Text

Application to Revise Technical Specifications to Adopt TSTF-582, Revision 0, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
	ML21109A113
Person / Time
Site:	FitzPatrick
Issue date:	04/16/2021
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	JAFP-21-0028
	Download: ML21109A113 (49)
	v • d • e

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-21-0028 April 16, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Application to Revise Technical Specifications to Adopt TSTF-582, Revision 0 "Reactor Pressure Vessel Water Inventory Control (RPV WIC)

Enhancements" Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, or early site permit, Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No.

DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

Exelon requests adoption of TSTF-582, Revision 0, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The TS related to RPV WIC are being revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides the existing TS Bases pages marked up to show revised text associated with the proposed TS changes and is provided for information only.

The proposed changes have been reviewed and approved by the sites Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon requests that the amendment requests be reviewed under the Consolidated Line Item Improvement Process (CLIIP).

Exelon requests approval of the proposed amendments by December 31, 2021, in support of the refueling outage scheduled to begin on September 2022. Once approved, the amendments shall be implemented within 60 days.

License Amendment Request Adopt TSTF-582 RPV WIC Enhancements Docket No. 50-333 April 16, 2021 Page 2 There are no regulatory commitments contained in this submittal.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendments by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Enrique Villar at 610-765-5736.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of April 2021.

Respectfully, David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Proposed Technical Specification Bases Changes (Mark-Up) -

For Information Only cc: Regional Administrator - NRC Region I w/ Attachments NRC Senior Resident Inspector - JAF "

NRC Project Manager, NRR "

A. L. Peterson, NYSERDA "

B. Frymire, NYSPSC "

ENCLOSURE License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Application to Revise Technical Specifications to Adopt TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Description and Assessment

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 1 of 7 Docket No. 50-333 Description and Assessment

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, or early site permit, Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-59 for James A. FitzPatrick Nuclear Power Plan (JAF).

Exelon requests adoption of TSTF-582, Revision 0, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" (Reference 1). The TS related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 2).

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Exelon has reviewed the NRC safety evaluation for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020 (Reference 3). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. Exelon has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to JAF and justify this amendment for incorporation of the changes to the JAF TS.

Exelon verifies that the required ECCS injection/spray subsystem can be aligned, and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room following plant procedures.

2.2 Optional Changes and Variations Exelon is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation.

TSTF-582 JAF TS JAF TS Technical Specification Section Title (NUREG1433 Applicability Definitions Drain Time Revised Drain Time Yes / Revised RPV Water Inventory Control Instrumentation 3.3.5.2A 3.3.5.2 3.3.5.2.A. A Deleted 3.3.5.2.A Yes / Deleted 3.3.5.2.A. B Renamed 3.3.5.2.B Yes / Renamed 3.3.5.2.A. C Deleted 3.3.5.2.C Yes / Deleted 3.3.5.2.A. D Deleted 3.3.2.5.D Yes / Deleted

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 2 of 7 Docket No. 50-333 Description and Assessment TSTF-582 JAF TS JAF TS Technical Specification Section Title (NUREG1433 Applicability 3.3.5.2.A. E Deleted 3.3.2.5.E Yes / Deleted Surveillance Note Revised Surveillance note Yes / Revised SR 3.3.5.2.3 Deleted N/A JAF does not contain this SR Table 3.3.5.2-1 Function 1 Core Spray Deleted Core Spray Yes / Deleted Function 2 Low Pressure Coolant Injection (LPCI) Deleted Low Pressure Yes / Deleted System Coolant Injection (LPCI) System Renumber rest of functions and deleted note (a) and Yes / Deleted renumber note (b) and Renumbered ECCS - Operating NUREG 1434/BWR-6) 3.5.1 3.5.1 ACTION Revised ACTION Yes / Revised RPV Water Inventory Control 3.5.2 3.5.2 3.5.2.C. C3 Revised 3.5.2.C3 Yes / Revised 3.5.2.D. D3 Revised 3.5.2.D3 Yes / Revised 3.5.2. D. D4 Revised 3.5.2. D4 Yes / Revised SR 3.5.2.2 Revised SR 3.5.2.2 Yes / Revised SR 3.5.2.5 Deleted SR 3.5.2.5 Yes / Deleted

SR 3.5.2.6 Revised and SR 3.5.2.6 Yes -Not Renumbered renumbered SR 3.5.2.7 Renumbered SR 3.5.2.7 Not renumbered SR 3.5.2.8 Renumbered SR 3.5.2.8 Not renumbered Primary Containment Isolation Valves (PCIVs) 3.6.1.3 3.6.1.3 Applicability Revised Applicability Yes / Revised 3.6.1.3. F Revised 3.6.1.3. F Yes / Revised 3.6.1.3. G Deleted 3.6.1.3. G Yes / Deleted

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 3 of 7 Docket No. 50-333 Description and Assessment TSTF-582 JAF TS JAF TS Technical Specification Section Title (NUREG1433 Applicability 3.6.1.3. H Deleted N/A JAF does not contain this Condition SR 3.6.1.3.1 Revised N/A JAF does not contain this SR SR 3.6.1.3.2 Revised SR 3.6.1.3.1 JAF does not contain this NOTE SR 3.6.1.3.7 Revised N/A JAF does not contain this SR SR 3.6.1.3.13 Revised SR 3.6.1.3.10 JAF does not contain this NOTE SR 3.6.1.3.12 N/A JAF does not contain this SR SR 3.6.1.3.13 Revised SR 3.6.1.3.10 JAF does not contain this NOTE SR 3.6.1.3.14 Revised N/A JAF does not contain this SR SR 3.6.1.3.15 Revised N/A JAF does not contain this SR AC Sources - Shutdown 3.8.2 3.8.2 SR 3.8.2.1 Revised SR 3.8.2.1 Yes Additionally:

1. The model application provided in TSTF-582 includes an attachment for typed, camera-ready (revised) TS pages reflecting the proposed changes. JAF is not including such an attachment due to the number of TS pages included in this submittal that have the potential to be affected by other unrelated license amendment requests and the straightforward nature of the proposed changes. Providing only mark-ups of the proposed TS changes satisfies the requirements of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," in that the mark-ups fully describe the changes desired. This is an administrative deviation from TSTF-582 with no impact on the NRC's model safety evaluation published on August 13, 2020. As a result of this deviation, the contents and numbering of the attachments for this amendment request differ from the attachments specified in the model application in TSTF-582.

2. TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable in Modes 1, 2, and 3, and when the associated diesel generator is required to be operable by TS 3.8.2. TSTF-582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal. Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 4 of 7 Docket No. 50-333 Description and Assessment include the specified condition, "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources - Shutdown'."

3. JAF TS SR 3.8.1.13 state, Verify interval between each sequenced load block is greater than or equal to the minimum design load interval. TSTF-582 retained SR 3.8.1.18 (Equivalent to JAF SR 3.8.1.13) as a test that must be met but not performed. The relay logic schemes that perform a function equivalent to a load sequencer are only used for the automatic start and loading of the diesel generator and are not used during a manual diesel generator start. Therefore, JAF SR 3.8.1.13 is added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1. This SR is not included under SR 3.8.2.1

4. The LCO 3.8.2 and SR 3.8.2.1 Bases are revised to reflect the TS requirements. This variation provides consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.2.1.

5. As an editorial improvement, SR 3.8.2.1 is revised to list the TS 3.8.1 SRs that are applicable instead of listing the TS 3.8.1 SRs that are not applicable. The SR 3.8.2.1 Bases are not affected and explain why the omitted TS 3.8.1 SRs are not applicable to TS 3.8.2

Applicable to JAF; however, JAF will delete verbiage associated with the SR and annotate this SR as Not Used. The remaining SRs numbers will not be revised to avoid an excessive administrative burden to update station procedure where these SRs may be Optional Changes and variations - referenced.

The variations identified above are administrative in nature and do not affect the applicability of TSTF-582 to the JAF TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plan (JAF).

Exelon requests adoption of TSTF-582, Revision 0, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The TS related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

TSTF-582 includes the following changes to the TS:

1. The TS are revised to eliminate the requirement for a manual ECCS initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 5 of 7 Docket No. 50-333 Description and Assessment

3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."

4. The TSs are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5. A Surveillance Requirement (SR) that requires operating the required Emergency Core Cooling System (ECCS) injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6. TS 3.8.2, "AC Sources - Shutdown," SR 3.8.2.1, is revised to not require SRs that test automatic diesel generator start to be met in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542.

7. Applicability of TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVS)," is revised to delete the phrase, "When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation." This makes TS 3.6.1.3 only applicable Modes 1, 2, and 3. Condition G, which is only applicable in Modes 4 and 5, is deleted.

8. Revised Condition 3.3.5.2.B to add new Required Action B.1 to state, " Initiate action to place channel in trip." Revised old B.1 to B.2.1 and revised old Required Action B.2 to B.2.2 to state, "Initiate action to calculate Drain Time." Tied new Required Action B.1 to Required Action B.2.1 with an "OR" logical connector.

9. The SR 3.5.3.5 Bases is revised to reference LCO 3.3.5.3 instead of LCO 3.3.5.2.

Exelon has evaluated if a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes incorporate operating experience and correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 6 of 7 Docket No. 50-333 Description and Assessment Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes incorporate operating experience and correct errors and omissions that were incorporated into the plant TSs when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Safety Analysis Report (USAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the USAR had it been previously identified.

None of the equipment affected by the proposed changes has a design function described in the USAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed changes will not change the design function of the affected equipment. The proposed changes will affect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed changes incorporate operating experience and correct errors and omissions that were incorporated into the plant TSs when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed changes do not affect any specific values that define a safety margin as established in the licensing basis. The proposed changes do not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed changes do not significantly reduce the margin of safety.

License Amendment Request Enclosure Adopt TSTF-582 RPV WIC Enhancements Page 7 of 7 Docket No. 50-333 Description and Assessment Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed changes would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

5.0 REFERENCES

1. TSTF-582, Revision 0, " Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements," dated August 28, 2019 ADAMS Accession No. ML19240A260.

2. TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016. ADAMS Accession No. ML16074A448.

3. Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-582, Revision 0, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)

Enhancements," dated August 13, 2020. ADAMS Accession No. ML20219A317.

4. NUREG-0123, Revision 2, "Standard Technical Specifications General Electric Boiling Water Reactors (GE-STS)," dated August 1979.

5. NUREG-1433, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 1, Revision 4, dated April 2012

6. NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Revision 4, dated April 2012

ATTACHMENT 1 License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Proposed Technical Specifications Markup Pages TS Pages 1.1-2a 3.3.5.2-1 3.3.5.2-2 3.3.5.2-3 3.3.8.1-1 3.5.1-1 3.5.2-2 3.5.2-3 3.5.2-4 3.5.2-5 3.5.2-6 3.6.1.3-1 3.6.1.3-6 3.8.2-4

1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate:

b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

closed and administratively controlled in

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

(continued)

JAFNPP 1.1-2a Amendment 321

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The Reactor Pressure Vessel (RPV) Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

immediately ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the A.1 Initiate action to place channel. channel in trip OR B. As required by Required B.1 Declare associated Immediately Action A.1 and penetration flow path(s) referenced in incapable of automatic Table 3.3.5.2-1. isolation.

A.2.1 A. One or more channels AND A.2.2 inoperable.

B.2 Calculate DRAIN TIME. Immediately Initiate action to c C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

JAFNPP 3.3.5.2-1 Amendment 321

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

These SRs apply to each Function in SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program JAFNPP 3.3.5.2-2 Amendment 321

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray

a. Reactor 4, 5 4(a) C SR 3.3.5.2.1 < 490 psig Pressure - SR 3.3.5.2.2 Low (Injection Permissive)

b. Core Spray 4, 5 1 per pump D SR 3.3.5.2.1 > 510 gpm Pump (a) SR 3.3.5.2.2 and Discharge < 980 gpm Flow - Low (Bypass)

c. Core Spray 4, 5 1 per pump D SR 3.3.5.2.1 > 90 psig Pump (a) SR 3.3.5.2.2 and Discharge < 110 psig Pressure -

High (Bypass)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor 4, 5 4(a) C SR 3.3.5.2.1 < 490 psig Pressure - SR 3.3.5.2.2 Low (Injection Permissive)

b. Low Pressure 4, 5 1 per pump D SR 3.3.5.2.1 > 1040 gpm Coolant (a) SR 3.3.5.2.2 and Injection < 1665 gpm Pump Discharge Flow - Low

1. (Bypass)

3. RHR System Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.2.1 > 177 inches Vessel Water system SR 3.3.5.2.2 Level - Low,

2. Level 3 (a)

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.2.1 > 177 inches Vessel Water system SR 3.3.5.2.2 Level - Low Level 3 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(a)

JAFNPP 3.3.5.2-3 Amendment 321

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power CLOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1*1 shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3.

When the associated emergency diesel generator CEDG) subsystem is required to be OPERABLE by LCO 3.8.2. "AC Sources - Shutdown. "

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.l Place channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. trip.

8. Required Action and B.1 Declare associated Immediately associated Completion EDGCs) inoperable.

Time not met.

JAFNPP 3.3.8.1-1 Amendment 274

ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

High Pressure ACTIONS Core Spray (HPCI)

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

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OR OPERABLE status.

One low pressure coolant injection (LPCI) pump in both LPCI subsystems inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in Mode 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

JAFNPP 3.5.1-1 Amendment 321

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND (SGT)

C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystem is capable of being placed in operation in less than the DRAIN TIME (continued)

JAFNPP 3.5.2-2 Amendment 321

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D.1 ---------NOTE------------ Immediately Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level

> TAF for > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary AND D.3 Initiate action to isolate Immediately automatically or each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one Immediately SGT standby gas treatment subsystem is capable of being placed in operation E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months JAFNPP 3.5.2-3 Amendment 321

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVELLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME > 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance 10.33 ft. Frequency Control Program (continued)

JAFNPP 3.5.2-4 Amendment 321

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance the: with the Surveillance

a. Suppression pool water level is 10.33 ft; or Frequency Control Program

b. The water level in each condensate storage tank is > 324 inches SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance subsystem, the piping is filled with water from the with the pump discharge valve to the injection valve. Surveillance Frequency Control Program SR 3.5.2.5 In accordance Verify, for the required ECCS injection/spray with the subsystem, each manual, power operated, and Surveillance Not Used automatic valve in the flow path, that is not locked, Frequency Control sealed or otherwise secured in position, is in the Program correct position.

(continued)

JAFNPP 3.5.2-5 Amendment 321

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVELLANCE FREQUENCY SR 3.5.2.6 Operate the required ECCS injection/spray subsystem In accordance with through the recirculation line for > 10 minutes the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated isolation Frequency Control signal. Program SR 3.5.2.8 - - - - - - - - - - - - - - -NOTE - - - - - - - - - - - - - - - -

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be In accordance with manually operated. the Surveillance Frequency Control Program

NOTES-------------------------

1. Operation may be through the test return line

2. Credit may be taken for normal system operation to satisfy this SR.

JAFNPP 3.5.2-6 Amendment 321

PC IVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."

JAFNPP 3.6.1.3-1 Amendment 274

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, AND B, C, D, or E not met in MODE 1, 2, or 3. F.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. Required Action and G.1 Initiate action to Immediately associated Completion restore valve(s) to Time of Condition A or OPERABLE status.

B not met for PCIV(s) required to be OPERABLE during Mode 4 or 5.

JAFNPP 3.6.1.3-6 Amendment 321

AC Sources Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY and SR 3.8.2.1 ---------------------------NOTES---------------------

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.8, SR 3.8.1.9, SR 3.8.1.11, SR 3.8.1.12, and SR 3.8.1.13.

2. SR 3.8.1.10 and SR 3.8.1.12 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control."

For AC sources required to be OPERABLE the In accordance SRs of Specification 3.8.1, except with applicable SR 3.8.1.7, are applicable. SRs The following SRs are applicable for AC sources to be OPERABLE:

SR 3.8.1.1, SR 3.8.1.2, SR 3.8.1.3, SR 3.8.1.4, SR 3.8.1.5, SR 3.8.1.6, SR 3.8.1.8, and SR 3.8.1.11.

JAFNPP 3.8.2-4 Amendment 321

ATTACHMENT 2 License Amendment Request James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Proposed Technical Specifications Bases Markup Pages TS Bases Pages B 3.3.5.2-1 B 3.3.5.2-2 B 3.3.5.2-3 B 3.3.5.2-4 B 3.3.5.2-5 B 3.3.5.2-6 B 3.3.5.2-7 B 3.3.5.2-8 B 3.3.8.1-4 B 3.3.8.1-6 B 3.5.2-1 B 3.5.2-2 B 3.5.2-3 B 3.5.2-4 B 3.5.2-5 B 3.5.2-6 B 3.5.2-7 B 3.5.2-8 B 3.5.2-9 B 3.5.3-7 B 3.6.1.3-4 B 3.6.1.3-9 B 3.8.2-6

RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded.

Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

JAFNPP B 3.3.5.2-1 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control, and the definition of DRAIN TIME.

There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE SAFETY With the unit in MODE 4 or 5, RPV water inventory control is not ANALYSIS, LCO, and required to mitigate any events or accidents evaluated in the safety APPLICABILITY analyses. RPV, LCO, water inventory control is required in MODES 4 and 5 to protect and Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

considered A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated in which a single operator error or initiating event allows draining of the RPV water inventory through a single an penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

(continued)

JAFNPP B 3.3.5.2-2 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE Core Spray and Low Pressure Coolant Injection Systems SAFETY ANALYSIS, 1.a, 2.a. Reactor Pressure - Low (Injection Permissive)

LCO, and Low reactor pressure signals are used as permissives for the low APPLICABILITY pressure ECCS injection/spray subsystem manual injection functions.

(continued)

This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor pressure will be below the ECCS maximum design pressure, the Reactor Pressure -

Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS. The Reactor Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b, and 1.c. Core Spray and Low Pressure Coolant Injection Pump Discharge Flow Low (Bypass), Core Spray Pump Discharge Pressure High (Bypass)

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One differential pressure indicating switch per CS pump and one differential pressure indicating switch per LPCI subsystem are used to detect the associated subsystems' flow rates. In addition, one pressure switch per CS pump is used to detect the associated pumps discharge pressure. The logic is arranged such that each differential pressure indicating switch causes its associated minimum flow valve to open. For CS both the differential pressure indicating switch and the pressure switch must actuate to cause the valve to open. The logic will close the minimum flow valve once the closure setpoint of the associated differential pressure indicating switch is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 10 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss during the (continued)

JAFNPP B 3.3.5.2-3 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1.b, 2.b, and 1.c. Core Spray and Low Pressure Coolant Injection SAFETY ANALYSIS, Pump Discharge Flow Low (Bypass), Core Spray Pump Discharge LCO, and Pressure High (Bypass) (continued)

APPLICABILITY startup of the Residual Heat Removal (RHR) shutdown cooling mode.

The Pump Discharge Flow - Low Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The Core Spray Pump Discharge Pressure-High (Bypass) Allowable Value is less than the pump discharge pressure when the pump is operating in a full flow mode and high enough to avoid any condition that results in a discharge pressure permissive when the CS pump is aligned for injection and the pump is not running.

One channel of the Pump Discharge Flow - Low Function and one channel of Core Spray Pump Discharge Pressure - High (Bypass) is required to be OPERABLE in MODES 4 and 5 when the associated Core Spray or LPCI pump is required to be OPERABLE by LCO 3.5.2 to ensure the pumps are capable of injecting into the Reactor Pressure Vessel when manually initiated.

RHR System Isolation 1a.

3.a - Reactor Vessel Water Level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low, Level 3 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the Primary Containment Isolation (continued)

JAFNPP B 3.3.5.2-4 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 1a BASES APPLICABLE 3.a - Reactor Vessel Water Level - Low, Level 3 (continued)

SAFETY ANALYSIS, Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable LCO, and Value (LCO 3.3.6.1), since the capability to cool the fuel may be APPLICABILITY threatened.

The Reactor Vessel Water Level - Low, Level 3 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 11 valves.

2a Reactor Water Cleanup (RWCU) System Isolation 4.a - Reactor Vessel Water level - Low, Level 3 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water Level - Low (Level 3)

Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low, (Level 3) signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel.

While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low (Level 3) Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low (Level 3) Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level - Low (Level 3) Allowable Value (LCO 3.3.1.1), since the capability to cool the fuel may be threatened. The allowable value is referenced from a level of water 352.56 inches above thr lowest point in the inside bottom of the RPV and also corresponds to the top of a 144 inch fuel column (Ref 6).

The Reactor Vessel Water Level - Low (Level 3) Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. This Function isolates the Group 5 valves.

(continued)

JAFNPP B 3.3.5.2-5 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for A.1 and A.2 transfer to the appropriate subsequent Condition.

B.1 and B.2 immediate action to place the channel in trip. With the RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and inoperable Reactor Water Cleanup System, Reactor Vessel Water Level - Low, channel in the tripped Level 3 functions are applicable when automatic isolation of the A.1 condition, the remaining associated penetration flow path is credited in calculating Drain Time.

channel will isolate the If the instrumentation is inoperable, Required Action B.1 directs an penetration flow path on low immediate declaration that the associated penetration flow path(s) water level. If both channels are incapable of automatic isolation. Required Action B.2 directs are inoperable calculation of DRAIN TIME. The calculation cannot credit automatic and placed in trip, the isolation of the affected penetration flow paths.

penetration flow path will be isolated. Alternatively, C.1 Required Action A.2.1 requires the associated Low reactor steam dome pressure signals are used as permissives for penetration flow path(s) to be the low pressure ECCS injection/spray subsystem manual injection immediately declared functions. If the permissive is inoperable, manual initiation of ECCS is incapable of prohibited. Therefore, the permissive must be placed in the trip automatic isolation. Required condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, Action A.2.2 directs initiating manual initiation may be performed. Prior to placing the permissive in action to the tripped condition, the operator can take manual control of the calculate DRAIN TIME. The pump and the injection valve to inject water into the RPV.

calculation cannot credit (continued) automatic isolation of the affected penetration flow paths.

JAFNPP B 3.3.5.2-6 Revision 41

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS C.1 (continued)

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

(continued)

JAFNPP B 3.3.5.2-7 Revision 41

RPV Water Inventory Control Instrumentation The following SRs apply to B 3.3.5.2 BASES (continued)

SURVEILLANCE As noted in the beginning of the SRs, the SRs for each RPV Water REQUIREMENTS Inventory Control instrument Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.3.5.2-8 Revision 41

LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY Two channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) Function and one channel of Loss of Voltage-Time Delay per associated emergency bus are required to be OPERABLE when the associated EDG is required to be OPERABLE to ensure that no single instrument failure can preclude the EDG function. Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the EDGs.

2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4.16 kV emergency bus indicates that, while preferred power may not be completely lost to the respective emergency bus. available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function.

The Degraded Voltage Function is monitored via the secondary windings of two transformers associated with each emergency bus. Therefore. power supply to the bus is transferred from the preferred power source to onsite EDG power when the voltage on the bus drops below the Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment.

The 4.16 kV Bus Undervoltage (Degraded Voltage) Allowable Value is low enough to prevent spurious power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Allowable Value corresponds to approximately 93% of nominal emergency bus voltage. The Time Delay Allowable Values are long enough to provide time for the preferred power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function, one channel of Degraded Voltage-Time Delay (LOCA), and one channel of Degraded Voltage-Time Delay (non-LOCA) per associated bus are required to be OPERABLE when the associated EDG is required to be OPERABLE to ensure that no single instrument failure can preclude the EDG function. Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the EDGs.

(continued)

JAFNPP B 3.3.8.1-4 Revision 0

LOP Instrumentation B3.3.8.1 BASES ACTIONS B.1 (continued) entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable EDG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

SR 3.3.8.1.1 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.2 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.3.8.1-6 Revision 30 I

RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSIS SAFETY required to mitigate any events or accidents evaluated in the safety ANALYSES analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

considered A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. an (an event that creates a drain Instead, an event is considered in which single operator error or path through multiple vessel initiating event allows draining of the RPV water inventory through a penetrations located below top single penetration flow path with the highest flow rate, or the sum of of active fuel, such as loss of the drain rates through multiple penetration flow paths susceptible to normal power, or a single a common mode failure (e.g., seismic event, loss of normal power, human error). single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety. Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

(continued)

JAFNPP B 3.5.2-1 Revision 38

RPV Water Inventory Control B 3.5.2 BASES (continued)

The RPV water level must be controlled in MODES 4 and 5 to ensure LCO that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation. aligned and One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually started to provide defense-indepth should an unexpected draining event occur. A low pressure from the ECCS injection/spray subsystem consists of either one Core Spray control (CS) subsystem or one Low Pressure Coolant Injection (LPCI) room subsystem. Each CS subsystem consists of one motor driven pump, OPERABILITY of the piping, and valves to transfer water from the suppression pool or ECCS injection/spray condensate storage tank (CST) to the RPV. Each LPCI subsystem subsystem consists of one motor driven pump, piping, and valves to transfer includes any water from the suppression pool to the RPV. In MODES 4 and 5, the necessary valves, RHR System cross tie valve is not required to be closed.

instrumentation, or controls needed to The LCO is modified by a Note which allows a required LPCI manually align and subsystem to be considered OPERABLE during alignment and start the subsystem operation for decay heat removal if capable of being manually from the control realigned (remote or local) to the LPCI mode and is not otherwise room. inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

(continued)

JAFNPP B 3.5.2-2 Revision 38

RPV Water Inventory Control B 3.5.2 (continued) " "

BASES RPV water inventory control is required in MODES 4 and 5.

APPLICABILITY Requirements on water inventory control in other MODES are

" contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel. , and RCIC System."

ACTIONS A.1 and B.1 If the required low pressure ECCS injection/spray subsystem is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In this Condition, the LCO controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for restoring the required low pressure ECCS injection/spray subsystem to OPERABLE status is based on engineering judgment that considers the LCO controls on DRAIN TIME and the low probability of an unexpected draining event that would result in loss of RPV water inventory.

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within the required Completion Time, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually initiated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If recirculation of injected water would occur, it may be credited in determining the necessary water volume.

C.1, C.2, and C.3 With the DRAIN TIME less than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months but greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur. Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

(continued)

JAFNPP B 3.5.2-3 Revision 38

RPV Water Inventory Control B 3.5.2 BASES ACTIONS C.1, C.2, and C.3 (continued)

(continued) The secondary containment provides a controlled volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action C.1 requires verification of the capability to establish the secondary containment boundary in less than the DRAIN TIME. The required verification confirms actions to establish the secondary containment boundary are preplanned and necessary materials are available. The secondary containment boundary is considered established when one Standby Gas Treatment (SGT) subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment.

Verification that the secondary containment boundary can be established must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment. Secondary containment penetration flow paths form a part of the secondary containment boundary. Required Action C.2 requires verification of the capability to isolate each secondary containment penetration flow path in less than the DRAIN TIME. The required verification confirms actions to isolate the secondary containment penetration flow paths are preplanned and necessary materials are available. Power operated valves are not required to receive automatic isolation signals if they can be closed manually within the required time. Verification that the secondary containment penetration flow paths can be isolated must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action C.3 requires verification of the capability to place one SGT subsystem in operation in less than the DRAIN TIME. The required verification confirms actions to place a SGT subsystem in operation are preplanned and necessary materials are available. Verification that a SGT subsystem can be placed in operation must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions C.1, C.2, and C.3 are considered met when Secondary Containment, Secondary Containment Isolation Valves (SCIVs), and the Standby Gas Treatment (SGT) System are OPERABLE in accordance with (continued)

LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

JAFNPP B 3.5.2-4 Revision 38

RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued) With the DRAIN TIME less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , mitigating actions are implemented in case an unexpected draining event should occur.

Note that if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action E.1 is also applicable.

Required Action D.1 requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCO. The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a control volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the secondary containment boundary. With the secondary containment boundary established, one SGT subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment.

The secondary containment penetrations form a part of the secondary containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be manually isolated from the control room.

automatically or (continued)

JAFNPP B 3.5.2-5 Revision 38

RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued)

One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment Required Actions D.2, and filter gaseous releases. Required Action D.4 requires that actions D.3, and D.4 are be immediately initiated to verify that at least one SGT subsystem is considered met when capable of being placed in operation. The required verification is an Secondary administrative activity and does not require manipulation or testing of Containment, equipment.

Secondary Containment Isolation Valves (SCIVs), E.1 and the Standby Gas If the Required Actions and associated Completion times of Treatment (SGT) Conditions C or D are not met or if the DRAIN TIME is less than 1 System are OPERABLE hour, actions must be initiated immediately to restore the DRAIN TIME in accordance with LCO to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In this condition, there may be insufficient time to 3.6.4.1, LCO 3.6.4.2, respond to an unexpected draining event to prevent the RPV water and LCO 3.6.4.3.

inventory from reaching the TAF. Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed crosssectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or (continued) closed and administratively JAFNPP B 3.5.2-6 controlled Revision 38

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration The exclusion of a single flow paths. A blank flange or other bolted device must be connected penetration flow path, or multiple with a sufficient number of bolts to prevent draining in the event of an penetration Operating Basis Earthquake. Normal or expected leakage from closed flow paths susceptible to a systems or past isolation devices is permitted. Determination that a common mode failure, from the system is intact and closed or isolated must consider the status of determination of DRAIN TIME should consider branch lines and ongoing plant maintenance and testing activities.

the effects of temporary The Residual Heat Removal (RHR) Shutdown Cooling System is only alterations in support of considered an intact closed system when misalignment issues maintenance (rigging, (Reference 6) have been precluded by functional valve interlocks or scaffolding, by isolation devices, such that redirection of RPV water out of an RHR temporary shielding, piping subsystem is precluded. Further, RHR Shutdown Cooling System is plugs, freeze seals, etc.). If only considered an intact closed system if its controls have not been reasonable controls are transferred to Remote Shutdown, which disables the interlocks and implemented to prevent such isolation signals.

temporary alternations from causing a draining The exclusion of penetration flow paths from the determination of event from a closed system, or DRAIN TIME must consider the potential effects of a single operator between the RPV and the error or initiating event on items supporting maintenance and testing isolation device, the effect of the (rigging, scaffolding, temporary shielding, piping plugs, snubber temporary alterations on DRAIN removal, freeze seals, etc.). If failure of such items could result and TIME need not be considered. would cause a draining event from a closed system or between the Reasonable controls include, but RPV and the isolation device, the penetration flow path may not be are not limited to, controls excluded from the DRAIN TIME calculation.

consistent with the guidance in Surveillance Requirement 3.0.1 requires SRs to be met between NUMARC 93-01, performances. Therefore, any changes in plant conditions that would "Industry Guideline for change the DRAIN TIME requires that a new DRAIN TIME be Monitoring the Effectiveness of Maintenance at determined.

Nuclear Power Plants," Revision The Surveillance Frequency is controlled under the Surveillance 4, NUMARC 91-06, "Guidelines Frequency Control Program.

for Industry Actions to Assess SR 3.5.2.2 and SR 3.5.2.3 Shutdown Management," or The minimum water level of 10.33 ft required for the suppression commitments to pool is periodically verified to ensure that the suppression pool will NUREG-0612, "Control of Heavy Loads at Nuclear Power provide adequate net positive suction head (NPSH) for the CS Plants."

subsystem or LPCI subsystem pump, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

(continued)

JAFNPP B 3.5.2-7 Revision 38

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.2 and SR 3.5.2.3 (continued)

REQUIREMENTS The required CS System is OPERABLE only if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CS pump. Therefore, a verification that either the suppression pool water level is 10.33 ft or that a required CS subsystem is aligned to take suction from the CST and the CST contains 354,000 gallons (two tanks) of water, equivalent to 324 inches (27 ft), ensures that the CS subsystem can supply at least 50,000 gallons of makeup water to the RPV. The CS suction is uncovered at the 258,000 gallon (two tanks) level.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.4 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. actuation The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.5 Deleted Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.5.2-8 Revision 38

RPV Water Inventory Control B 3.5.2 d

BASES SR 3.5.2.6 may be done SURVEILLANCE REQUIREMENTS test return Verifying that the required ECCS injection/spray subsystem can be (continued) manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing aligned, and the pump the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes was based on engineering judgement.

Note 2 states that The Surveillance Frequency is controlled under the Surveillance credit for meeting the Frequency Control Program. This SR is modified by two SR may be taken for Notes. Note 1 states that normal system SR 3.5.2.7 testing operation that satisfies the SR, such Verifying that each valve credited for automatically isolating a as using the RHR penetration flow path actuates to the isolation position on an actual mode of LPCI for or simulated RPV water level isolation signal is required to prevent 10 minutes. RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.8 This Surveillance The required ECCS injection/spray subsystem shall be capable of verifies that a being manually operated from the Control Room. This Surveillance required CS verifies that the required CS or LPCI subsystem (including the subsystems or LPCI associated pump and valve(s)) can be manually operated to provide subsystem can be additional RPV water inventory, if needed.

manually aligned and started from the The Surveillance Frequency is controlled under the Surveillance control room, Frequency Control Program.

including any This SR is modified by a Note that excludes vessel injection/spray necessary valve during the Surveillance. Since all active components are testable and alignment, full flow can be demonstrated by recirculation through the test line, instrumentation, or coolant injection into the RPV is not required during the Surveillance.

controls, to transfer water from the suppression pool or CST to the RPV.

(continued)

JAFNPP B 3.5.2-9 Revision 38

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.5 (continued)

REQUIREMENTS automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) signal (Level 8 signal closes RCIC steam inlet valve, and subsequent Level 2 signal will re-open valve) and that the suction is automatically transferred from the CST to the suppression pool. The 3 LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed design function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by Note 1 that says the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The time allowed for this test after required pressure and flow are reached is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR. Adequate reactor pressure must be available to perform this test. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Thus, sufficient time is allowed after adequate pressure and flow are achieved to perform this test. Adequate reactor steam pressure is > 150 psig. Adequate steam flow is represented by at least one turbine bypass valve open. Reactor startup is allowed prior to performing this test because the reactor pressure is low and the time allowed to satisfactorily perform the test is short.

This SR is modified by Note 2 that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

(continued)

JAFNPP B 3.5.3-7 Revision 38

PCIVs B 3.6.1.3 BASES APPLICABLE This LCO provides assurance that the PCIVs will perform their SAFETY ANALYSIS designed safety functions to minimize the loss of reactor coolant (continued) inventory and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, PCIVs are not required to be OPERABLE and the primary containment vent and purge valves are not required to be normally closed in MODES 4 and 5. Certain valves, however, are required to be OPERABLE when the associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instrumentation.)

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV. Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve). Note 4 ensures appropriate remedial actions are taken when the primary containment leakage limits are exceeded. Pursuant to LCO 3.0.6, these actions are not required even when the associated LCO is not met. Therefore, Notes 3 and 4 are added to require the proper actions be taken.

(continued)

JAFNPP B 3.6.1.3-4 Revision 46

PCIVs B 3.6.1.3 BASES ACTIONS F.1 and F.2 (continued) If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

G.1 and G.2 If any Required Action and associated Completion Time cannot be met for PCIV(s) required to OPERABLE during MODE 4 or 5, the plant must be placed in a condition in which the LCO does not apply. Action must be immediately initiated to restore the valve(s) to OPERABLE status.

This allows RHR shutdown cooling to remain in service while actions are being taken to restore the valve.

SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR ensures that the primary containment vent and purge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. The SR is modified by a Note stating that the SR is not required to be met when the vent and purge valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the full-flow 12 inch line (with valve 27MOV-120) to the SGT System is closed and one or more SGT System reactor building suction valves are open. This will ensure there is no damage to the filters if a LOCA were to occur with the vent and purge valves open since excessive differential pressure is not expected with the full-flow 12 inch line closed and one or more SGT System reactor building suction valves open. The 20 and 24 inch vent and purge valves are capable of closing against the dynamic effects of a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

JAFNPP B 3.6.1.3-9 Revision 46

AC Sources - Shutdown B 3.8.2 BASES (continued)

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.7 is not required to be met since the main generator is not used to provide AC power while shutdown. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by two Notes. The reason for Note 1 is to preclude requiring the OPERABLE EDG subsystem from being paralleled with the reserve power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4.16 kV emergency bus or disconnecting a required reserve circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required reserve circuit and EDG subsystem. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the EDG subsystem and reserve circuit is required to be OPERABLE.

Note 2 states that SRs 3.8.1.10 and 3.8.1.12 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE. These SRs demonstrate the EDG response to an ECCS signal (either alone or in conjunction with a loss of power signal). This is consistent with the ECCS instrumentation requirements that do not require the ECCS signal when the ECCS System is not required to-be OPERABLE.

SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the REFERENCES 1. OPERABILITY 10 CFR 50.36(c)(2)(ii).

of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.7 is not required to be met since the main generator is not used to provide AC power while shutdown. SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.12, and SR 3.8.1.13 are not required to be met because EDG response on an offsite power or ECCS initiation signal is not required. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by two a Notes. which precludes The reason for Note 1 is to preclude requiring the OPERABLE EDG subsystem from being paralleled with the reserve power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4.16 kV emergency bus or disconnecting a required reserve circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required reserve circuit and EDG subsystem. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods then the EDG subsystem and reserve circuit is required to be OPERABLE.

JAFNPP B 3.8.2-6 Revision 38

v t e Letter Sequence Request
EPID:L-2021-LLA-0076, TSTF-582 (Approved, Closed)
Initiation Request Acceptance Supplement Administration Questions Answers Results Approval Other:
MONTHYEAR2021-04-16 [Table View]

JAFP-21-0028, Application to Revise Technical Specifications to Adopt TSTF-582, Revision 0, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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JAFP-21-0028, Application to Revise Technical Specifications to Adopt TSTF-582, Revision 0, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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3.0 REGULATORY ANALYSIS

5.0 REFERENCES

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