates CTS requirements. Ther6 fore en appropriate markup of CTS 1.27 saould b6 included in CTS markup of ITS 3.6.16 (See Comment Number 3.6.161). CTS 1.27.a is the same requirement and used basicati the same words as STS SR 3.6.19.2. Therefore the addition of ITS SR 3.6.16.1 is not a More Restrictive change but an Administrative change. The addition of the frequency of 31 days is however, a More Restrictive change in addition, STS SR 3.6.19.2 requires verifying that each door in each access opening is closed, except when the access opening is being used for normal entry and wxit; "then, at least one door shall be closed". ITS SR 3.6.16.1 deletes the phrase "then, at least one door shall be closed" based on the JFD 3 which states that this requirement is not applicable to the facility. The Bases for ITS SR 3.6.16.1 also deletes this requirement. This is incorrect since CTS 1.27.a has these words.

Comment: Revise the CTS markup according to the above discussion (See Comment Number 3.6.101), delete the change to ITS SR 3.6.16.1 and its Associated Bases that deletes the phrase "then, at least one door shall be closed," and provide any additional discussions and justifications to support these required changes.

DEC Response:

3.6.16 3 DOC A 33 (Catawba only)

DOC A.35 JFD 1 CTS 4.6.1.7 ITS SR 3.6.16.3 and associated Bases CTS 4.6.1.7 requires a visual inspection of the reactor building structuraiintegrity on a frequency equivalunt to 10 CFR 50 Appendix J, Option A for Type A tests. The CTS and ITS markups are modified to reflect this frequency. The change in the CTS markup for Catawba Unlt 1 is designated DOC A.35 and for Catawba Unit 2 DOC A.33. The ITS markup is designated JFD 1 and no designallon/lustification is provided in ths Bases for ITS SR 3.6.16.3. The justifica5tions for DOC A 33 states it's not used and for DOC A.35 the justification references ITS SR 3.6.16.2 not SR 3.6.16.3. lne changes made in the McGuire Bases for this SR are designated JFD Bases 1, JFD Bases 4 and JFD Bases 5.

Comt. Ant: Revise the CTS /ITS submittal to make all units / plants changes / justifications consistent. Provide any additional d!seus11on and justification as necessary.

DEC Response:

MC 2_CR_3.6 3.6 27 January 28,1998

e'. '. '

McGuire & Catawba improved T8 Review Comments ITS Section 3.6, Contelnment Systems 3.6.16 4 DOC A.35 CTS 4.6.1.7 ITS SR 3.6.16.2 and Associated Bases CTS 4.6.1.7 for McGuire is converted to ITS SR 3.6.16.2. Based on the Writers Guide with regards to SR order, this SR should be SR 3.6.16.3 as was done on the Catawba ITS.

Comment: Renumber the SRs in accordance with the Writer's Guide and revise and update l

DOC A.35 to conform to the new numbering.

DEC Response:

3.6.16 5 JFD Bases 9 (Catawba only)

A justification JFD Bases 9 is provided and discussed in the listing of justifications.

However no JFD Bases 9 is shown in the ITS Bases for Catawba; there is a JFD Bases 9 shown in McGuire ITS B3.6.16 Bases SR 3.6.16.3. Comment: Either indicate where JFD Base 9 is located in the Catawba ITS Bases or delete the item.

DEC Response:

3.6.17 Containment Velves injection Water System (CVlWS) (Catawba only) 3.6.17 1 DOC A.36 DOC L.28 CTS 4.6.6.2 ITS SR 3.6.17.3 CTS 4.6.6.2 requires that each automatic valve in the flow path actuate to its correct position on a Containment Pressure-High or a Containment Pressure High High test signal.

ITS SR 3.6.17.3 specifies actuaticn on an actual or simulated actuation signal. The proposed change nas been categorized as an Administrative change. The staff considers this proposed change as a Less Restrictive change and that DOC L.28 is the appropriate justification to use. See Comment Number 3.6.10 2. Comment: Revise the submittal to provide ths appropriate justification (DOC L.28) for this Lesa Restrictive change.

DEC Response:

M C 2_C R_3.6 3.6 28 January 28,1998

4

)

g McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3.6.17 2 DOC L.23 JFD 5 JFD Bases 5 CTS 4.6.6.1 ITS SR 3.6.17.1 and Associated Bases CTS 4.6.6.1 requires verifying that the CVlWS is pressurized to greater than or equal to 16.2 psig and has adequate capacity to mainteln system pressure for at least 30 days. ITS SR 3.6.17.1 changes this requirement to require verifying that the system surge tanks are pressurized to 236.4 psig. This change as discussed in DOC L.23 is based on a one pump configuration rather than the two pump configuration used for the current licensing basis.

The staff considers this proposed change as a beyond scope of review item for this conversion. Comment: Delete this change and modify the CTS /ITS markup to conform to the CTS requirements. Provide any additional discussions and justification as necessary.

DEC Response:

3.6,17 3 DOC L.23 JFD 5 JFD Bases 5 CTS 4.6.6.2 ITS SR 3.6.17.2 CTS 4.6.6.2 requires verifying that the CVlWS valve sealinjection flow rate is less than 1.7 gpm for Train A and 1.4 gpm for Train B with a tank pressure greater than or equal to 45 psig, iTS SR 3.6.17.2 changes this requirement to require verifying that the valve injection flow rate is < 1.09 gpm for Train A and 1.16 gpm for Train B (for Unit 1) and <

1.21 gpm for Train A and 1.16 gpm for Train B for Unit 2with a surge tank pressure of a 36.4 psig. This change as discussed in DOC L.23 is based on a one pump configuration rather than the two pump configuration used for the current licensing basis. The staff corisiders this a beyoad scope of review item for thir conversion. Comment: Delete this change and modify the CTS /ITS markups to conform to the CTS requirements. Provide any additional discussions a d,ustifications as necessary.

DEC Response: -

CTS 3/4.6.4.1 Hydrogen Monitors

_=

MC2_CR_3.6 '

3.6-29 January 28,1998

e,*

McGuire & Catawba improved TS Review Comments ITS Section 3.6, Containment Systems 3/4.6.4.1 1 DOC None CTS 3/4.6.4.1 The markup for CTS 3/4.6.4.1 " Hydrogen Monitors" shows that this specification is to be relocated to ITS 3.3.3. No justification is provided for this Administrative change.

Comment: Provide a discussion and justification for thle Auministrative change.

DEC Response:

i l

MC 2_C R_3.6 3.6 30 January 28,1998

_