L-22-053, Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time

Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time

ML22137A049
Person / Time
Site:	Beaver Valley
Issue date:	05/16/2022
From:	Grabnar J Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-22-053
Download: ML22137A049 (129)

Text

Energy Harbor Nuclear Corp.

Beaver Valley Power Station P.O. Box 4 Shippingport, PA 15077 John J. Grabnar 724-682-5234 Site Vice President, Beaver Valley Nuclear May 16, 2022 L-22-053 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. is submitting a request to amend the renewed facility operating licenses numbered DPR-66 and NPF-73 for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, respectively. The proposed change would revise the Technical Specifications (TS) to add a Limiting Condition for Operation (LCO) titled Decay Time restricting movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> appear in the applicability statements and conditions of several TS LCOs. These restrictions will be consolidated in the new LCO titled Decay Time, which will ensure the decay time assumed in the design basis fuel handling accident is maintained.

Energy Harbor Nuclear Corp.s detailed description and evaluation of the proposed amendments is provided in Attachment 1. Affected pages of the current TSs, annotated to show the proposed changes, are provided in Attachment 2. Proposed changes to the TS Bases are provided for information only in Attachment 3.

NRC staff approval of the proposed amendments is requested by May 31, 2023, and the amendments shall be implemented within 60 days of approval.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-22-053 Page 2 There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May II. , 2022.

Sincerely, John J. Grabnar Attachments:

1. Evaluation of the Proposed Amendments

2. Proposed Technical Specification Changes, Annotated Copy

3. Proposed Technical Specification Bases Changes, Annotated Copy cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Attachment 1 L-22-053 Evaluation of the Proposed Amendments Page 1 of 41

Subject:

Request for an Amendment to Consolidate Fuel Decay Time Technical Specifications in a New Limiting Condition for Operation Titled Decay Time TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.2 No Significant Hazards Consideration Analysis 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

L-22-053 Page 2 of 41 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the renewed facility operating licenses numbered DPR-66 and NPF-73 for the Beaver Valley Power Station (BVPS), Unit Nos.

1 and 2, respectively. The proposed change would revise the TSs to add an LCO titled Decay Time restricting movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> appear in the applicability statements and conditions of several TS LCOs. These restrictions will be consolidated in the new LCO titled Decay Time, which will ensure the decay time assumed in the design basis fuel handling accident (FHA) is maintained.

2.0 DETAILED DESCRIPTION The systems impacted by this proposed change are those that are required during movement of recently irradiated fuel or movement of fuel over recently irradiated fuel.

System requirements in modes or other specified conditions, beyond recently irradiated fuel movement conditions, are not affected by this proposed change and are therefore, not discussed here. The only design basis accident (DBA) impacted by this proposed change is the FHA involving movement of fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, that is, recently irradiated fuel. The BVPS TSs refer to recently irradiated fuel as well as non-recently irradiated fuel, that is, fuel that has not occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The applicability statements for the following TS LCOs include statements referencing movement of recently irradiated fuel assemblies, and movement of fuel assemblies over recently irradiated fuel. Additionally, certain conditions and notes in the following TS LCOs reference recently irradiated fuel or non-recently irradiated fuel:

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation; TS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation; TS 3.7.10, Control Room Emergency Ventilation System (CREVS);

TS 3.7.11, CR Emergency Air Cooling System; TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS);

TS 3.8.2, AC [alternating current] Sources - Shutdown; TS 3.8.5, DC [direct current] Sources - Shutdown; TS 3.8.8, Inverters - Shutdown; TS 3.8.10, Distribution Systems; TS 3.9.3, Containment Penetrations; TS 5.5.7, Ventilation Filter Testing Program (VFTP), is also impacted as it involves filters associated with the CREVS and SLCRS.

BVPS does not have an FHA analysis to support movement of recently irradiated fuel and currently has a Licensing Requirements Manual (LRM) licensing requirement (LR),

L-22-053 Page 3 of 41 titled Decay Time, which prohibits fuel movement involving recently irradiated fuel. In the NRC Safety Evaluation for Amendments 278 and 161, dated February 21, 2007, (Accession No. ML070160593) the NRC staff stated the following:

Although BVPS-1 and 2 do not currently have safety analyses that support moving recently irradiated fuel assemblies, TS requirements have been retained to address the condition of moving recently irradiated fuel assemblies. These TS requirements are retained because decay time limits for moving irradiated fuel are in the LRM and the NRC staff has determined that fuel handling limits should be retained in the TSs should the licensee develop future capability to move recently irradiated fuel.

Adding an LCO, titled Decay Time, which prohibits fuel movements involving recently irradiated fuel obviates the need for the individual requirements in the affected TS LCOs, applicability statements, conditions, and notes. Specific changes to TS LCOs, and the bases for those changes, are discussed in Section 3 of this attachment.

2.1 System Design and Operation Unit 2 Containment Purge and Exhaust Isolation Instrumentation The Unit 2 containment purge and exhaust isolation instrumentation closes the containment isolation valves in the purge and exhaust system. This action isolates the containment atmosphere from the environment to minimize releases of radioactivity in the event of an FHA involving recently irradiated fuel. The containment purge and exhaust isolation is initiated by a high containment radiation signal or may be closed manually by control switches in the control room.

The Unit 2 Updated Final Safety Analysis Report (UFSAR), Section 15.7.4, discusses the radiological consequence of fuel handling accidents. During refueling operations, the postulated event that results in the most severe radiological consequences is a fuel handling accident. The limiting FHA analyzed in the Unit 2 UFSAR includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100-hour decay time prior to moving irradiated fuel. The applicable limits for offsite and control room dose due to an FHA are specified in 10 CFR 50.67 and NUREG-0800, Standard Review Plan, Section 15.0.1, Rev 0, hereafter referred to as regulatory acceptance criteria.

TS LCO 3.9.6, Refueling Cavity Water Level, requires the refueling cavity water level be maintained greater than or equal to () 23 feet above the top of the reactor vessel flange during fuel movement involving irradiated fuel within containment. These water level requirements, in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to fuel movement involving irradiated fuel, ensure that the resulting offsite and control room dose from the limiting FHA is within the limits required by the regulatory acceptance criteria without the need for containment purge and exhaust isolation. Consequently, L-22-053 Page 4 of 41 when moving non-recently irradiated fuel, no requirements are placed on the containment purge and exhaust isolation instrumentation.

Therefore, the instrumentation requirements of LCO 3.3.6 "Containment Purge and Exhaust Isolation Instrumentation" are only applicable during fuel movement involving recently irradiated fuel. Although movement of recently irradiated fuel is not currently permitted, the requirements for containment purge and exhaust isolation instrumentation have been retained in the TS in the event these requirements are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

The containment purge and exhaust isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

The containment purge and exhaust isolation instrument requirements are applicable during movement of recently irradiated fuel assemblies or the movement of fuel assemblies over recently irradiated fuel assemblies within containment when the potential for the limiting fuel handling accident exists. In MODES 1, 2, 3, and 4, containment penetration requirements (including the purge and exhaust isolation valves) are addressed by LCO 3.6.3, "Containment Isolation Valves" and LCO 3.6.1, "Containment OPERABILITY." In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist.

A fuel handling accident that does not involve recently irradiated fuel will result in doses that are well within the regulatory acceptance criteria, even without containment closure capability. Therefore, under these conditions no requirements are placed on the containment purge and exhaust isolation instrumentation.

Although the movement of recently irradiated fuel is not currently permitted, the operability requirements for the containment purge and exhaust isolation instrumentation manual actuation and the containment radiation monitors are retained in the TS, applicable during fuel movement involving recently irradiated fuel, in the event these requirements are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

Control Room Emergency Ventilation System The CREVS provides a protected environment for occupants of the main control room (MCR) following an uncontrolled release of radioactivity. BVPS has a common control room envelope (CRE) for Unit 1 and Unit 2. The CREVS consists of pressurization fan subsystems, the CRE isolation subsystems, and a CRE boundary that limits the in-leakage of unfiltered air. During normal operation, the control room ventilation system recirculates the control room air and provides unfiltered makeup air and cooling. Upon receipt of a CREVs actuation signal from either unit (manual initiation, control room radiation, or containment isolation Phase B), the Unit 1 and 2 control room ventilation L-22-053 Page 5 of 41 intake and exhaust ducts are isolated to prevent unfiltered makeup air from entering the control room.

In addition, the CREVS actuation signal from either unit will automatically start one Unit 2 CREVS fan to provide filtered makeup air to pressurize the control room. If the preferred Unit 2 CREVS fan does not start, the backup Unit 2 fan will automatically start.

Unit 1 may take credit for the operation of one or both of the Unit 2 CREVS fans and filters. One of the two Unit 1 CREVS fans and a single filter must be manually aligned and placed in service if required. Once the control room ventilation intake and exhaust ducts are isolated, and the CREVS fan is providing filtered makeup, control room ventilation is in the emergency pressurization mode of operation. The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any DBA.

The manual initiation is required to be operable in MODES 1 through 4, and during fuel movement involving recently irradiated fuel. The applicable safety analyses for all DBAs considered in MODES 1, 2, 3, and 4, except LOCA, assume manual initiation of the emergency pressurization mode of operation of control room ventilation. The LOCA accident analysis assumes an automatic control room ventilation system isolation on a containment isolation - Phase B signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. Although the CIB signal will automatically start a CREVS fan and filtered flow path, a 30-minute delay to allow for manual initiation of a CREVS fan and filtered flow path is specifically assumed in all analyses to permit the use of a Unit 1 CREVS fan and filtration flow path which require manual operator action to place in service. Therefore, the CREVS manual actuation must be operable in MODES 1, 2, 3, and 4 to provide the required CREVS initiation assumed in the applicable safety analyses. In MODES 5 and 6, when no fuel movement involving recently irradiated fuel is taking place, there are no requirements for CREVS operability consistent with the safety analyses assumptions applicable in these modes.

Although the movement of recently irradiated fuel is not currently permitted, the operability requirements for the CREVS manual actuation and the control room area radiation monitors are retained in the TS, applicable during fuel movement involving recently irradiated fuel, in the event these requirements are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

The CREVS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Control Room Emergency Air Cooling System The control room emergency air cooling system (CREACS) provides 1) a control room heat removal function following isolation of the control room, and 2) control room atmosphere purge capability for the combined units main control room. The heat removal function ensures that the control equipment qualification is maintained following isolation of the control room. The purge function is necessary to limit the dose received L-22-053 Page 6 of 41 by control room personnel following certain DBAs. Each unit has its own CREACS, however, the CREACS trains share common ventilation ductwork and normal air inlet and exhaust flow paths.

Control room isolation, and therefore, the control room heat removal function of CREACS, is not credited for either unit for an FHA or for any other DBA in MODES 5 and 6 (for example, the waste gas tank rupture DBA). As such, the heat removal function of CREACS is not required in MODES 5 and 6 or during fuel movement involving non-recently irradiated fuel.

The Unit 1 FHA analysis for fuel movement involving non-recently irradiated fuel credits a manually initiated 30-minute control room ventilation purge after the accident sequence is complete and the environmental release has been terminated. Purge is not credited in the Unit 2 FHA analysis.

The CREACS is required to be operable for both units during fuel movement involving recently irradiated fuel to ensure the radiation exposure to personnel occupying the control room remains below the requirements of 10 CFR 50.67 should an FHA involving recently irradiated fuel occur. Although the movement of recently irradiated fuel is not currently permitted, the requirements for both the temperature control and purge functions have been retained in the TS in the event the CREACS functions are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

The CREACS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Supplemental Leakage Collection and Release System (SLCRS)

SLCRS filters airborne radioactivity from the containment building (Unit 1 only) and the fuel building (both Units) following a fuel handling accident involving recently irradiated fuel. This ensures that, prior to release to the environment, the exhaust from these areas in the event of a fuel handling accident is limited to radioactive releases within 10 CFR 50.67 limits. Since SLCRS is not credited in any existing DBA analysis applicable in MODES 1 through 6, the SLCRS is not required to be OPERABLE in these MODES, except as required to support fuel movement involving recently irradiated fuel.

The SLCRS may be used for normal, as well as post-accident, atmospheric cleanup functions. SLCRS also provides ventilation and heat removal functions to the areas it serves. As discussed in the NRC staff safety evaluations for amendments 278 and 161, these functions do not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion in the technical specifications and therefore, reside in the LRM. These functions are ensured via the Unit 1 and Unit 2 LRM LC 3.7.7, Supplementation Leak Collection and Release System (SLCRS), which requires SLCRS operability in MODES 1 through 4 and are not affected by the proposed change.

L-22-053 Page 7 of 41 As discussed in the UFSARs (Unit 1 UFSAR Section 14.2.1 and Unit 2 UFSAR Section 15.7.4), during fuel handling operations, the postulated event that results in the most severe radiological consequences is a fuel handling accident. The limiting fuel handling accident analyzed includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100-hour decay time prior to moving irradiated fuel.

TS LCO 3.7.15, Fuel Storage Pool Water Level, requires the fuel storage water level be maintained 23 feet above the top of the irradiated fuel assemblies seated in the storage racks. This water level requirement, in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensures the resulting offsite and control room dose from the limiting fuel handling accident is within the regulatory acceptance criteria, without the need for containment and fuel building closure or filtration.

Therefore, the SLCRS requirements contained in LCO 3.7.12 are only applicable during refueling operations involving recently irradiated fuel. Although movement of recently irradiated fuel is not currently permitted, the requirements for SLCRS have been retained in the TS in the event these requirements are necessary to support fuel movement involving recently irradiated fuel at some point in the future.

When required in accordance with LCO 3.9.3.c.3, for Unit 1, one train of SLCRS is required to be operable and in operation to reduce the consequences of a fuel handling accident inside containment. This applicability applies only to Unit 1 in accordance with the provisions of LCO 3.9.3, "Containment Penetrations" when the containment purge and exhaust system penetrations are open coincident with fuel movement involving recently irradiated fuel assemblies within containment.

During movement of recently irradiated fuel assemblies within the fuel storage pool or during movement of fuel assemblies over recently irradiated fuel assemblies within the fuel storage pool, one train of SLCRS is required to be operable and in operation to alleviate the consequences of a potential fuel handling accident. Since SLCRS is not credited in any existing DBA analysis applicable in MODES 1, 2, 3, 4, 5, and 6, the SLCRS is not required to be operable in these MODES, except as required to support fuel movement involving recently irradiated fuel assemblies described above.

In accordance with LCO 3.7.14, SLCRS is required to be operable when fuel is in the fuel cask area during the Unit 2 re-rack project. The BVPS Unit 2 re-rack project was completed several years ago. Therefore, this requirement is historical.

The SLCRS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

AC Sources - Shutdown The Class 1E AC electrical power distribution system AC sources consist of the offsite power sources (preferred power sources, normal and alternate(s)), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). The design of L-22-053 Page 8 of 41 the AC electrical power system provides independence and redundancy to ensure an available source of power to the engineered safety feature (ESF) systems.

The operability of the minimum AC sources during MODES 5 and 6 and during movement of irradiated fuel assemblies or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 (which includes recently irradiated fuel) and during movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensure that adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The current FHA analysis does not rely on the automatic actuation of any systems or components to mitigate the accident. Furthermore, the current FHA analysis does not assume isolation or filtration to mitigate the event. However, to limit the control room dose following a fuel handling accident, Unit 1 must purge the control room atmosphere for 30 minutes following termination of the release. The required Unit 1 purge is a manual action for which the technical specifications require power (LCO 3.8.2) and ventilation system (LCO 3.7.11) operability when moving any irradiated fuel assemblies or fuel assemblies over any irradiated fuel assemblies. The Unit 1 requirement to purge the control room after a fuel handling accident involving any type of irradiated fuel is the reason for the difference in the fuel movement applicability for each unit in LCO 3.8.2.

Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel. However, the technical specifications continue to address fuel movement involving recently irradiated fuel to support requirements for isolation or filtration that may be necessary to mitigate a fuel handling accident involving recently irradiated fuel. These requirements have been maintained in the TS in the event they are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

DC Sources - Shutdown The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related equipment and preferred AC vital bus power via the inverters.

The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all modes of operation. The operability of the minimum DC electrical power sources during MODES 5 and 6 and during movement of irradiated fuel assemblies or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensure that adequate DC electrical power is provided to mitigate events postulated during shutdown, such as an FHA involving irradiated fuel. For Unit 2 L-22-053 Page 9 of 41 only, DC electrical power is only required to mitigate fuel handling accidents involving recently irradiated fuel.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Inverters - Shutdown The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The DC to AC inverters provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the reactor protective system and engineered safety features actuation system instrumentation and controls so that the fuel, reactor coolant system, and containment design limits are not exceeded.

The operability of the inverters to each AC vital bus during MODES 5 and 6 and during fuel movement ensures that adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident involving handling irradiated fuel or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2. For Unit 2 only, the inverters are only required to mitigate fuel handling accidents involving handling recently irradiated fuel.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Distribution Systems - Shutdown The required power distribution subsystems ensure the availability of AC, DC, and AC vital bus electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, reactor coolant system, and containment design limits are not exceeded.

The operability of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6, and during movement of irradiated fuel assemblies or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensure that adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving irradiated fuel (Unit 1). For Unit 2 only, AC and DC electrical power is only required to mitigate an FHA involving recently irradiated fuel.

The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

L-22-053 Page 10 of 41 Refueling Operations Containment Penetration During an FHA involving recently irradiated fuel, Unit 1 cannot credit containment isolation to mitigate radiological consequences and must rely on filtration of the purge exhaust by an operable SLCRS filter train. For a Unit 1 FHA involving non-recently irradiated fuel, the FHA initial conditions of 23 feet of water above the top of irradiated fuel and a minimum fuel decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> ensure that the resulting offsite and control room dose from the limiting fuel handling accident is within the regulatory acceptance criteria without the need for containment closure.

During an FHA involving recently irradiated fuel, Unit 2 credits containment isolation to mitigate the radiological consequences. For a Unit 2 FHA involving non-recently irradiated fuel, the FHA initial conditions of 23 feet of water above the top of irradiated fuel and a minimum fuel decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> ensure that the resulting offsite and control room dose from the limiting fuel handling accident is within the regulatory acceptance criteria without the need for containment closure.

The water level requirements of LCO 3.9.6, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensure that the resulting offsite and control room dose from the limiting fuel handling accident is within the regulatory limits without the need for containment closure.

Therefore, the containment closure requirements of LCO 3.9.3, "Containment Penetrations," are only applicable during refueling operations involving recently irradiated fuel. Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel. Although movement of recently irradiated fuel is not currently permitted, the requirements for containment penetrations have been retained in the TS in the event these requirements are necessary to support fuel movement involving recently irradiated fuel at some point in the future.

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Ventilation Filter Testing Program (VFTP)

TS 5.5.7, Ventilation Filter Testing Program (VFTP), implements the required testing of ESF filter ventilation systems for the CREVS and SLCRS. Surveillance Requirement (SR) 3.7.10.2 states that required CREVS filter testing in accordance with the VFTP is required. Similarly, SR 3.7.12.2 testing states that required SLCRS filter testing in accordance with the VFTP is required. The VFTP specifies maintenance requirements and frequencies, as well as test criteria for the CREVS and SLCRS ventilation systems.

2.2 Current Technical Specification Requirements As discussed above, those systems that are required in the event of an FHA involving recently irradiated fuel, that is, fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, have applicability statements involving movement of recently irradiated fuel as well as restrictions in various conditions and surveillance notes.

L-22-053 Page 11 of 41 Energy Harbor Nuclear Corp. currently does not have an FHA analysis that supports moving recently irradiated fuel. The licensee controlled LRM provides a restriction in the form of a Decay Time LCO that prohibits fuel movements involving recently irradiated fuel. 10 CFR 50.36(c)(2)(ii)(B) requires that TS LCOs be established for a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, these restrictions on fuel movements involving recently irradiated fuel in individual technical specifications are consistent with 10 CFR 50.36(c)(2)(ii)(B).

2.3 Reason for Proposed Change Use of the terms recently irradiated fuel and non-recently irradiated fuel can cause confusion and potentially create an error trap. Additionally, the restrictions on recently irradiated fuel movements that currently appear in individual TS have resulted in several LCOs, and corresponding SRs, that are applicable only during movement of recently irradiated fuel. Since movement of recently irradiated fuel is prohibited, these LCOs are never entered. As such, the performance of their associated SRs represents a burden with no commensurate safety benefit.

Energy Harbor Nuclear Corp. proposes the addition of LCO 3.9.7, Decay Time, that clearly prohibits fuel movement of recently irradiated fuel. It is proposed to move the existing LRM Decay Time LCO to the TS with some administrative changes for consistency. This offers the same restriction prohibiting fuel movement of recently irradiated fuel in accordance with 10 CFR 50.36(c)(2). Addition of the Decay Time LCO will ensure prior NRC approval is sought should Energy Harbor Nuclear Corp.

develop an FHA analysis to support movement of fuel that has occupied a critical reactor core within the last 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

Historically, Energy Harbor Nuclear Corp. has not begun fuel movement at BVPS sooner than six days after reactor shutdown and does not anticipate any future need to begin fuel movement involving irradiated fuel prior to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after reactor shutdown.

2.4 Description of Proposed Change Energy Harbor Nuclear Corp. is requesting the addition of TS LCO 3.9.7, Decay Time, that clearly prohibits movement of recently irradiated fuel. This is consistent with the requirements of 10 CFR 50.36(c)(2)(ii).

The addition of TS LCO 3.9.7 allows the deletion of the following TSs that only have applicabilities during movement of recently irradiated fuel or movement of fuel over recently irradiated fuel:

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation; TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS);

TS 3.9.3, Containment Penetrations.

L-22-053 Page 12 of 41 The proposed deletion of these three specifications is consistent with the removal of specifications in the improved technical specification conversion in Amendments 278 and 161. Section 4 of the NRC staffs safety evaluation described those specifications relocated to licensee-controlled documents, including the UFSAR or LRM, as appropriate. The three technical specifications proposed for deletion above are currently described in the licensee-controlled documents as follows:

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation:

Section 9.4.7.3, Containment Purge Air System, of the Unit 2 UFSAR describes the system, instrumentation, and operation (including isolation).

TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS):

Section 3.7.7, Supplemental Leak Collection and Release System (SLCRS), of both Unit 1 and Unit 2 LRMs require the SLCRS air filter trains to be functional.

TS 3.9.3, Containment Penetrations:

Containment penetration controls following a fuel handling accident are currently described in Section 15.7.4.2.1 of the Unit 2 UFSAR. Section 14.2.1.2 of the Unit 1 UFSAR notes that the containment may be open during a fuel handling accident and that releases could be along the containment wall via the equipment or personnel hatch.

Adding TS LCO 3.9.7 would allow requirements for recently irradiated fuel to be removed from the following TSs:

TS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation; TS 3.7.10, Control Room Emergency Ventilation System (CREVS);

TS 3.7.11, CR Emergency Air Cooling System; TS 3.8.2, AC [alternating current] Sources - Shutdown; TS 3.8.5, DC [direct current] Sources - Shutdown; TS 3.8.8, Inverters - Shutdown; TS 3.8.10, Distribution Systems; TS 5.5.7, Ventilation Filter Testing Program (VFTP), is also impacted as it involves filters associated with the CREVS and SLCRS.

The proposed changes and the acceptability of those changes is provided in the next section.

L-22-053 Page 13 of 41

3.0 TECHNICAL EVALUATION

Energy Harbor Nuclear Corp. proposes to modify the BVPS TS as listed in the following table. The table identifies each section that is proposed to be changed, the proposed changes, and the basis for each change. Proposed deletions are shown with strikethrough and additions are shown in bold italics. to this submittal contains a mark-up of the current TS pages. The markups of the TS Bases in Attachment 3 are provided for information only.

TS SECTION 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation Current TS 3.3.6 Proposed TS 3.3.6 LCO 3.3.6 LCO 3.3.6

- NOTE - - NOTE -

This Specification is only applicable to Unit 2 This Specification is only applicable to Unit 2 The Containment Purge and Exhaust Isolation The Containment Purge and Exhaust Isolation Instrumentation for each Function in Table Instrumentation for each Function in Table 3.3.6.1 shall be OPERABLE. 3.3.6.1 shall be OPERABLE.

The requirement for the Unit 2 Containment For entirety of LCO 3.3.6, see Attachment 2. Purge and Exhaust Isolation Instrumentation is deleted.

For entirety of LCO 3.3.6 deletion, see Attachment 2.

L-22-053 Page 14 of 41 Basis TS 3.3.6 is proposed for deletion in its entirety, including the deletion of Table 3.3.6-1.

The Unit 2 Containment Purge and Exhaust Isolation Instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii), that is, a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Unit 2 Containment Purge and Exhaust Isolation function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future and would represent the primary success path for an FHA involving recently irradiated fuel. As such, LCO 3.3.6 has the following Applicability:

During movement of recently irradiated fuel assemblies within the containment, During movement of fuel assemblies over recently irradiated fuel assemblies within the containment.

As discussed in Section 2.1, the Unit 2 Containment Purge and Exhaust Isolation Instrumentation is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The Unit 2 Containment Purge and Exhaust Isolation Instrumentation is required to be operable if fuel movement involving recently irradiated fuel is taking place. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and there are no MODES or other plant conditions for which the Unit 2 Containment Purge and Exhaust isolation instrumentation meets the 10 CFR 50.36 criterion for inclusion in the Technical Specifications.

Therefore, deletion of LCO 3.3.6 is consistent with 10 CFR 50.36 and is acceptable.

3.3.7 Control Room Emergency Ventilation (CREVS) Actuation Instrumentation Table 3.3.7-1 is proposed for deletion in its entirety. For clarity, the deletion of Table 3.3.7-1 will be addressed first.

Table 3.3.7-1 CREVS Actuation Instrumentation Applicable Applicable MODES or MODES or Other Other Specified Specified Function Conditions Function Conditions

1. Manual Initiation 1, 2, 3, 4, (a) 1. Manual Initiation 1, 2, 3, 4, (a)

2. Control Room Area (a) 2. Control Room Area (a)

Radiation Monitors Radiation Monitors

3. Containment Isolation - Refer to 3. Containment Isolation - Refer to Phase B LCO 3.3.2 Phase B LCO 3.3.2 Footnote (a) Footnote (a)

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies, and during movement of fuel L-22-053 Page 15 of 41 assemblies over recently irradiated fuel assemblies over recently irradiated fuel assemblies. assemblies.

For entirety of Table 3.3.7-1 see Attachment 2. For entirety of Table 3.3.7-1 deletions, see Attachment 2.

Basis The CREVS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). Footnote (a) appears in the Applicable Modes or Other Specified Conditions column for the Manual Initiation and Control Room Area Radiation Monitors Functions. Footnote (a) is the following applicability statement:

During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies.

Manual Initiation The CREVS Manual Initiation function is applicable in MODES 1, 2, 3, 4, and in the condition specified in footnote (a). The CREVS manual initiation function is credited in DBAs in MODES 1 through 4. The MODES 1 through 4 Operability requirements for the CREVS manual initiation function are unchanged by this LAR and are being retained in the proposed TS 3.3.7 Condition A as discussed later in this table.

The CREVS Manual Initiation function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and the CREVS instrumentation for Manual Initiation is only required in MODES 1 through 4. Addition of LCO 3.9.7, Decay Time, obviates the need for the CREVS instrumentation for Manual Initiation operability in the condition described in footnote (a).

Control Room Area Radiation Monitors The CREVS Control Room Area Radiation Monitors actuation instrumentation is applicable in the condition specified in footnote (a). The CREVS Control Room Area Radiation Monitors actuation function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

As discussed in Section 2.1, the CREVS instrumentation for Manual Initiation and initiation by the Control Room Area Radiation Monitors is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The instrumentation for CREVS initiation by the Control Room Area Radiation Monitors is required to be operable if fuel movement involving recently irradiated fuel is taking place. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and there are no MODES or other plant conditions for which the instrumentation for CREVS initiation by the Control Room Area Radiation Monitors meets the 10 CFR 50.36 criterion for inclusion in the Technical Specifications.

Removal of the Control Room Area Radiation Monitors function from Table 3.3.7-1, as discussed above, includes removal of the trip setpoints for both units specified in Table 3.3.7-1. The Unit 1 L-22-053 Page 16 of 41 control room area radiation monitors, designated as RM-1RM-218 A & B, are required to be FUNCTIONAL in MODES 1 through 4 as specified in the Unit 1 LRM LR 3.3.14, Control Room Isolation Radiation Monitors. Removal of the setpoint requirement from Table 3.3.7-1 during fuel movement involving recently irradiated fuel is appropriate because proposed LCO 3.9.7, Decay Time, will prohibit this activity. The setpoint requirement in MODES 1 through 4, as specified in Unit 1 LRM LR 3.3.14, is unchanged.

Similarly, the Unit 2 control room area radiation monitors, designated as 2RMC-RQ201 & 202, are required to be FUNCTIONAL in MODES 1 through 4 as specified in the Unit 2 LRM LR 3.3.14, Control Room Isolation Radiation Monitors. Removal of the setpoint requirement from Table 3.3.7-1 during fuel movement involving recently irradiated fuel is appropriate because proposed LCO 3.9.7, Decay Time, will prohibit this activity. The setpoint requirement in MODES 1 through 4, as specified in Unit 2 LRM LR 3.3.14, is unchanged.

Therefore, deletion of footnote (a) and Table 3.3.7-1 Item 2, Control Room Area Radiation Monitors, is consistent with 10 CFR 50.36 and is acceptable.

Containment Isolation - Phase B Table 3.3.7-1 Item 3, Containment Isolation - Phase B (CIB), is proposed for deletion. Currently, Table 3.3.7-1 lists CIB as part of the CREVS Actuation Instrumentation but does not list any requirements for the instrumentation. Instead, the Table 3.3.7-1 entry appears to be for information only and simply states: Refer to LCO 3.3.2, ESFAS Instrumentation, Function 3.b, for all initiation functions and requirements. References to LCO 3.3.2 for the CIB appear in the TS Bases. As such, there is no need to repeat this information in the TS LCO.

In Modes 1 through 4, the LOCA accident analysis assumes an automatic Control Room Ventilation System isolation on a CIB signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. As stated in Table 3.3.7-1, the Operability requirements for CIB, in Modes 1 through 4, are specified in LCO 3.3.2, Engineered Safety Feature Actuation System (ESFAS).

As a result of the Modes 1 through 4 Operability requirements for CIB being specified in LCO 3.3.2, the Table 3.3.7-1, Item 3 can be deleted.

Removal of Table 3.3.7-1 As a result of the changes to Table 3.3.7-1 proposed above, the only remaining entry on the Table is the requirement for the CREVS Manual Initiation function to be Operable in Modes 1 through 4. A table with only one entry is unnecessary and the requirements specified in Table 3.3.7-1 for Manual Initiation will be incorporated into LCO 3.3.7 as described below.

Removal of the SRs is discussed below.

Current LCO 3.3.7 Proposed LCO 3.3.7 The CREVS actuation instrumentation for each The CREVS actuation instrumentation for Function in Table 3.3.7-1 shall be OPERABLE. Manual Initiation each Function in Table 3.3.7-1 shall be OPERABLE.

Basis As discussed above, Table 3.3.7-1 is proposed for deletion, therefore, the Operability requirements for the CREVS Manual Initiation function are incorporated directly into LCO 3.3.7.

L-22-053 Page 17 of 41 Current APPLICABILITY Proposed APPLICABILITY According to Table 3.3.7-1. MODES 1, 2, 3, and 4 According to Table 3.3.7-1.

Basis As discussed above, Table 3.3.7-1 is proposed for deletion, therefore, the Applicability requirements for the CREVS Manual Initiation function are incorporated directly into LCO 3.3.7.

- NOTE - - NOTE -

Separate Condition entry is allowed for Separate Condition entry is allowed for each Function. each Function.

Basis As discussed above, Manual Initiation is the only function remaining with associated Conditions and Actions within LCO 3.3.7. Consequently, the Note allowing separate Condition entry for each function, when only one function exists, is unnecessary.

Current CONDITION A Proposed CONDITION A One or more Functions with one channel or One CREVS Manual Initiation or more train inoperable. Functions with one channel or train inoperable.

Basis As discussed above, the Manual Initiation is the only function remaining with associated Conditions and Actions within LCO 3.3.7. With the deletion of Table 3.3.7-1, the condition of one CREVS Manual Initiation train inoperable is incorporated directly into Condition A.

Current CONDITION B Proposed CONDITION B One or more Functions with two channels or Two CREVS Manual Initiation One or more two trains inoperable. Functions with two channels or two trains inoperable.

Basis As discussed above, the Manual Initiation is the only function remaining with associated Conditions and Actions within LCO 3.3.7. With the deletion of Table 3.3.7-1, the condition of two CREVS Manual Initiation trains inoperable is incorporated directly into Condition B.

Current CONDITION C Proposed CONDITION C Required Action and associated Completion Required Action and associated Completion Time for Condition A or B not met in MODE 1, Time for Condition A or B not met in MODE 1, 2, 3, or 4. 2, 3, or 4.

Basis Condition C directs Required Actions if the plant is in MODE 1, 2, 3, or 4. The MODES are specified to distinguish the Condition from that of Condition D, which directs Required Actions if the plant is performing fuel movements involving recently irradiated fuel. The addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, leaving the LCO applicable only in MODES 1 through 4. As such, there is no need to specify that Condition C is applicable in MODES 1, 2, 3, or 4, since these are the only plant conditions that LCO 3.3.7, CREVS Actuation Instrumentation will be applicable. Therefore, the proposed change to Condition C is acceptable.

L-22-053 Page 18 of 41 Current CONDITION D Proposed CONDITION D Required Action and associated Completion Required Action and associated Completion Time for Condition A or B not met during Time for Condition A or B not met during movement of recently irradiated fuel movement of recently irradiated fuel assemblies, or during movement of fuel assemblies, or during movement of fuel assemblies over recently irradiated fuel assemblies over recently irradiated fuel assemblies. assemblies.

Basis Condition D requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this LCO entry Condition. Therefore, deletion of Condition D is acceptable.

- NOTE - - NOTE -

Refer to Table 3.3.7-1 to determine which Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation SRs apply for each CREVS Actuation Function. Function.

SR 3.3.7.1 Perform CHANNEL CHECK. SR 3.3.7.1 Perform CHANNEL CHECK.

SR 3.3.7.2 Perform COT. SR 3.3.7.2 Perform COT.

SR 3.3.7.3 -----------NOTE------------------ SR 3.3.7.31 -----------NOTE------------------

Verification of setpoint is not Verification of setpoint is not required. required.

Perform TADOT. Perform TADOT.

SR 3.3.7.4 Perform CHANNEL SR 3.3.7.4 Perform CHANNEL CALIBRATION. CALIBRATION.

Basis SR 3.3.7.1, CHANNEL CHECK, ensures that a gross failure of the Control Room Area Radiation Monitors instrumentation has not occurred and is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. SR 3.3.7.2, CHANNEL OPERATIONAL TEST (COT), is performed to ensure the entire channel will perform the intended function. SR 3.3.7.4, CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. Per Table 3.3.7-1, these SRs are only applicable during fuel movements involving recently irradiated fuel. The addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur. Consequently, these SR will no longer be applicable.

The Unit 1 and Unit 2 LR 3.3.14, The Control Room Isolation Radiation Monitors, include the following SRs, which are applicable in MODES 1 through 4: LRS 3.3.14.1, CHANNEL CHECK, which ensures that a gross failure of the Control Room Isolation Radiation Monitors instrumentation has not occurred and is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION; LRS 3.3.14.2, CHANNEL OPERATIONAL TEST, which is performed to ensure the entire channel will perform the intended function; and LRS 3.3.14.3, CHANNEL CALIBRATION, which is a complete check of the instrument loop, including the sensor. The Unit 1 and Unit 2 LRM LR 3.3.14, Control Room Isolation Radiation Monitors, and associated surveillance requirements ensure functionality of the Control Room L-22-053 Page 19 of 41 Isolation Radiation Monitors in MODES 1 through 4 and are unchanged by this LAR.

The removal of Table 3.3.7-1 and the SRs associated with the Control Room Area Radiation Monitors instrumentation obviates the need for the Note provided under SURVEILLANCE REQUIREMENTS. SR 3.3.7.3 is renumbered as SR 3.3.7.1 as an administrative change.

Based on the above, removing the applicability requirements for these SRs during fuel movement involving recently irradiated fuel, an activity prohibited by the new LCO 3.9.7, Decay Time, is acceptable.

3.7.10 Control Room Emergency Ventilation System (CREVS)

Current APPLICABILITY Proposed APPLICABILITY MODES 1, 2, 3, and 4, MODES 1, 2, 3, and 4, During movement of recently irradiated During movement of recently irradiated fuel assemblies, fuel assemblies, During movement of fuel assemblies over During movement of fuel assemblies recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

Basis The Control Room Emergency Ventilation System (CREVS) satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). The CREVS is applicable in MODES 1, 2, 3, 4, and during fuel movement involving recently irradiated fuel. The CREVS is credited in DBAs in MODES 1 through 4. The MODES 1 through 4 Operability requirements for the CREVS are unchanged by this LAR.

As discussed in Section 2.1, the CREVS is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The CREVS function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel. Therefore, an FHA involving recently irradiated fuel cannot occur.

The CREVS is only required to be operable in MODES 1 through 4 and if fuel movement involving recently irradiated fuel is taking place. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, the CREVS is only required in MODES 1 through 4. Addition of LCO 3.9.7, Decay Time, obviates the need for the CREVS operability during fuel movement involving recently irradiated fuel.

Therefore, the proposed change to LCO 3.7.10 Applicability is consistent with 10 CFR 50.36 and is acceptable.

L-22-053 Page 20 of 41 Current Condition B Proposed Condition B One or more required CREVS trains One or more required CREVS trains inoperable due to inoperable CRE boundary inoperable due to inoperable CRE boundary in in MODE 1, 2, 3, or 4. MODE 1, 2, 3, or 4.

Current Condition C Proposed Condition C Required Action and associated Completion Required Action and associated Completion Time of Condition A or B not met in MODE 1, Time of Condition A or B not met in MODE 1, 2, 3, or 4. 2, 3, or 4.

Basis Conditions B and C direct Required Actions if the plant is in MODE 1, 2, 3, or 4. In the existing TS, the MODES are specified to distinguish Conditions B and C from that of Conditions D and E, which directs Required Actions if the plant is performing fuel movements involving recently irradiated fuel. The addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, leaving the LCO applicable only in MODES 1 through 4. As such, there is no need to specify that Conditions B and C are applicable in MODES 1, 2, 3, or 4, since these are the only plant conditions that LCO 3.3.7, CREVS, will be applicable.

Therefore, the proposed changes to Conditions B and C are acceptable.

Current Condition D Proposed Condition D Required Action and associated Completion Required Action and associated Completion Time of Condition A not met during movement Time of Condition A not met during movement of recently irradiated fuel assemblies or during of recently irradiated fuel assemblies or during movement over fuel assemblies of recently movement over fuel assemblies of recently irradiated fuel assemblies. irradiated fuel assemblies.

Basis Condition D is only applicable during fuel movements involving recently irradiated fuel. Condition D requires immediately placing the OPERABLE CREVS train in emergency pressurization mode and the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Condition. Therefore, deletion of Condition D is acceptable.

L-22-053 Page 21 of 41 Current Condition E Proposed Condition E Two required CREVS trains inoperable during Two required CREVS trains inoperable during movement of recently irradiated fuel movement of recently irradiated fuel assemblies or during movement of fuel assemblies or during movement of fuel assemblies over recently irradiated fuel assemblies over recently irradiated fuel assemblies. assemblies.

OR OR One or more required CREVS trains One or more required CREVS trains inoperable due to an inoperable CRE inoperable due to an inoperable CRE boundary during movement of recently boundary during movement of recently irradiated fuel assemblies or during movement irradiated fuel assemblies or during movement of fuel assemblies over recently irradiated fuel of fuel assemblies over recently irradiated fuel assemblies. assemblies.

Basis Condition E requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this LCO entry Condition. Therefore, deletion of Condition E is acceptable.

Current Condition F Proposed Condition FD Two required CREVS trains inoperable in Two required CREVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than MODE 1, 2, 3, or 4 for reasons other than Condition B. Condition B.

Current Required Action F.1 Proposed Required Action DF.1 Enter LCO 3.0.3 Enter LCO 3.0.3 Basis Since MODES 1, 2, 3, or 4 are the only applicable plant conditions, it is no longer necessary to specify that the condition is applicable to those modes. Removal of Conditions D and E prompt Condition F and Required Action F.1 to be administratively relabeled Condition D and Required Action D.1, respectively.

3.7.11 Control Room Emergency Air Cooling System (CREACS)

Current LCO 3.7.11 Note Proposed LCO 3.7.11 Note

- NOTE - - NOTE -

For Unit 1, the heat removal function of For Unit 1, the heat removal function of CREACS is not required to be OPERABLE CREACS is not required to be OPERABLE to support fuel movement involving non- to support fuel movement involving non-recently irradiated fuel assemblies. recently irradiated fuel assemblies.

L-22-053 Page 22 of 41 Basis LCO 3.7.11.1 is modified by a note that states that, for Unit 1, the heat removal function of CREACS is not required to support the movement involving non-recently irradiated fuel assemblies. Since the addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, the only fuel movement occurring at either unit will be that of non-recently irradiated fuel. As such, it is not necessary to specify non-recently fuel in the SR Note.

Current APPLICABILITY Proposed APPLICABILITY MODES 1, 2, 3, and 4, MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies During movement of irradiated fuel (Unit 1), assemblies (Unit 1),

During movement of fuel assemblies over During movement of fuel assemblies over irradiated fuel assemblies (Unit 1), irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies (Unit 2), assemblies (Unit 2),

During movement of fuel assemblies over During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2). recently irradiated fuel assemblies (Unit 2).

Basis The Control Room Emergency Air Cooling System (CREACS) satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). The CREACS is applicable in MODES 1, 2, 3, 4 for both units; during fuel movement involving irradiated fuel at Unit 1; and during fuel movement involving recently irradiated fuel at Unit 2. The CREACS is credited in DBAs in MODES 1 through 4, and for an FHA involving irradiated fuel for Unit 1. The MODES 1 through 4, and Unit 1 Operability requirements for the CREACS are unchanged by this LAR.

As discussed in Section 2.1, the CREACS is not required to mitigate the consequences of an FHA at Unit 2 involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

The CREACS function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel.

The CREACS is required to be operable in MODES 1 through 4, during fuel movement involving irradiated fuel at Unit 1, and during fuel movement involving recently irradiated fuel at Unit 2. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel an FHA involving recently irradiated fuel cannot occur and, the CREACS will, consequently, only be required in MODES 1 through 4, and during fuel movement involving irradiated fuel at Unit 1. Addition of LCO 3.9.7, Decay Time, obviates the need for the CREACS operability during fuel movement involving recently irradiated fuel at Unit 2.

Therefore, the proposed change to LCO 3.7.11 Applicability is consistent with 10 CFR 50.36 and is acceptable.

L-22-053 Page 23 of 41 Current Condition C Proposed Condition C

- NOTES - - NOTES -

1. Only applicable to Unit 1 during 1. Only applicable to Unit 1 during movement of irradiated fuel movement of irradiated fuel assemblies or fuel assemblies over assemblies or fuel assemblies over irradiated fuel assemblies. irradiated fuel assemblies.

2. Only applicable to Unit 2 during 2. Only applicable to Unit 2 during movement of recently irradiated fuel movement of recently irradiated fuel assemblies and fuel assemblies over assemblies and fuel assemblies over recently irradiated fuel assemblies. recently irradiated fuel assemblies.

Required Action and associated Required Action and associated Completion Time of Condition A not met. Completion Time of Condition A not met.

Basis Condition C is modified by two Notes. Note 2 states that Condition C is only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies. Since the addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, and CREACS is not required to mitigate the consequences of an FHA at Unit 2 involving non-recently irradiated fuel, the LCO entry Condition C Note 2 is no longer necessary. Therefore, deletion of Condition C, Note 2 is acceptable.

Current Condition D Proposed Condition D

- NOTES - - NOTES -

1. Only applicable to Unit 1 during 1. Only applicable to Unit 1 during movement of irradiated fuel movement of irradiated fuel assemblies or fuel assemblies over assemblies or fuel assemblies over irradiated fuel assemblies. irradiated fuel assemblies.

2. Only applicable to Unit 2 during 2. Only applicable to Unit 2 during movement of recently irradiated fuel movement of recently irradiated fuel assemblies and fuel assemblies over assemblies and fuel assemblies over recently irradiated fuel assemblies. recently irradiated fuel assemblies.

Two CREACS trains inoperable. Two CREACS trains inoperable.

Basis Condition D is modified by two Notes. Note 2 states that Condition D is only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies. Since the addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, and CREACS is not required to mitigate the consequences of an FHA at Unit 2 involving non-recently irradiated fuel, the LCO entry Condition D Note 2 is no longer necessary. Therefore, deletion of Condition D, Note 2, is acceptable.

L-22-053 Page 24 of 41 Current SR 3.7.11.1 - NOTE - Proposed SR 3.7.11.1 - NOTE -

For Unit 1, the verification of heat removal For Unit 1, the verification of heat removal function of CREACS is not required to support function of CREACS is not required to support the movement of non-recently irradiated fuel. the movement of non-recently irradiated fuel.

Basis SR 3.7.11.1 is modified by a note that states that, for Unit 1, the verification of the heat removal function of CREACS is not required to support the movement of non-recently irradiated fuel.

Since the addition of LCO 3.9.7, Decay Time, will ensure that fuel movement involving recently irradiated fuel assemblies does not occur, the only fuel movement occurring at either unit will be that of non-recently irradiated fuel. As such, it is not necessary to specify non-recently fuel in the SR Note.

TS SECTION 3.7.12, Supplemental Leak Collection and Release System (SLCRS)

Current LCO 3.7.12 Proposed LCO 3.7.12 One SLCRS train shall be OPERABLE and in One SLCRS train shall be OPERABLE and in operation. operation.

The requirement for the Supplemental Leak For entirety of LCO 3.7.12, see Attachment 2. Collection and Release System (SLCRS) is deleted.

For entirety of LCO 3.7.12 deletion, see Attachment 2.

Basis TS 3.7.12 is proposed for deletion in its entirety.

The SLCRS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii), that is, a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The SLCRS function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiation fuel at some point in the future and would represent the primary success path for an FHA involving recently irradiated fuel. As such, LCO 3.7.12 has the following Applicability:

When required in accordance with LCO 3.9.3.c.3 (Unit 1 only),

During movement of recently irradiated fuel assemblies within the fuel storage pool, During movement of fuel assemblies over recently irradiated fuel assemblies within the fuel storage pool.

As discussed in Section 2.1, the SLCRS is not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

L-22-053 Page 25 of 41 The SLCRS is required to be Operable when required by LCO 3.9.3.c.3. LCO 3.9.3.c.3 states, that for Unit 1, the Containment Purge and Exhaust System penetrations may be open when the system airflow is exhausted to an OPERABLE filtered SCLRS train. This LCO ensures that, for Unit 1, the purge exhaust is lined up to an OPERABLE SLCRS train when performing fuel movements involving recently irradiated fuel assemblies and, therefore, releases resulting from an FHA involving recently irradiated fuel are filtered such that radiological doses are maintained within the acceptance limit. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel. Therefore, an FHA involving recently irradiated fuel can no longer occur.

Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, there are no MODES or other plant conditions for which the SLCRS meets the 10 CFR 50.36 criterion for inclusion in the Technical Specifications.

The BASES for LCO 3.7.12 states that LCO 3.7.14 requires LCO 3.7.12 be applicable to the fuel cask area when fuel is in the fuel cask area during Unit 2 re-rack project. The BVPS Unit 2 re-rack project was completed in 2012. Therefore, this requirement is historical and doesnt impact the deletion of LCO 3.7.12.

Therefore, deletion of LCO 3.7.12 is consistent with 10 CFR 50.36 and is acceptable.

TS SECTION 3.8.2, AC Sources - Shutdown Current Applicability Proposed Applicability MODES 5 and 6, MODES 5 and 6, During movement of irradiated fuel assemblies During movement of irradiated fuel assemblies (Unit 1), (Unit 1),

During movement of fuel assemblies over During movement of fuel assemblies over irradiated fuel assemblies (Unit 1), irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies (Unit 2), assemblies (Unit 2),

During movement of fuel assemblies over During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2). recently irradiated fuel assemblies (Unit 2).

Basis AC Sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO 3.8.2, AC Sources - Shutdown, is applicable in MODES 5 and 6, during fuel movement involving irradiated fuel at Unit 1, and during fuel movement involving recently irradiated fuel at Unit 2. AC Sources are credited in DBAs in MODES 5 and 6, and in an FHA involving irradiated fuel at Unit 1. The Operability requirements in MODES 5 and 6, and during fuel movement involving irradiated fuel at Unit 1 are unchanged by this LAR.

As discussed in Section 2.1, AC Sources are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel at Unit 2, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The AC Sources function has been retained in TS 3.8.2 in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel.

L-22-053 Page 26 of 41 AC Sources are only required to be operable in MODES 5 and 6, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. AC Sources are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and AC Sources are only required in MODES 5 and 6, and during fuel movements involving irradiated fuel at Unit 1. Addition of LCO 3.9.7, Decay Time, obviates the need for AC Sources to be operable during fuel movement involving recently irradiated fuel at Unit 2.

Therefore, the proposed changes to the Applicability of LCO 3.8.2 is consistent with 10 CFR 50.36 and is acceptable.

Current Required Action A.2.3 Proposed Required Action A.2.3

- NOTE - - NOTE -

Only applicable to Unit 2 Only applicable to Unit 2 Suspend movement of recently irradiated fuel Suspend movement of recently irradiated fuel assemblies and movement of fuel assemblies assemblies and movement of fuel assemblies over recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

Basis Required Action A.2.3 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Required Action. Therefore, deletion of Required Action A.2.3 is acceptable. The AND preceding Required Action A.2.3 is deleted and Required Actions A.2.4 and A.2.5 are administratively renumbered accordingly.

Current Required Action B.3 Proposed Required Action B.3

- NOTE - - NOTE -

Only applicable to Unit 2 Only applicable to Unit 2 Suspend movement of recently irradiated fuel Suspend movement of recently irradiated fuel assemblies and movement of fuel assemblies assemblies and movement of fuel assemblies over recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

Basis Required Action B.3 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Required Action. Therefore, deletion of Required Action B.3 is acceptable. The AND preceding Required Action B.3 is deleted and Required Actions B.4 and B.5 are administratively renumbered accordingly.

L-22-053 Page 27 of 41 TS SECTION 3.8.5, DC Sources - Shutdown Current Applicability Proposed Applicability MODES 5 and 6, MODES 5 and 6, During movement of irradiated fuel assemblies During movement of irradiated fuel assemblies (Unit 1), (Unit 1),

During movement of fuel assemblies over During movement of fuel assemblies over irradiated fuel assemblies (Unit 1), irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies (Unit 2), assemblies (Unit 2),

During movement of fuel assemblies over During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2). recently irradiated fuel assemblies (Unit 2).

Basis DC Sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO 3.8.5, DC Sources - Shutdown, is applicable in MODES 5 and 6, during fuel movement involving irradiated fuel at Unit 1, and during fuel movement involving recently irradiated fuel at Unit 2. The Operability requirements in MODES 5 and 6, in an FHA involving irradiated fuel at Unit 1, are unchanged by this LAR.

As discussed in Section 2.1, DC Sources are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel at Unit 2, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The DC Sources function has been retained in TS 3.8.5 in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel.

DC Sources are only required to be operable in MODES 5 and 6, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. DC Sources are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and DC Sources are only required in MODES 5 and 6, and during fuel movements involving irradiated fuel at Unit 1. Addition of LCO 3.9.7, Decay Time, obviates the need for DC Sources to be operable during fuel movement involving recently irradiated fuel at Unit 2.

Therefore, the proposed changes to the Applicability of LCO 3.8.5 is consistent with 10 CFR 50.36 and is acceptable.

Current Required Action A.2.3 Proposed Required Action A.2.3

- NOTE - - NOTE -

Only applicable to Unit 2 Only applicable to Unit 2 Suspend movement of recently irradiated fuel Suspend movement of recently irradiated fuel assemblies and movement of fuel assemblies assemblies and movement of fuel assemblies over recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

L-22-053 Page 28 of 41 Basis Required Action A.2.3 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Required Action. Therefore, deletion of Required Action A.2.3 is acceptable. The AND preceding Required Action A.2.3 is deleted and Required Actions A.2.4 and A.2.5 are administratively renumbered accordingly.

TS SECTION 3.8.8, Inverters - Shutdown Current Applicability Proposed Applicability MODES 5 and 6, MODES 5 and 6, During movement of irradiated fuel assemblies During movement of irradiated fuel assemblies (Unit 1), (Unit 1),

During movement of fuel assemblies over During movement of fuel assemblies over irradiated fuel assemblies (Unit 1), irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies (Unit 2), assemblies (Unit 2),

During movement of fuel assemblies over During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2). recently irradiated fuel assemblies (Unit 2).

Basis The inverters satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO 3.8.8, Inverters - Shutdown, is applicable in MODES 5 and 6, during fuel movement involving irradiated fuel at Unit 1, and during fuel movement involving recently irradiated fuel at Unit 2. The inverters are credited in DBAs in MODES 5 and 6, in an FHA involving irradiated fuel at Unit 1. The Operability requirements in MODES 5 and 6, and during fuel movement involving irradiated fuel at Unit 1 are unchanged by this LAR.

As discussed in Section 2.1, the inverters are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel at Unit 2, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The Inverters - Shutdown function has been retained in TS 3.8.8 in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel.

The inverters are only required to be operable in MODES 5 and 6, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The inverters are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and the inverters are only required in MODES 5 and 6, and during fuel movements involving irradiated fuel at Unit 1.

Addition of LCO 3.9.7, Decay Time, obviates the need for the inverters to be operable during fuel movement involving recently irradiated fuel at Unit 2.

Therefore, the proposed changes to the Applicability of LCO 3.8.8 is consistent with 10 CFR 50.36 and is acceptable.

L-22-053 Page 29 of 41 Current Required Action A.2.3 Proposed Required Action A.2.3

- NOTE - - NOTE -

Only applicable to Unit 2 Only applicable to Unit 2 Suspend movement of recently irradiated fuel Suspend movement of recently irradiated fuel assemblies and movement of fuel assemblies assemblies and movement of fuel assemblies over recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

Basis Required Action A.2.3 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Required Action. Therefore, deletion of Required Action A.2.3 is acceptable. The AND preceding Required Action A.2.3 is deleted and Required Actions A.2.4 and A.2.5 are administratively renumbered accordingly.

TS SECTION 3.8.10, Distribution Systems - Shutdown Current Applicability Proposed Applicability MODES 5 and 6, MODES 5 and 6, During movement of irradiated fuel assemblies During movement of irradiated fuel assemblies (Unit 1), (Unit 1),

During movement of fuel assemblies over During movement of fuel assemblies over irradiated fuel assemblies (Unit 1), irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel During movement of recently irradiated fuel assemblies (Unit 2), assemblies (Unit 2),

During movement of fuel assemblies over During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2). recently irradiated fuel assemblies (Unit 2).

Basis The electrical distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO 3.8.10, Distribution Systems - Shutdown, is applicable in MODES 5 and 6, during fuel movement involving irradiated fuel at Unit 1, and during fuel movement involving recently irradiated fuel at Unit 2. The electrical distribution systems are credited in DBAs in MODES 5 and 6, and in an FHA involving irradiated fuel at Unit 1. The Operability requirements in MODES 5 and 6, and during fuel movement involving irradiated fuel at Unit 1 are unchanged by this LAR.

As discussed in Section 2.1, the electrical distribution systems are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel at Unit 2, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The electrical distribution function has been retained in TS 3.8.10 in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future. The proposed addition of LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel.

L-22-053 Page 30 of 41 The electrical distribution systems are only required to be operable in MODES 5 and 6, during fuel movement at Unit 1, and if fuel movement involving recently irradiated fuel is taking place at Unit 2. The electrical distribution systems are not required to mitigate the consequences of a Unit 2 FHA involving non-recently irradiated fuel. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and the electrical distribution systems are only required in MODES 5 and 6, and during fuel movements involving irradiated fuel at Unit 1. Addition of LCO 3.9.7, Decay Time, obviates the need for the electrical distribution systems to be operable during fuel movement involving recently irradiated fuel at Unit 2.

Therefore, the proposed changes to the Applicability of LCO 3.8.10 is consistent with 10 CFR 50.36 and is acceptable.

Current Required Action A.2.3 Proposed Required Action A.2.3

- NOTE - - NOTE -

Only applicable to Unit 2 Only applicable to Unit 2 Suspend movement of recently irradiated fuel Suspend movement of recently irradiated fuel assemblies and movement of fuel assemblies assemblies and movement of fuel assemblies over recently irradiated fuel assemblies. over recently irradiated fuel assemblies.

Basis Required Action A.2.3 requires the immediate suspension of movement of recently irradiated fuel assemblies and immediate suspension of movement of fuel assemblies over recently irradiated fuel assemblies. The addition of LCO 3.9.7, Decay Time, will ensure that movement of recently irradiated fuel assemblies and movement of fuel over recently irradiated fuel assemblies does not occur, obviating the need for this Required Action. Therefore, deletion of Required Action A.2.3 is acceptable. The AND preceding Required Action A.2.3 is deleted and Required Actions A.2.4, A.2.5, and A.2.6 are administratively renumbered accordingly.

TS SECTION 3.9.3, Containment Penetrations Current TS 3.9.3 Proposed TS 3.9.3 LCO 3.9.3 LCO 3.9.3 The containment penetrations shall be in the The containment penetrations shall be in the following status following status The requirement for the Unit 2 Containment For entirety of LCO 3.9.3, see Attachment 2. Penetrations is deleted.

For entirety of LCO 3.9.3 deletion, see Attachment 2.

L-22-053 Page 31 of 41 Basis TS 3.9.3 is proposed for deletion in its entirety.

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii), that is, a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Containment penetrations function has been retained in the TS in the event it is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future and would represent the primary success path for an FHA involving recently irradiated fuel. As such, LCO 3.9.3 has the following Applicability:

During movement of recently irradiated fuel assemblies within the containment, During movement of fuel assemblies over recently irradiated fuel assemblies within the containment.

As discussed in Section 2.1, containment penetrations are not required to mitigate the consequences of an FHA involving non-recently irradiated fuel, that is, fuel that has decayed at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

Containment penetrations are required to be operable if fuel movement involving recently irradiated fuel is taking place. Since LCO 3.9.7, Decay Time, will prohibit fuel movement involving recently irradiated fuel, an FHA involving recently irradiated fuel cannot occur and there are no MODES or other plant conditions for which the containment penetrations meet the 10 CFR 50.36 criterion for inclusion in the Technical Specifications.

Therefore, deletion of LCO 3.9.3 is consistent with 10 CFR 50.36 and is acceptable.

L-22-053 Page 32 of 41 NEW TS SECTION 3.9.7, Decay Time Proposed NEW TS 3.9.7, Decay Time LCO 3.9.7: The reactor shall be subcritical for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

APPLICABILITY: During movement of irradiated fuel assemblies within containment, During movement of fuel assemblies over irradiated fuel assemblies within the containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor subcritical < 100 A.1 Suspend movement of Immediately hours. irradiated fuel assemblies within containment.

AND A.2 Suspend movement of Immediately fuel assemblies over irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.9.7.1 The reactor shall be determined to have been Prior to movement of subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> by verification irradiated fuel assemblies of the date and time of subcriticality. within containment Basis The limiting FHA analyzed in the UFSARs includes dropping a single irradiated fuel assembly and handling tool directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100-hour decay time prior to moving irradiated fuel.

The FHA analysis assumes a water level of 23 feet above the top of the irradiated fuel. This requirement is maintained by LCO 3.9.6, Refueling Cavity Water Level, and LCO 3.7.15, Fuel Storage Pool Water Level. These water level requirements, in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to fuel movement involving irradiated fuel, ensure that the resulting offsite and control room dose from the limiting FHA is within the limits required by the regulatory acceptance criteria. Similarly, the proposed LCO 3.9.7, Decay Time, will ensure the FHA analysis initial condition of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> minimum fuel decay time is maintained.

Therefore, the proposed LCO 3.9.7, Decay Time, meets Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) for inclusion in the TS.

L-22-053 Page 33 of 41 TS SECTION 5.5.7, Ventilation Filter Testing Program (VFTP)

Current Ventilation Filter Testing Program Proposed Ventilation Filter Testing Program A program shall be established to implement the A program shall be established to implement the following required testing of Engineered Safety following required testing of Engineered Safety Feature (ESF) filter ventilation systems for the Feature (ESF) filter ventilation systems for the Control Room Emergency Ventilation System Control Room Emergency Ventilation System (CREVS) and the Supplemental Leak Collection (CREVS) and the Supplemental Leak Collection and Release System (SLCRS). and Release System (SLCRS).

Tests described in Specifications 5.5.7.a and Tests described in Specifications 5.5.7.a and 5.5.7.b shall be performed at least once per 5.5.7.b shall be performed at least once per 18 months and after the following: 18 months and after the following:

Each complete or partial replacement of the Each complete or partial replacement of the high efficiency particulate air (HEPA) filter or high efficiency particulate air (HEPA) filter or charcoal adsorber bank; charcoal adsorber bank; Any structural maintenance on the HEPA Any structural maintenance on the HEPA filter or charcoal adsorber housing; filter or charcoal adsorber housing; and Significant painting, fire, or chemical release Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 SLCRS) in any (for the Unit 1 and Unit 2 SLCRS) in any ventilation zone communicating with the system ventilation zone communicating with the system while the filtration system is operating; and while the filtration system is operating; and Significant painting, fire, or chemical release Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the of control room outside air intakes while the system is operating. system is operating.

Tests described in Specification 5.5.7.c shall be Tests described in Specification 5.5.7.c shall be performed at least once per 18 months and performed at least once per 18 months and after the following: after the following:

720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (for the Unit 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (for the Unit 1 and 2 CREVS and the Unit 1 SLCRS) or 1 and 2 CREVS and the Unit 1 SLCRS) or after 4 months of adsorber operation (for the after 4 months of adsorber operation (for the Unit 2 SCLRS); Unit 2 SLCRS);

Any structural maintenance on the charcoal Any structural maintenance on the charcoal adsorber bank housing; adsorber bank housing; and Significant painting, fire, or chemical release Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 SLCRS) in any (for the Unit 1 and Unit 2 SLCRS) in any ventilation zone communicating with the ventilation zone communicating with the system while the filtration system is operating; system while the filtration system is operating; and and Significant painting, fire, or chemical release Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes vicinity of control room outside air intakes L-22-053 Page 34 of 41 while the system is operating. while the system is operating.

Tests described in Specifications 5.5.7.d and Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed at least once per 18 5.5.7.e shall be performed at least once per 18 months. months.

The provisions of SR 3.0.2 and SR 3.0.3 are The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies. applicable to the VFTP test frequencies.

a. Demonstrate for each of the required ESF a. Demonstrate for each of the required ESF systems that an inplace test of the HEPA systems that an inplace test of the HEPA filters shows a penetration and system filters shows a penetration and system bypass specified below when tested in bypass specified below when tested in accordance with ANSI N510-1980 (for the accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS) and the Unit 2 SLCRS Unit 1 and 2 CREVS) and the Unit 2 SLCRS and in accordance with ANSI N510-1975 and in accordance with ANSI N510-1975 (for the Unit 1 SLCRS) at the system (for the Unit 1 SLCRS) at the system flowrate specified below: flowrate specified below:

ESF Penetration Flowrate ESF Penetration Flowrate Ventilation Ventilation System System SLCRS <1.0%(Unit 1) 32,400 cfm and SLCRS <1.0%(Unit 1) 32,400 cfm and 39,600 cfm (Unit 1) 39,600 cfm (Unit 1)

<0.05%(Unit 2) 51,300 cfm and <0.05%(Unit 2) 51,300 cfm and 62,700 cfm (Unit 2) 62,700 cfm (Unit 2)

CREVS <0.05% 800 cfm and 1000 cfm CREVS <0.05% 800 cfm and 1000 cfm

b. Demonstrate for each of the required ESF b. Demonstrate for each of the required ESF systems that an inplace test of the charcoal systems that an inplace test of the charcoal adsorber shows a penetration and system adsorber shows a penetration and system bypass specified below when tested in bypass specified below when tested in accordance with ANSI N510-1980 (for the accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS and the Unit 2 SLCRS) Unit 1 and 2 CREVS and the Unit 2 SLCRS) and ANSI N510-1975 (for the Unit 1 SLCRS) and ANSI N510-1975 (for the Unit 1 SLCRS) at the system flowrate specified below: at the system flowrate specified below:

ESF Penetration Flowrate ESF Penetration Flowrate Ventilation Ventilation System System SLCRS <1.0%(Unit 1) 32,400 cfm and SLCRS <1.0%(Unit 1) 32,400 cfm and 39,600 cfm (Unit 1) 39,600 cfm (Unit 1)

<0.05%(Unit 2) 51,300 cfm and <0.05%(Unit 2) 51,300 cfm and 62,700 cfm (Unit 2) 62,700 cfm (Unit 2)

CREVS <0.5% 800 cfm and 1000 CREVS <0.5% 800 cfm and 1000 cfm cfm

c. Demonstrate for each of the required ESF c. Demonstrate for each of the required ESF systems that a laboratory test of a sample systems that a laboratory test of a sample of of the charcoal adsorber, when obtained as the charcoal adsorber, when obtained as L-22-053 Page 35 of 41 described in Regulatory Guide 1.52, described in Regulatory Guide 1.52, Revision 2, or using a slotted tube sampler Revision 2, or using a slotted tube sampler in accordance with ANSI N509-1980 shows, in accordance with ANSI N509-1980 shows, within 31 days after removal, the methyl within 31 days after removal, the methyl iodide removal efficiency greater than or iodide removal efficiency greater than or equal to the value specified below when equal to the value specified below when tested in accordance with ASTM D3803- tested in accordance with ASTM D3803-1989 at a temperature of 30C, an inlet 1989 at a temperature of 30C, an inlet methyl iodide concentration of 1.75 mg/m3, methyl iodide concentration of 1.75 mg/m3, and an air flow velocity and relative humidity and an air flow velocity and relative humidity (RH) specified below: (RH) specified below:

ESF Removal Air Flow RH ESF Removal Air Flow RH Ventilation Efficiency Velocity Ventilation Efficiency Velocity System System SLCRS 90%(Unit 1) 0.9 ft/sec 95% SLCRS 90%(Unit 1) 0.9 ft/sec 95%

99%(Unit 2) 0.7 ft/sec 70% 99%(Unit 2) 0.7 ft/sec 70%

CREVS 99.5%(Unit 1) 0.68 ft/sec 70% CREVS 99.5%(Unit 1) 0.68 ft/sec 70%

99.5%(Unit 2) 0.7 ft/sec 70% 99.5%(Unit 2) 0.7 ft/sec 70%

d. Demonstrate for each of the required ESF d. Demonstrate for each of the required ESF systems that the pressure drop across the systems that the pressure drop across the combined HEPA filters and the charcoal combined HEPA filters and the charcoal adsorbers is less than the value specified adsorbers is less than the value specified below when tested at the system flowrate below when tested at the system flowrate specified as follows: specified as follows:

ESF Delta P Flowrate ESF Delta P Flowrate Ventilation Ventilation System System SLCRS 6 inches Water 32,400 cfm and SLCRS 6 inches Water 32,400 cfm and Gauge (Unit 1) 39,600 cfm (Unit 1) Gauge (Unit 1) 39,600 cfm (Unit 1) 6.8 inches Water 51,300 cfm and 6.8 inches Water 51,300 cfm and Gauge (Unit 2) 62,700 cfm (Unit 2) Gauge (Unit 2) 62,700 cfm (Unit 2)

CREVS 6 inches Water 800 cfm and 1000 CREVS 6 inches Water 800 cfm and 1000 Gauge (Unit 1) cfm Gauge (Unit 1) cfm 5.6 inches Water 800 cfm and 1000 5.6 inches Water 800 cfm and 1000 Gauge (Unit 2) cfm Gauge (Unit 2) cfm

e. Demonstrate that the heaters for each of the e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified ESF systems dissipate the value specified below when tested in accordance with ANSI below when tested in accordance with ANSI N510-1980. N510-1980.

ESF Wattage ESF Wattage Ventilation Ventilation System System SLCRS 160.9 kW and 264.5 kW (Unit 2 only) SLCRS 160.9 kW and 264.5 kW (Unit 2 only)

CREVS 3.87 kW and 5.50 kW CREVS 3.87 kW and 5.50 kW L-22-053 Page 36 of 41 Basis TS 5.5.7, Ventilation Filter Testing Program (VFTP), implements the required testing of Engineered Safety Feature (EFS) filter ventilation systems for the CREVS and SLCRS. The VFTP specifies maintenance requirements and frequencies, as well as test criteria for the CREVS and SLCRS ventilation systems.

TS LCO 3.7.12, Supplemental Leak Collection and Release System (SLCRS), is proposed for deletion, in its entirety. Deletion of LCO 3.7.12 includes deletion of SR 3.7.12.2 which requires SLCRS filter testing be performed in accordance with the VFTP. As discussed earlier, deletion of LCO 3.7.12 is consistent with 10 CFR 50.36 as the SLCRS no longer represents a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. As such, SLCRS no longer represents an ESF Ventilation System required to be included in the VFTP and its removal from the VFTP is acceptable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 10 CFR 50.36, Technical Specifications Pursuant to 10 CFR 50.36, TSs are required to include items in the following five categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a facilities' TSs.

Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B)

Criterion 2 states that TS LCOs must be established for a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The limiting FHA analyzed includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100-hour decay time prior to moving irradiated fuel. The applicable limits for offsite and control room dose due to an FHA are specified in 10 CFR 50.67 and NUREG-0800, Standard Review Plan, Section 15.0.1, Rev 0.

The FHA analysis assumes a water level of 23 feet above the top of the irradiated fuel. This requirement is maintained by LCO 3.9.6, Refueling Cavity Water Level, and LCO 3.7.15, Fuel Storage Pool Water Level. These water level requirements, in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensure that the resulting offsite and control room dose from the limiting FHA is within the limits required by the regulatory acceptance criteria. Similarly, the proposed LCO L-22-053 Page 37 of 41 3.9.7, Decay Time, will ensure the FHA analysis initial condition of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> minimum fuel decay time is maintained.

Therefore, the proposed LCO 3.9.7, Decay Time, meets Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) for inclusion in the TS.

Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C)

Criterion 3 states that TS LCOs must be established for a SSC that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into the TSs only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion), so that the plant response to DBAs and transients limits the consequences of these events to within the appropriate acceptance criteria.

The following three LCOs are proposed for deletion:

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation; TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS);

TS 3.9.3, Containment Penetrations These LCOs meet Criterion 3 in the current TS because they are part of the success path for an FHA involving recently irradiated fuel. Although BVPS does not have an analysis to support fuel movement involving recently irradiated fuel and the movement of recently irradiated fuel is not permitted, these LCOs were retained in the TS in the event these requirements were necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel at some point in the future.

The proposed addition of LCO 3.9.7, Decay Time, will restrict fuel movement prior to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of decay time and, therefore, an FHA involving recently irradiated fuel can no longer occur. As such, these LCOs no longer are part of the success path for an FHA and no longer meet Criterion 3 for inclusion in the TS. Therefore, their removal from the TS is consistent with 10 CFR 50.36(c)(2)(ii)(C).

The prohibition of fuel movements involving recently irradiated fuel (fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />,) as required by the FHA analysis, appears in the applicability statements, conditions, and notes of the following LCOs:

TS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation; TS 3.7.10, Control Room Emergency Ventilation System (CREVS);

TS 3.7.11, CR Emergency Air Cooling System; TS 3.8.2, AC Sources - Shutdown; L-22-053 Page 38 of 41 TS 3.8.5, DC Sources - Shutdown; TS 3.8.8, Inverters - Shutdown; TS 3.8.10, Distribution Systems.

The proposed addition of LCO 3.9.7, Decay Time, prohibits fuel movement involving recently irradiated fuel in accordance with 10 CFR 50.36(c)(2)(ii) and ensures an FHA involving recently irradiated fuel will not occur. Therefore, the restriction on fuel movement involving recently irradiated fuel that appears in the LCO applicability statements, conditions, and notes are no longer required and are acceptable for deletion as discussed in Section 3.0.

In conclusion, the proposed change does not affect compliance with these regulations and will ensure that the lowest functional capabilities or performance levels of equipment required for safe operation are met.

4.2 No Significant Hazards Consideration Analysis Energy Harbor Nuclear Corp. requests amending the renewed facility operating licenses numbered DPR-66 and NPF-73 for the Beaver Valley Power Station (BVPS), Unit Nos.

1 and 2, respectively. The proposed change would revise the Technical Specifications (TS) to add a Limiting Condition for Operation (LCO) 3.9.7 titled Decay Time restricting movement involving fuel or over fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The current TS restrictions on fuel movement involving fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> appear in the applicability statements and conditions of several TS LCOs. These restrictions will be consolidated in the new LCO titled Decay Time, which will ensure the decay time assumed in the design basis fuel handling accident (FHA) is maintained.

The addition of TS LCO 3.9.7 allows the deletion of the following TSs that only have applicabilities during movement of recently irradiated fuel or movement of fuel over recently irradiated fuel:

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation; TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS);

TS 3.9.3, Containment Penetrations.

Adding TS LCO 3.9.7 would allow requirements for recently irradiated fuel to be removed from the following TSs:

TS 3.3.7, Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation; TS 3.7.10, Control Room Emergency Ventilation System (CREVS);

TS 3.7.11, CR Emergency Air Cooling System; TS 3.8.2, AC [alternating current] Sources - Shutdown; TS 3.8.5, DC [direct current] Sources - Shutdown; TS 3.8.8, Inverters - Shutdown; L-22-053 Page 39 of 41 TS 3.8.10, Distribution Systems; TS 5.5.7, Ventilation Filter Testing Program (VFTP), is also impacted as it involves filters associated with the CREVS and SLCRS.

Energy Harbor Nuclear Corp. has evaluated whether or not 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. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Although BVPS-1 and 2 do not currently have safety analyses that support moving recently irradiated fuel assemblies, TS requirements were retained to address the condition of moving recently irradiated fuel assemblies. These TS requirements were retained as a method of prohibiting fuel movement involving recently irradiated fuel and in the event these requirements are necessary to support fuel movement involving recently irradiated fuel at some point in the future. The addition of LCO 3.9.7, Decay Time, to prohibit the movement of recently irradiated fuel eliminates the possibility of an FHA involving recently irradiated fuel. As such, the requirements that were retained as a method of prohibiting fuel movement involving recently irradiated fuel, that appear in applicability statements, conditions, and notes of several TS LCOs, are unnecessary and are proposed for removal. The addition of LCO 3.9.7, Decay Time, to prohibit the movement of recently irradiated fuel ensures the BVPS FHA assumptions and initial conditions are maintained.

The TS requirements for systems that mitigate the consequences of an FHA involving non-recently irradiated fuel are unaffected by this proposed change.

The proposed change does not alter the design function of the systems involved.

No new systems are installed or removed as part of the proposed change. As such, the probability of an accident previously evaluated is not increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

L-22-053 Page 40 of 41 TS requirements involving recently irradiated fuel were retained as a method of prohibiting fuel movement involving recently irradiated fuel and in the event these requirements are necessary to support fuel movement involving recently irradiated fuel at some point in the future. Energy Harbor Corp. does not anticipate any future need to begin fuel movement involving recently irradiated fuel and therefore, proposes the addition of LCO 3.9.7, Decay Time, to prohibit the movement of recently irradiated fuel. The addition of LCO 3.9.7, Decay Time, to prohibit the movement of recently irradiated fuel eliminates the possibility of an FHA involving recently irradiated fuel and does not create the possibility of a new or different kind of accident. The addition of LCO 3.9.7, Decay Time, to prohibit the movement of recently irradiated fuel ensures the BVPS FHA assumptions and initial conditions are maintained.

The proposed change does not alter the design function of the systems involved.

No new systems are installed or removed as part of the proposed change. As such, no new credible accident is created by the proposed change.

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

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change would replace restrictions on fuel movement involving recently irradiated fuel, which currently appear in the applicability statements, conditions and notes of several LCOs with a new TS LCO titled Decay Time.

The new LCO will provide the same restrictions on the fuel movement involving irradiated fuel that currently exists. The proposed change does not affect the controlling values of parameters used to avoid exceeding regulatory or licensing limits. No Safety Limits are affected by the proposed change. The proposed change does not affect any inputs or assumptions in the accident analyses that demonstrate compliance with regulatory and licensing requirements.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, Energy Harbor Nuclear Corp. concludes that the proposed amendment does not involve a 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.

L-22-053 Page 41 of 41 4.3 Conclusions 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 Commission's 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment 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. However, the proposed amendment does 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 amendment meets 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 amendment.

Attachment 2 L-22-053 Proposed Technical Specification Changes Annotated Copy (29 pages follow)

Unit 2 Containment Purge and Exhaust Isolation Instrumentation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Unit 2 Containment Purge and Exhaust Isolation Instrumentation The requirement for the Unit 2 Containment Purge and Exhaust Isolation Instrumentation is deleted.

LCO 3.3.6 ----------------------------------------------------------------------------------------------

- NOTE -

This Specification is only applicable to Unit 2.

The Containment Purge and Exhaust Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.

APPLICABILITY: During movement of recently irradiated fuel assemblies within the containment, During movement of fuel assemblies over recently irradiated fuel assemblies within the containment.

ACTIONS

- NOTE -

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One radiation monitoring A.1 Restore the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> channel inoperable. channel to OPERABLE status.

B. One or more manual B.1 Place and maintain Immediately initiation channels containment purge and inoperable. exhaust valves in closed position.

OR OR Two radiation monitoring channels inoperable. B.2 Enter applicable Conditions Immediately and Required Actions of OR LCO 3.9.3, "Containment Penetrations," for Required Action and containment purge and associated Completion exhaust isolation valves Time for Condition A not made inoperable by met. isolation instrumentation.

Beaver Valley Units 1 and 2 3.3.6 - 1 Amendments 278 / 161

Unit 2 Containment Purge and Exhaust Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS

- NOTE -

Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge and Exhaust Isolation Function.

SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.6.3 -------------------------------------------------------------------------

- NOTE -

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.3.6 - 2 Amendments 292 / 179

Unit 2 Containment Purge and Exhaust Isolation Instrumentation 3.3.6 Table 3.3.6-1 (page 1 of 1)

Containment Purge and Exhaust Isolation Instrumentation REQUIRED SURVEILLANCE FUNCTION CHANNELS REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1 per valve SR 3.3.6.3 NA

2. Containment Radiation 2 SR 3.3.6.1 1.01 x 10-3 Ci/cc Gaseous SR 3.3.6.2 above background SR 3.3.6.4 Beaver Valley Units 1 and 2 3.3.6 - 3 Amendments 278 / 161

CREVS Actuation Instrumentation 3.3.7 3.3 INSTRUMENTATION 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation LCO 3.3.7 The CREVS actuation instrumentation for each Function in Table 3.3.7-1Manual Initiation shall be OPERABLE.

APPLICABILITY: According to Table 3.3.7-1MODES 1, 2, 3, and 4.

ACTIONS

- NOTE -

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place one CREVS train in 7 days with one channel orCREVS emergency pressurization Manual Initiation train mode of operation.

inoperable.

B. One or more Functions B.1 Place one CREVS train in Immediately with two channels or emergency pressurization twoTwo CREVS Manual mode of operation.

Initiation trains inoperable.

AND B.2 Enter applicable Conditions Immediately and Required Actions of LCO 3.7.10, "CREVS," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time for Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Beaver Valley Units 1 and 2 3.3.7 - 1 Amendments 278 / 161

CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Suspend movement of Immediately associated Completion recently irradiated fuel Time for Condition A or B assemblies.

not met during movement of recently irradiated fuel AND assemblies, or during movement of fuel D.2 Suspend movement of fuel Immediately assemblies over recently assemblies over recently irradiated fuel assemblies. irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS

- NOTE -

Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.31 ------------------------------------------------------------------------

- NOTE -

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.3.7 - 2 Amendments 292 / 179

CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS CHANNELS REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4, (a) 2 trains SR 3.3.7.3 NA

2. Control Room Area Radiation (a) 2 SR 3.3.7.1 Unit 1 Monitors SR 3.3.7.2 0.47 mR/hr SR 3.3.7.4 above background Unit 2 0.476 mR/hr above background

3. Containment Isolation - Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.b, for Phase B all initiation functions and requirements.

(a) During movement of recently irradiated fuel assemblies, and during movement of fuel assemblies over recently irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.3.7 - 3 Amendments 278 / 161

CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

- NOTE -

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of recently irradiated fuel assemblies, During movement of fuel assemblies over recently irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required CREVS train A.1 Restore required CREVS 7 days inoperable for reasons train to OPERABLE status.

other than Condition B.

B. One or more required B.1 Initiate action to implement Immediately CREVS trains inoperable mitigating actions.

due to inoperable CRE boundary in MODE 1, 2, 3, AND or 4.

B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore CRE boundary to 90 days OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Beaver Valley Units 1 and 2 3.7.10 - 1 Amendments 281 / 163

CREVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE CREVS Immediately associated Completion train in emergency Time of Condition A not pressurization mode of met during movement of operation.

recently irradiated fuel assemblies or during OR movement of fuel assemblies over recently D.2 Suspend movement of Immediately irradiated fuel assemblies. recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

E. Two required CREVS E.1 Suspend movement of Immediately trains inoperable during recently irradiated fuel movement of recently assemblies and movement irradiated fuel assemblies of fuel assemblies over or during movement of fuel recently irradiated fuel assemblies over recently assemblies.

irradiated fuel assemblies.

OR One or more required CREVS trains inoperable due to an inoperable CRE boundary during movement of recently irradiated fuel assemblies or during movement of fuel assemblies over recently irradiated fuel assemblies.

FD. Two required CREVS FD.1 Enter LCO 3.0.3. Immediately trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

Beaver Valley Units 1 and 2 3.7.10 - 2 Amendments 281 / 163

CREACS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cooling System (CREACS)

LCO 3.7.11 Two CREACS trains shall be OPERABLE.

- NOTE -

For Unit 1, the heat removal function of CREACS is not required OPERABLE to support fuel movement involving non-recently irradiated fuel assemblies.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel assemblies (Unit 2),

During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACS train A.1 Restore CREACS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Beaver Valley Units 1 and 2 3.7.11 - 1 Amendments 278 / 161

CREACS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ----------------------------------

- NOTES -

1. Only applicable to Unit 1 during movement of irradiated fuel assemblies or fuel assemblies over irradiated fuel assemblies.

2. Only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies.

Required Action and C.1 Place OPERABLE Immediately associated Completion CREACS train in operation.

Time of Condition A not met. OR C.2 Suspend movement of Immediately irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies.

Beaver Valley Units 1 and 2 3.7.11 - 2 Amendments 278 / 161

CREACS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. ----------------------------------

- NOTES -

1. Only applicable to Unit 1 during movement of irradiated fuel assemblies or fuel assemblies over irradiated fuel assemblies.

2. Only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies.

Two CREACS trains D.1 Suspend movement of Immediately inoperable. irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies.

E. Two CREACS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 -------------------------------------------------------------------------

- NOTE -

For Unit 1, the verification of heat removal function of CREACS is not required to support the movement of non-recently irradiated fuel.

Verify each CREACS train has the capability to remove In accordance the required heat load and purge the control room with the atmosphere at the required flow rate. Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.7.11 - 3 Amendments 292 / 179

SLCRS 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Supplemental Leak Collection and Release System (SLCRS)

The requirement for the Supplementation Leak Collection and Release System (SLCRS) is deleted.

LCO 3.7.12 One SLCRS train shall be OPERABLE and in operation.

- NOTE -

The fuel building boundary may be opened intermittently under administrative control.

APPLICABILITY: When required in accordance with LCO 3.9.3.c.3 (Unit 1 only),

During movement of recently irradiated fuel assemblies within the fuel storage pool, During movement of fuel assemblies over recently irradiated fuel assemblies within the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ----------------------------------

- NOTE -

Only applicable to Unit 1.

Requirements of LCO not A.1 Enter applicable Conditions Immediately met when required in and Required Actions of accordance with LCO 3.9.3, "Containment LCO 3.9.3.c.3. Penetrations."

B. Requirements of LCO not -----------------------------------------------

met during fuel movement - NOTE -

involving recently irradiated LCO 3.0.3 is not applicable.

fuel assemblies within fuel -----------------------------------------------

storage pool.

B.1 Suspend movement of Immediately recently irradiated fuel assemblies within the fuel storage pool.

AND B.2 Suspend movement of fuel Immediately assemblies over recently irradiated fuel assemblies within the fuel storage pool.

Beaver Valley Units 1 and 2 3.7.12 - 1 Amendments 278 / 161

SLCRS 3.7.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Verify required SLCRS train is in operation. In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required SLCRS filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.12.3 -------------------------------------------------------------------------

- NOTE -

Only required to be met during movement of recently irradiated fuel assemblies within the fuel storage pool and during movement of fuel assemblies over recently irradiated fuel assemblies within the fuel storage pool.

Verify the required SLCRS train can maintain the fuel In accordance storage pool area at a negative pressure of 0.125 with the (Unit 1), 0.05 (Unit 2) inches water gauge relative to Surveillance atmospheric pressure during system operation. Frequency Control Program Beaver Valley Units 1 and 2 3.7.12 - 2 Amendments 292 / 179

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown," and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel assemblies (Unit 2),

During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2).

ACTIONS

- NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit ------------------------------------------------

inoperable. - NOTE -

Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR Beaver Valley Units 1 and 2 3.8.2 - 1 Amendments 278 / 161

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 -----------------------------------

- NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND A.2.3 -----------------------------------

- NOTE -

Only applicable to Unit 2.

Suspend movement of Immediately recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

AND A.2.43 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.54 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

Beaver Valley Units 1 and 2 3.8.2 - 2 Amendments 278 / 161

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND B.2 -----------------------------------

- NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND B.3 -----------------------------------

- NOTE -

Only applicable to Unit 2.

Suspend movement of Immediately recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

AND B.43 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.54 Initiate action to restore Immediately required DG to OPERABLE status.

Beaver Valley Units 1 and 2 3.8.2 - 3 Amendments 278 / 161

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 One DC electrical power subsystem shall be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel assemblies (Unit 2),

During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2).

ACTIONS

- NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required DC electrical A.1 Declare affected required Immediately power subsystem feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 -----------------------------------

- NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND Beaver Valley Units 1 and 2 3.8.5 - 1 Amendments 278 / 161

DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.3 -----------------------------------

- NOTE -

Only applicable to Unit 2.

Suspend movement of Immediately recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

AND A.2.43 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.54 Initiate action to restore Immediately required DC electrical power subsystems to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ------------------------------------------------------------------------

- NOTE -

The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 Beaver Valley Units 1 and 2 3.8.5 - 2 Amendments 278 / 161

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 Two inverters shall be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel assemblies (Unit 2),

During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2).

ACTIONS

- NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 -----------------------------------

- NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND Beaver Valley Units 1 and 2 3.8.8 - 1 Amendments 278 / 161

Inverters - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.3 -----------------------------------

- NOTE -

Only applicable to Unit 2.

Suspend movement of Immediately recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

AND Immediately A.2.43 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Immediately A.2.54 Initiate action to restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and alignments to In accordance required AC vital buses. with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.8.8 - 2 Amendments 278 / 161

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies (Unit 1),

During movement of fuel assemblies over irradiated fuel assemblies (Unit 1),

During movement of recently irradiated fuel assemblies (Unit 2),

During movement of fuel assemblies over recently irradiated fuel assemblies (Unit 2).

ACTIONS

- NOTE -

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required electrical power distribution feature(s) inoperable.

subsystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 -----------------------------------

- NOTE -

Only applicable to Unit 1.

Suspend movement of Immediately irradiated fuel assemblies and movement of fuel assemblies over irradiated fuel assemblies.

AND Beaver Valley Units 1 and 2 3.8.10 - 1 Amendments 278 / 161

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.3 -----------------------------------

- NOTE -

Only applicable to Unit 2.

Suspend movement of Immediately recently irradiated fuel assemblies and movement of fuel assemblies over recently irradiated fuel assemblies.

AND A.2.43 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Immediately A.2.54 Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

AND Immediately A.2.65 Declare associated required residual heat removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to In accordance required AC, DC, and AC vital bus electrical power with the distribution subsystems. Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.8.10 - 2 Amendments 278 / 161

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations The requirement for the Containment Penetrations is deleted.

LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts,

b. One door in each air lock is closed, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:

1. Closed by a manual or automatic isolation valve, blind flange, or equivalent or

2. Unit 2 only. Capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System, and

3. Unit 1 only. The Containment Purge and Exhaust System penetrations may be open when the system airflow is exhausted to an OPERABLE filtered Supplemental Leak Collection and Release System train.

APPLICABILITY: During movement of recently irradiated fuel assemblies within containment, During movement of fuel assemblies over recently irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend movement of Immediately containment penetrations recently irradiated fuel not in required status. assemblies within containment.

AND A.2 Suspend movement of fuel Immediately assemblies over recently irradiated fuel assemblies within containment.

Beaver Valley Units 1 and 2 3.9.3 - 1 Amendments 278 / 161

Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 --------------------------------------------------------------------

- NOTES -

1. Only applicable to Unit 2.

2. Only required to be met when operating the Containment Purge and Exhaust System in accordance with LCO 3.9.3.c.2.

Verify the containment purge exhaust flow rate is In accordance 7500 cfm. with the Surveillance Frequency Control Program SR 3.9.3.2 Verify each required containment penetration is in the In accordance required status. with the Surveillance Frequency Control Program SR 3.9.3.3 --------------------------------------------------------------------

- NOTES -

1. Only applicable to Unit 2.

2. Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.3.c.1.

Verify each required containment purge and exhaust In accordance valve actuates to the isolation position on an actual or with the simulated actuation signal. Surveillance Frequency Control Program SR 3.9.3.4 --------------------------------------------------------------------

- NOTES -

1. Only applicable to Unit 2.

2. Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.3.c.1.

Verify the isolation time of each containment purge In accordance and exhaust valve is within limit. with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2 3.9.3 - 2 Amendments 292 / 179

Decay Time 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Decay Time LCO 3.9.7 The reactor shall be subcritical for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

APPLICABILITY: During movement of irradiated fuel assemblies within containment, During movement of fuel assemblies over irradiated fuel assemblies within the containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor subcritical < A.1 Suspend movement of Immediately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. irradiated fuel assemblies within containment.

AND A.2 Suspend movement of fuel Immediately assemblies over irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 The reactor shall be determined to have been Prior to movement subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> by verification of the of irradiated fuel date and time of subcriticality. assemblies within containment Beaver Valley Units 1 and 2 3.9.7 - 1 Amendments /

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables,

b. Identification of the procedures used to measure the values of the critical variables,

c. Identification of process sampling points,

d. Procedures for the recording and management of data,

e. Procedures defining corrective actions for all off control point chemistry conditions, and

f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.7 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems for the Control Room Emergency Ventilation System (CREVS) and the Supplemental Leak Collection and Release System (SLCRS).

Tests described in Specifications 5.5.7.a and 5.5.7.b shall be performed at least once per 18 months and after the following:

Each complete or partial replacement of the high efficiency particulate air (HEPA) filter or charcoal adsorber bank; Any structural maintenance on the HEPA filter or charcoal adsorber housing; and Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 SLCRS) in any ventilation zone communicating with the system while the filtration system is operating; and Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Beaver Valley Units 1 and 2 5.5 - 13 Amendments 296 / 184

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

Tests described in Specification 5.5.7.c shall be performed at least once per 18 months and after the following:

720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation (for the Unit 1 and 2 CREVS and the Unit 1 SLCRS) or after 4 months of adsorber operation (for the Unit 2 SLCRS);

Any structural maintenance on the charcoal adsorber bank housing; and Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 SLCRS) in any ventilation zone communicating with the system while the filtration system is operating; and Significant painting, fire, or chemical release (for the Unit 1 and Unit 2 CREVS) in the vicinity of control room outside air intakes while the system is operating.

Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed at least once per 18 months.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

a. Demonstrate for each of the required ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass specified below when tested in accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS) and the Unit 2 SLCRS and in accordance with ANSI N510-1975 (for the Unit 1 SLCRS) at the system flowrate specified below:

ESF Ventilation System Penetration Flowrate SLCRS 1.0% (Unit 1) 32,400 cfm and 39,600 cfm (Unit 1) 0.05% (Unit 2) 51,300 cfm and 62,700 cfm (Unit 2)

CREVS 0.05% 800 cfm and 1000 cfm

b. Demonstrate for each of the required ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass specified below when tested in accordance with ANSI N510-1980 (for the Unit 1 and 2 CREVS and the Unit 2 SLCRS) and ANSI N510-1975 (for the Unit 1 SLCRS) at the system flowrate specified below:

Beaver Valley Units 1 and 2 5.5 - 14 Amendments 296 / 184

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

ESF Ventilation System Penetration Flowrate SLCRS 1.0% (Unit 1) 32,400 cfm and 39,600 cfm (Unit 1) 0.05% (Unit 2) 51,300 cfm and 62,700 cfm (Unit 2)

CREVS 0.5% 800 cfm and 1000 cfm

c. Demonstrate for each of the required ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, or using a slotted tube sampler in accordance with ANSI N509-1980 shows, within 31 days after removal, the methyl iodide removal efficiency greater than or equal to the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30C, an inlet methyl iodide concentration of 1.75 mg/m3, and an air flow velocity and relative humidity (RH) specified below:

ESF Ventilation Removal System Efficiency Air Flow Velocity RH SLCRS 90% (Unit 1) 0.9 ft/sec (Unit 1) 95% (Unit 1) 99% (Unit 2) 0.7 ft/sec (Unit 2) 70% (Unit 2)

CREVS 99.5% (Unit 1) 0.68 ft/sec (Unit 1) 70% (Unit 1) 99.5% (Unit 2) 0.7 ft/sec (Unit 2) 70% (Unit 2)

d. Demonstrate for each of the required ESF systems that the pressure drop across the combined HEPA filters and the charcoal adsorbers is less than the value specified below when tested at the system flowrate specified as follows:

ESF Ventilation System Delta P Flowrate SLCRS 6 inches Water Gauge 32,400 cfm and 39,600 cfm (Unit 1) (Unit 1) 6.8 inches Water 51,300 cfm and 62,700 cfm Gauge (Unit 2) (Unit 2)

CREVS 6 inches Water Gauge 800 cfm and 1000 cfm (Unit 1)

(Unit 1) 5.6 inches Water 800 cfm and 1000 cfm (Unit 2)

Gauge (Unit 2)

Beaver Valley Units 1 and 2 5.5 - 15 Amendments 305 / 195

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

e. Demonstrate that the heaters for each of the ESF systems dissipate the value specified below when tested in accordance with ANSI N510-1980.

ESF Ventilation System Wattage SLCRS 160.9 kW and 264.5 kW (Unit 2 only)

CREVS 3.87 kW and 5.50 kW 5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in waste gas decay tanks (Unit 1) and gaseous waste storage tanks (Unit 2), and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall ensure that the concentration of hydrogen and oxygen is maintained below flammability limits,

b. A surveillance program to ensure that the quantity of radioactivity contained in each waste gas decay tank (Unit 1) and each connected group of waste gas storage tanks (Unit 2) is less than the amount that would result in a whole body exposure of > 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents, and

c. A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations greater than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

Beaver Valley Units 1 and 2 5.5 - 16 Amendments 296 / 184

Attachment 3 L-22-053 Proposed Technical Specification Bases Changes, Annotated Copy (55 pages follow)

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY B 3.3 INSTRUMENTATION B 3.3.6 DeletedUnit 2 Containment Purge and Exhaust Isolation Instrumentation BASES BACKGROUND The Unit 2 containment purge and exhaust isolation instrumentation closes the 42 inch containment isolation valves in the Purge and Exhaust System. This action isolates the containment atmosphere from the environment to minimize releases of radioactivity in the event of a fuel handling accident involving recently irradiated fuel.

Two gaseous (Xe-133) radiation monitoring channels (2HVR-RQ104A&B) are provided as input to the containment purge and exhaust isolation.

The radiation monitors have a measurement range of 10-6 to 10-1 Ci/cc.

The Purge and Exhaust System has inner and outer containment isolation valves in its supply and exhaust ducts. A high radiation signal from the 2HVR-RQ104A gaseous radiation monitor closes the outer isolation valves in each penetration and a high radiation signal from the 2HVR-RQ104B gaseous monitor closes the inner isolation valves in each penetration.

In addition to the automatic closure provided by the high radiation signal each containment purge and exhaust isolation valve may be closed manually by its individual control switch.

APPLICABLE During refueling operations, the postulated event that results in the most SAFETY severe radiological consequences is a fuel handling accident (Ref. 1).

ANALYSES The limiting fuel handling accident analyzed in Reference 1, includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100-hour decay time prior to moving irradiated fuel.

The applicable limits for offsite and control room dose from a fuel handling accident are specified in 10 CFR 50.67. Standard Review Plan, Section 15.0.1, Rev 0 (Ref. 2) provides an additional offsite dose criteria of 6.3 rem total effective dose equivalent (TEDE) for fuel handling accidents.

The water level requirements of LCO 3.9.6, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensure that the resulting offsite and control room dose from the limiting fuel handling accident is within the limits required by 10 CFR 50.67 and within the acceptance criteria of Beaver Valley Units 1 and 2 B 3.3.6 - 1 Revision 0

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

Reference 2 without the need for containment purge and exhaust isolation.

Therefore, the instrumentation requirements of LCO 3.3.6 "Containment Purge and Exhaust Isolation Instrumentation" are only applicable during refueling operations involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />).

Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel. However, the requirements for containment purge and exhaust isolation instrumentation are retained in the Technical Specifications in case these requirements are necessary to support fuel movement involving recently irradiated fuel.

The containment purge and exhaust isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirements ensure that the instrumentation necessary to initiate Containment Purge and Exhaust Isolation, listed in Table 3.3.6-1, is OPERABLE for Unit 2.

The LCO is modified by a Note that states "This specification is only applicable to Unit 2." Unit 1 relies on filtration of the Containment Purge and Exhaust System effluent by an OPERABLE train of Supplemental Leak Collection and Release System (SLCRS) instead of isolation. Unit 1 must rely on filtration due to the design of the Unit 1 Containment Purge and Exhaust System ductwork where the radiation monitors are located.

The Unit 1 ductwork is not designed to withstand a seismic event (Ref. 3).

1. Manual Initiation The LCO requires one manual initiation channel per Purge and Exhaust System isolation valve to be OPERABLE. Containment Purge and Exhaust Isolation may be initiated at any time by using the individual valve control switches in the control room. Each channel consists of a manual switch and interconnecting circuits to the valve actuator.

2. Containment Radiation The LCO specifies two required channels of gaseous radiation monitors to ensure that the radiation monitoring instrumentation necessary to initiate Containment Purge and Exhaust Isolation remains OPERABLE.

Beaver Valley Units 1 and 2 B 3.3.6 - 2 Revision 0

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY BASES LCO (continued)

The required gaseous monitors are an in-line type and are mounted directly in the exhaust ductwork. An OPERABLE radiation monitor channel consists of the monitor and includes any associated circuitry necessary to provide the required isolation function.

APPLICABILITY The containment purge and exhaust isolation instrument requirements are applicable during movement of recently irradiated fuel assemblies or the movement of fuel assemblies over recently irradiated fuel assemblies within containment because this is when there is a potential for the limiting fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements (including the purge and exhaust isolation valves) are addressed by LCO 3.6.3, "Containment Isolation Valves" and LCO 3.6.1, "Containment OPERABILITY." In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist.

Additionally, due to radioactive decay, a fuel handling accident that does not involve recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) will result in doses that are well within the guideline values specified in 10 CFR 50.67 even without containment closure capability. Therefore, under these conditions no requirements are placed on the Containment Purge and Exhaust Isolation Instrumentation.

Although movement of recently irradiated fuel is not currently permitted, the requirements for containment purge and exhaust isolation instrumentation are retained in the Technical Specifications in case these requirements are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel consistent with the guidance of Ref. 4.

ACTIONS If the Trip Setpoint is less conservative than specified in Table 3.3.6-1, the channel must be declared inoperable immediately and the appropriate Condition entered.

A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.6-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

Beaver Valley Units 1 and 2 B 3.3.6 - 3 Revision 29

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY BASES ACTIONS (continued)

A.1 Condition A applies to the failure of one containment purge isolation radiation monitor channel. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore the affected channel is justified by the low likelihood of events occurring during this interval, and recognition that the remaining channel will isolate the purge and exhaust lines on high radiation.

B.1 and B.2 Condition B applies to all Containment Purge and Exhaust Isolation Functions. It addresses the failure of multiple radiation monitoring channels, or the inability to restore a single failed channel to OPERABLE status in the time allowed for Required Action A.1. If one or more manual initiation channels are inoperable, or two radiation monitor channels are inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action to place and maintain containment purge and exhaust isolation valves in their closed position is met or the applicable Conditions of LCO 3.9.3, "Containment Penetrations," are met for each valve made inoperable by failure of isolation instrumentation. The Completion Time for these Required Actions is Immediately.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.6-1 REQUIREMENTS determines which SRs apply to which Containment Purge and Exhaust Isolation Functions.

SR 3.3.6.1 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 two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the unit 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 sensor or the signal processing equipment has drifted outside its limit.

Beaver Valley Units 1 and 2 B 3.3.6 - 4 Revision 29

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

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 LCO required channels.

SR 3.3.6.2 A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of any 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 COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications Surveillance Requirements. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This test verifies the capability of the instrumentation to provide the containment purge and exhaust system isolation. The setpoint shall be left consistent with the current unit specific calibration procedure tolerance.

SR 3.3.6.3 SR 3.3.6.3 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested for each valve. The test includes actuation of the end device (i.e., valve cycles).

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.

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

SR 3.3.6.4 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

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

Beaver Valley Units 1 and 2 B 3.3.6 - 5 Revision 29

Unit 2 Containment Purge and Exhaust Isolation Instrumentation B 3.3.6 FOR INFORMATION ONLY BASES REFERENCES 1. Unit 2 UFSAR 15.7.4.

2. NUREG-0800, Section 15.0.1, Rev. 0, July 2000.

3. NRC Safety Evaluation Report for Unit 1 Amendment 23, 12/12/79.

4. NUREG-1431, "Standard Technical Specifications for Westinghouse Plants," Rev. 2, April 2001.

Beaver Valley Units 1 and 2 B 3.3.6 - 6 Revision 29

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY B 3.3 INSTRUMENTATION B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation BASES BACKGROUND The CREVS provides an enclosed common control room environment from which both units can be operated following an uncontrolled release of radioactivity. During normal operation, the Control Room Ventilation System recirculates the control room air and provides unfiltered makeup air and cooling. Upon receipt of a CREVS actuation signal from either unit, the Unit 1 and 2 control room ventilation intake and exhaust ducts are isolated to prevent unfiltered makeup air from entering the control room. In addition, the CREVS actuation signal from either unit will also automatically start one Unit 2 CREVS fan to provide filtered makeup air to pressurize the control room. If the preferred Unit 2 CREVS fan does not start, the backup Unit 2 fan will automatically start. Unit 1 may take credit for the operation of one or both of the Unit 2 CREVS fans and filters. One of the two Unit 1 CREVS fans and single filter must be manually aligned and placed in service if required. Once the control room ventilation intake and exhaust ducts are isolated, and the CREVS fan is providing filtered makeup, control room ventilation is in the emergency pressurization mode of operation. The CREVS is described in the Bases for LCO 3.7.10, "Control Room Emergency Ventilation System."

The CREVS actuation instrumentation consists of redundant control room area radiation monitors for each unit, Containment Isolation - Phase B (CIB) signal from each unit, and two train related manual switches (pushbuttons) in each unit's control room. A high radiation signal from the radiation monitors in either unit, a CIB from either unit, or manual switch actuation from either unit such that both trains of CREVS receive an actuation signal, will initiate the CREVS actuation sequence described above. The CIB Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation." The Function of the Control Room Area Radiation Monitors is discussed in LRM LR 3.3.14.

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations. The CREVS acts ANALYSES to terminate the supply of unfiltered outside air to the control room, initiate intake air filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

The applicable safety analyses for all design basis accidents considered in MODES 1, 2, 3, and 4 (except LOCA) assume manual initiation of the emergency pressurization mode of operation of control room ventilation (i.e., control room ventilation isolation, filtered makeup, and Beaver Valley Units 1 and 2 B 3.3.7 - 1 Revision 0

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued) pressurization). The LOCA accident analysis assumes an automatic Control Room Ventilation System isolation on a CIB signal and subsequent manual initiation of a CREVS fan for filtered makeup and pressurization of the control room. Although the CIB signal will automatically start a CREVS fan and filtered flow path, a 30-minute delay to allow for manual initiation of a CREVS fan and filtered flow path is specifically assumed in all analyses to permit the use of a Unit 1 CREVS fan and filtration flow path which require manual operator action to place in service (Ref. 1).

The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any design basis accident. However, requirements for the radiation monitors to be OPERABLE are retained in case the monitors are required to support the assumptions of a fuel handling accident analysis for the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or the movement of fuel over recently irradiated fuel consistent with the guidance of Ref. 2.

The CREVS actuation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the CREVS is OPERABLE.

1. Manual Initiation The LCO requires two trains OPERABLE. The operator can initiate the CREVS at any time by using either of two switches (pushbuttons) in the control room. This action will cause actuation of all components in the same manner as a single train of the automatic actuation signals (i.e., isolate control room ventilation and start one Unit 2 CREVS fan aligned for filtration and pressurization).

However, when Unit 1 is relying on the Unit 1 CREVS train, as one of the two required trains, only one of the Unit 1 manual pushbuttons is required to start a Unit 2 Fan, but both Unit 1 pushbuttons must be capable of isolating the control room. In this case, the Unit 1 requirement (on Table 3.3.7-1) for two trains of manual initiation is met by one train of manual initiation that is capable of isolating the control room and starting a Unit 2 fan and one train of manual initiation that is capable of isolating the control room. The capability to manually place the Unit 1 CREVS fan and filtered flow path in service is addressed by the OPERABILITY requirements for the Unit 1 CREVS equipment contained in LCO 3.7.10, "Control Room Emergency Ventilation System."

Beaver Valley Units 1 and 2 B 3.3.7 - 2 Revision 0

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES LCO (continued)

The LCO for Manual Initiation ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

Each manual initiation train consists of a switch (pushbutton) in the control room, and the interconnecting wiring to the actuating relays.

2. Control Room Radiation The LCO specifies two required Control Room Area Radiation Monitors to ensure that the radiation monitoring instrumentation necessary to initiate the CREVS remains OPERABLE.

The required Unit 1 radiation monitors are designated RM-1RM-218 A & B with a measurement range of 10-2 to 103 mR/hr. The required Unit 2 radiation monitors are designated 2RMC-RQ201 & 202 with a measurement range of 10-2 to 103 mR/hr.

32. Containment Isolation Phase B (CIB)

Refer to LCO 3.3.2, Function 3.b, for all initiating Functions and requirements.

If one or more of the CIB functions becomes inoperable in such a manner that only the CREVS function is affected, the Conditions applicable to their CIB function need not be entered. The less restrictive Actions specified for inoperability of the CREVS Functions specify sufficient compensatory measures for this case.

APPLICABILITY The CREVS manual actuation instrumentation must be OPERABLE in MODES 1, 2, 3, and 4 to provide the required CREVS initiation assumed in the applicable safety analyses. In MODES 5 and 6, when no fuel movement involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) is taking place, there are no requirements for CREVS instrumentation OPERABILITY consistent with the safety analyses assumptions applicable in these MODES. In addition, both manual and radiation monitor instrument channels are required OPERABLE when moving recently irradiated fuel or moving fuel over recently irradiated fuel.

Although the movement of recently irradiated fuel is not currently permitted, these requirements are retained in the Technical Specifications in case the CREVS instrumentation is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of Reference 2.

Beaver Valley Units 1 and 2 B 3.3.7 - 3 Revision 0

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES APPLICABILITY (continued)

The Applicability for the CREVS actuation on the ESFAS CIB Functions are specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for discussion of the CIB Function Applicability. The Applicability for the CREVS actuation on the Control Room Area Radiation Monitors Function is specified in LRM LR 3.3.14.

ACTIONS If the Trip Setpoint is less conservative than required in Table 3.3.7-1, the channel must be declared inoperable immediately and the appropriate Condition entered.

A Note has been added to the ACTIONS indicating that separate Condition entry is allowed for each Function. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.7-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to the radiation monitor channel Functions, and the manual initiation train Functions.

If one train of CREVS Manual Initiation is inoperable, or one radiation monitor channel is inoperable in one or more Functions, 7 days are permitted to restore it to OPERABLE status. The 7 day Completion Time is the same as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this Completion Time is the same as provided in LCO 3.7.10. If the channel/train cannot be restored to OPERABLE status, one CREVS train must be placed in the emergency pressurization mode of operation as described in LCO 3.7.10 bases. This accomplishes the actuation instrumentation Function and places the unit in a conservative mode of operation.

B.1 and B.2 Condition B applies to the failure of two radiation monitor channels, or two manual CREVS Manual Initiation trains. The first Required Action is to place one CREVS train in the emergency pressurization mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.10 must also be entered for the remaining CREVS train made inoperable by the inoperable actuation instrumentation. This ensures appropriate limits are placed upon train inoperability as discussed in the Bases for LCO 3.7.10.

Beaver Valley Units 1 and 2 B 3.3.7 - 4 Revision 0

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES ACTIONS (continued)

C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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

D.1 and D.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when moving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or fuel assemblies over recently irradiated fuel. Fuel movement involving recently irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREVS actuation.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1 REQUIREMENTS determines which SRs apply to which CREVS Actuation Functions.

SR 3.3.7.1 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 two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the unit 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 sensor or the signal processing equipment has drifted outside its limit.

Beaver Valley Units 1 and 2 B 3.3.7 - 5 Revision 29

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

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 LCO required channels.

SR 3.3.7.2 A COT is performed on each required channel to ensure the entire channel will perform the intended function. This test verifies the capability of the instrumentation to provide the CREVS actuation. A successful test of any 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 COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications Surveillance Requirements. The setpoints shall be left consistent with the unit specific calibration procedure tolerance.

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

SR 3.3.7.31 SR 3.3.7.31 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested.

A successful test of any 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 TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications Surveillance Requirements.

The test may either include actuation of the end device (i.e., dampers close, and fan starts, etc.), or test up to the point of overlap with other tests that demonstrate actuation of the end devices.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.

Beaver Valley Units 1 and 2 B 3.3.7 - 6 Revision 29

CREVS Actuation Instrumentation B 3.3.7 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.4 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

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

REFERENCES 1. Unit 1 UFSAR Table 14.1-1A and Unit 2 UFSAR Table 15.0-13.

2. NUREG-1431, "Standard Technical Specifications for Westinghouse Plants," Rev. 2, April 2001.

Beaver Valley Units 1 and 2 B 3.3.7 - 7 Revision 29

CREVS B 3.7.10 FOR INFORMATION ONLY BASES BACKGROUND (continued)

Redundant CREVS trains are required OPERABLE to ensure the pressurization and filtration function can be accomplished should one train fail. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREVS is designed in accordance with Seismic Category I requirements.

The CREVS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 rem total effective dose equivalent (TEDE). This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50 and 10 CFR 50.67.

The CREVS is automatically actuated by a containment isolation phase B (CIB) signal (see LCO 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation) or a control room area high radiation signal (see LRM LR 3.3.14, Control Room Isolation Radiation Monitors).

In addition, the CREVS can be actuated manually. The OPERABILITY requirements for the CREVS Manual Initiation instrumentation are specified in LCO 3.3.7, "CREVS Actuation Instrumentation."

CREVS does not have automatic detection and isolation for hazardous chemicals or smoke. Refer to Applicable Safety Analyses for a discussion of the design basis of CREVS with regard to these events.

APPLICABLE The CREVS components are arranged in redundant, safety related SAFETY ventilation trains. The location of most components and ducting within ANALYSES the CRE helps to minimize air in leakage and ensures an adequate supply of filtered air to all areas requiring access. The CREVS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE habitability analyses for the most limiting DBAs: loss of coolant accident (LOCA), control rod ejection accident (CREA), and main steam line break (MSLB) accident, presented in the UFSAR, Chapter 14 (Unit 1) and Chapter 15 (Unit 2) (Ref. 2). CRE isolation and operation of CREVS was not credited in other DBAs.

The worst case single active failure of a component of the CREVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The LOCA accident analysis assumes an automatic isolation of the CRE normal ventilation system following a CIB signal and subsequent manual initiation of a CREVS pressurization fan subsystem for filtered makeup and pressurization of the CRE. Although the CIB signal will automatically start one of the two Unit 2 CREVS pressurization fan subsystems, a Beaver Valley Units 1 and 2 B 3.7.10 - 3 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued) 30 minute delay to allow for manual initiation of a CREVS pressurization fan subsystem is specifically assumed in the analysis to permit the use of the Unit 1 CREVS pressurization fan subsystem which requires manual operator action to place in service (Ref. 3). The CREA and the MSLB accident analyses assume manual initiation of the emergency pressurization mode of operation of CRE ventilation (i.e., CRE ventilation isolation, filtered makeup and pressurization), within 30 minutes after the accident.

Although the CRE occupant dose calculations for the limiting DBAs (i.e.,

LOCA, CREA, and MSLB) assume that the CRE is pressurized in 30 minutes of the accident by manually actuating a pressurization fan subsystem, the specification conservatively requires automatic actuation of a Unit 2 CREVS pressurization fan subsystem.

The current safety analyses do not assume the control room area radiation monitors provide a CREVS actuation signal for any DBA.

However, requirements for the automatic initiation of CREVS (both isolation and pressurization fan subsystems) on high radiation are retained in the Technical Specifications in case this automatic function is required to support the assumptions of a fuel handling accident analysis for the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) or the movement of fuel over recently irradiated fuel consistent with the guidance of NUREG-1431 (Ref. 4).

An automatic start time delay is included in the initiation circuitry of the Unit 2 CREVS pressurization fan subsystems. The basis for this time delay includes the following considerations:

1. The delay times prevent loading of the pressurization fans onto the emergency busses until after the emergency diesel generator load sequencing is completed.

2. The pressurization fan delay times are staggered to ensure only one fan will be operating.

3. A pressurization fan is started early to minimize dose to the operators.

4. The delay times are selected such that sufficient time will be available for the manual initiation of a pressurization fan subsystem within 30 minutes after an accident should a pressurization fan fail to start.

Beaver Valley Units 1 and 2 B 3.7.10 - 4 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES LCO (continued)

The OPERABILITY of CREVS ensures that the CRE will remain habitable with respect to potential radiation hazards for operations personnel during and following all credible accident conditions. The OPERABILITY of this system is based on limiting the radiation exposure to personnel occupying the CRE to 5 rem TEDE. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A", 10 CFR 50 and 10 CFR 50.67. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary, could result in exceeding these dose limits in the event of a large radioactive release.

Each CREVS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE.

A CREVS train is OPERABLE when the associated:

a. Fan is OPERABLE (including required automatic start capability for Unit 2 fans),

b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and

c. Heater, prefilter (Unit 1), moisture separator (Unit 2), ductwork, valves, and dampers are OPERABLE (i.e., capable of supporting pressurization of the CRE when a CREVS train is actuated). This includes:

1) In MODES 1, 2, 3, and 4, the series normal air intake and exhaust isolation dampers for both units must be OPERABLE and capable of automatic closure on a CIB actuation signal. The series normal air intake and exhaust isolation dampers for both units may also be considered OPERABLE when secured in a closed position with power removed.

2) During fuel assembly movement involving recently irradiated fuel assemblies, the series normal air intake and exhaust isolation dampers for both units must be OPERABLE and capable of automatic initiation by a control room high radiation signal. The series air intake and exhaust isolation dampers for both units may also be considered OPERABLE when secured in a closed position with power removed.

LCO 3.3.7, "CREVS Actuation Instrumentation," contains the OPERABILITY, ACTION, and Surveillance Requirements for the CREVS Manual Initiation actuating instrumentation.

Beaver Valley Units 1 and 2 B 3.7.10 - 6 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES LCO (continued)

In order for the CREVS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings (hatches, access panels, floor plugs, etc.), these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated. If the above conditions for utilizing the LCO Note cannot be met, then Action B should be entered.

APPLICABILITY In MODES 1, 2, 3, and 4, and during the movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) and the movement of fuel assemblies over recently irradiated fuel assemblies, the CREVS is required to be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

In MODES 5 and 6, when no fuel movement involving recently irradiated fuel is taking place, there are no requirements for CREVS OPERABILITY consistent with the safety analyses assumptions applicable in these MODES. A for a fuel handling accident (FHA). The design basis FHA results involving non-recently irradiated fuel will result in radiation exposure, to personnel occupying the CRE, that is within the guideline values specified in 10 CFR 50.67 without any reliance on the requirements of this Specification to limit personnel exposure. LCO 3.9.7, Decay Time, restricts movement of fuel that has occupied part of a critical core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

This LCO is applicable during movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) and during movement of fuel assemblies over recently irradiated fuel assemblies. During fuel movement involving recently irradiated fuel there is a potential for a limiting FHA for which the requirements of this Specification may be necessary to limit radiation exposure to personnel occupying the CRE to within the requirements of Beaver Valley Units 1 and 2 B 3.7.10 - 7 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES APPLICABILITY (continued) 10 CFR 50.67. Although the movement of recently irradiated fuel is not currently permitted, these requirements are retained in the Technical Specifications in case the CREVS is necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of Reference 4.

ACTIONS A.1 When one required CREVS train is inoperable for reasons other than an inoperable CRE boundary (this action includes one or more of the associated train related series isolation dampers inoperable), action must be taken to restore it to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train (including the associated train of isolation dampers) is adequate to perform the CRE occupant radiation protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time, and the ability of the remaining train to provide the required safety function.

B.1, B.2, and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. As discussed in the Applicable Safety Analyses section, the current licensing basis identifies that CRE inleakage limits for hazardous chemicals and smoke are not necessary to protect CRE occupants; therefore, the limit established for radiological events is the limiting value for determining entry into Condition B for an inoperable CRE boundary. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that the CRE occupants are protected from hazardous chemicals and smoke. These Beaver Valley Units 1 and 2 B 3.7.10 - 8 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES ACTIONS (continued) mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if If the inoperable CREVS train or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1 and D.2 During fuel movement involving recently irradiated fuel assemblies, if an inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREVS train must immediately be placed in the emergency pressurization mode of operation. This action requires the CRE ventilation isolation dampers to be closed and the CRE to be pressurized by the operating CREVS train. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative action is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Beaver Valley Units 1 and 2 B 3.7.10 - 9 Revision 7

CREVS B 3.7.10 FOR INFORMATION ONLY BASES ACTIONS (continued)

E.1 During fuel movement involving recently irradiated fuel assemblies, if two required CREVS trains are inoperable or with one or more required CREVS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable.

This Action involves suspending movement of recently irradiated fuel assemblies and suspending movement of fuel assemblies over recently irradiated fuel assemblies. This places the unit in a condition that minimizes the accident risk. This Action does not preclude the movement of fuel to a safe position.

FD.1 If both required CREVS trains are inoperable in MODES 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B) the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Two inoperable trains also include the conditions of one or more inoperable series isolation dampers in both trains or one or more inoperable series isolation dampers in one train and the opposite CREVS train inoperable. In this condition, Specification 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check of this system. The CREVS fan and filter flow path is operated for 15 minutes by initiating flow through the HEPA filter and charcoal adsorber train with heaters operating to ensure that they function properly. This Surveillance does not require that the CRE be isolated in order to verify fan and filter flow path functionality. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Beaver Valley Units 1 and 2 B 3.7.10 - 10 Revision 29

CREVS B 3.7.10 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.10.3 This SR verifies that each CREVS train operates as required on an actual or simulated containment isolation phase B actuation signal (only required in MODES 1, 2, 3, and 4) and control room high radiation actuation signal (only required for fuel movement involving recently irradiated fuel). The actuation testing includes verification that each train of series air intake and exhaust isolation dampers for both units close to isolate the CRE from the outside atmosphere. In addition, for Unit 2, the automatic start (following a time delay) of each CREVS pressurization fan subsystem supplying air to pressurize the CRE through the HEPA filters and charcoal adsorber banks is verified. For Unit 1, an automatic start of the CREVS pressurization fan subsystem is not required since the Unit 1 subsystem is placed in service by manual operator action.

LCO 3.3.7, "CREVS Actuation Instrumentation," contains the OPERABILITY requirements including the Applicability, ACTION, and Surveillance Requirements for the CREVS actuating instrumentation.

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

SR 3.7.10.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B Beaver Valley Units 1 and 2 B 3.7.10 -11 Revision 29

CREACS B 3.7.11 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

During emergency operation when the control room is isolated, the safety related CREACS is manually initiated to provide air cooling to maintain the temperature 120F when the normal non safety related air conditioning becomes unavailable. The CREACS is capable of removing sensible and latent heat loads from the control room, which include consideration of equipment heat loads to ensure equipment OPERABILITY. The CREACS heat removal function is only required following post-DBA isolation of the control room (when control room isolation is required to meet radiological dose analysis requirements) and the normal non safety related air conditioning equipment is unavailable.

The heat removal function of CREACS is credited in DBAs for MODES 1, 2, 3, and 4 (e.g., the loss of coolant accident (LOCA), the main steam line break (MSLB) and control rod ejection DBAs for both units require control room isolation). Since neither unit requires control room isolation (and hence the control room heat function of CREACS) to meet its fuel handling accident (FHA) DBA nor requires control room isolation following any other DBA in MODES 5 and 6 (e.g., waste gas tank rupture DBA), the heat removal function of CREACS is not required in MODES 5 and 6 or during fuel movement involving non-recently irradiated fuel.

The design basis of the CREACS control room ventilation purge function ensures the capability to manually purge the air from the control room for selected DBAs to ensure acceptable dose consequences to the control room personnel following a DBA.

For both Unit 1 and Unit 2, the MSLB and steam generator tube rupture (SGTR) accident analyses credit a manually initiated 30 minute control room ventilation purge at a flow rate of 16,200 cfm after the accident sequence is complete and the environmental release has been terminated. Also for Unit 1 only, the FHA analysis for fuel movement involving non-recently irradiated fuel credits a manually initiated 30 minute control room ventilation purge at a flow rate of 16,200 cfm after the accident sequence is complete and the environmental release has been terminated. The dose consequence analyses assume that for the MSLB, the SGTR, and the Unit 1 FHA, control room purge is initiated at T=24 hours, T=8 hours and T=2 hours after accident initiation, respectively.

Only Unit 1 requires the purge function of CREACS during fuel movement involving non-recently irradiated fuel. Therefore, the purge function of CREACS is required for Unit 1 during fuel movement involving non-recently irradiated fuel. Thus, the control room ventilation purge functions of CREACS are credited in DBAs for MODES 1, 2, 3, and 4 at both units, and for fuel movement involving non-recently irradiated fuel assemblies at Unit 1.

Beaver Valley Units 1 and 2 B 3.7.11 - 2 Revision 0

CREACS B 3.7.11 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

This LCO is also applicable for both units during movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) and during movement of fuel assemblies over recently irradiated fuel assemblies. The requirement for recently irradiated fuel assemblies is included because there is a potential for a limiting FHA for which the requirements of this Specification may be necessary to limit radiation exposure to personnel occupying the control room to within the requirements of 10 CFR 50.67. Although the movement of recently irradiated fuel is not currently permitted for either unit, the requirements for both the temperature control and purge functions are retained in the Technical Specifications in case the CREACS functions are necessary to support the assumptions of a safety analysis for fuel movement involving recently irradiated fuel, consistent with the guidance of NUREG-1431 (Ref. 3).

The CREACS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The Unit 1 FHA analysis does not require control room isolation to limit the dose to control room personnel to within the required limits.

Therefore, a Note modifying the LCO requirement is included to clarify that the Unit 1 CREACS heat removal function is not required OPERABLE to support fuel movement involving non-recently irradiated fuel. Only the purge function of the Unit 1 CREACS is required to support fuel movement involving non-recently irradiated fuel as only the purge function is required in the Unit 1 accident analysis to limit dose. The Note is only applicable to Unit 1 because operation of the Unit 2 CREACS is not required by the Unit 2 FHA analysis for fuel movement involving non-recently irradiated fuel. Therefore, operation of the Unit 2 CREACS is not required to limit the dose to control room personnel from a FHA involving non-recently irradiated fuel.

Two trains of the CREACS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disabling the other train. Total system failure of the heat removal function could result in the equipment operating temperature exceeding limits in the event of an accident. Total system failure of the control room atmosphere purge function could result in exceeding a dose of 5 rem TEDE to the control room operator in the event of a large radioactive release following a MSLB, SGTR, or a Unit 1 FHA.

Beaver Valley Units 1 and 2 B 3.7.11 - 3 Revision 0

CREACS B 3.7.11 FOR INFORMATION ONLY BASES LCO (continued)

With regard to the control room atmospheric purge function only, the LCO requirement for two OPERABLE CREACS trains may be met by crediting OPERABLE Unit 1 train(s) for Unit 2 and crediting OPERABLE Unit 2 train(s) for Unit 1. The control room atmospheric purge flow requirements for each unit are the same and the control room envelope is common.

Therefore, the purge flow assumed in the DBA analysis may be accomplished by the manual initiation of a CREACS train from either unit.

The CREACS is considered to be OPERABLE when the individual components necessary to maintain the control room temperature 120F (when the control room is isolated) and to provide the control room ventilation purge function at the required flow rate are OPERABLE in two trains. These components include the river/service water emergency cooling coils, necessary ductwork and associated dampers, fans, and associated fan controls. The capability to manually operate the components of the CREACS is all that is required for OPERABILITY. In addition, the CREACS must be OPERABLE to the extent that air circulation necessary for the required temperature control can be maintained.

APPLICABILITY CREACS must be OPERABLE in MODES 1, 2, 3, and 4 at either unit and during fuel movement involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) at either unit. The CREACS ensures that control room temperatures will not exceed equipment operational requirements and that the control room ventilation is capable of purging the control room atmosphere after a DBA to maintain dose within the limit.

For Unit 1 only, during movement of non-recently irradiated fuel assemblies and during movement of fuel assemblies over non-recently irradiated fuel assemblies, the ventilation purge function of CREACS must be OPERABLE. The Unit 1 temperature control function of CREACS is not required OPERABLE during fuel movement involving non-recently irradiated fuel because the Unit 1 FHA analysis does not require control room isolation to limit dose.

CREACS is not required in MODES 5 or 6 at either unit when fuel movement is not occurringduring no fuel movement nor is it required during fuel movement involving non-recently irradiated fuel movement at Unit 2.

Beaver Valley Units 1 and 2 B 3.7.11 - 4 Revision 0

CREACS B 3.7.11 FOR INFORMATION ONLY BASES ACTIONS A.1 With one CREACS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to maintain the control room temperature 120F when the control room is isolated and provide the required control room atmosphere purge function. However, the overall reliability is reduced because a single failure in the OPERABLE CREACS train could result in loss of CREACS function. The 30 day Completion Time is based on the low probability of an event requiring control room isolation or purge, the consideration that the remaining train can provide the required protection, and that alternate safety or nonsafety related means of cooling the control room air and of purging the control room atmosphere are available.

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable CREACS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1 and C.2 Condition C is modified by atwo Notes indicating the applicability of this Condition to Unit 1each unit. The Note 1 states that the Condition is only applicable to Unit 1 during movement of irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies. The Condition is not applicable to Unit 2Note 2 states that this Condition is only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies. If the inoperable CREACS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREACS train must be placed in operation immediately. This action requires that the OPERABLE CREACS ventilation fan be in service and circulating control room air, and if the heat removal function is required by the LCO, with river/service water being supplied to the emergency cooling coils. This action ensures the remaining train is OPERABLE and active failures will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room or a purge of the control room atmosphere.

Beaver Valley Units 1 and 2 B 3.7.11 - 5 Revision 0

CREACS B 3.7.11 FOR INFORMATION ONLY BASES ACTIONS (continued)

This involves suspending movement of irradiated fuel assemblies and suspending movement of fuel assemblies over irradiated fuel assemblies.

This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

D.1 Condition D is modified by atwo Notes indicating the applicability of this Condition to Unit 1each unit. The Note 1 states that the Condition is only applicable to Unit 1 during movement of irradiated fuel assemblies and fuel assemblies over irradiated fuel assemblies. The Condition is not applicable to Unit 2Note 2 states that this Condition is only applicable to Unit 2 during movement of recently irradiated fuel assemblies and fuel assemblies over recently irradiated fuel assemblies. With two CREACS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room or a purge of the control room atmosphere. This involves suspending movement of irradiated fuel assemblies and suspending movement of fuel assemblies over irradiated fuel assemblies.

This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

E.1 If both CREACS trains are inoperable in MODE 1, 2, 3, or 4, the control room CREACS may not be capable of performing its intended function.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies the heat removal capability of the system is sufficient to remove the required heat load to maintain the control room temperature within the equipment design limit ( 120F). The verification of the CREACS heat removal capability consists of a combination of river/service water flow measurement, fan performance, and mechanical cleaning and inspections of the river/service water cooling coils.

This SR also verifies the control room atmosphere purge capability of the system is sufficient to remove air from the control room for the DBAs that require a control room purge to limit dose. The control room purge capability is verified by assuring each train of CREACS can be aligned to purge the control room atmosphere and can achieve the required purge flow rate of 16,200 cfm. This part of the SR may be accomplished by Beaver Valley Units 1 and 2 B 3.7.11 - 6 Revision 0

SLCRS B 3.7.12 FOR INFORMATION ONLY B 3.7 PLANT SYSTEMS B 3.7.12 DeletedSupplemental Leak Collection and Release System (SLCRS)

BASES BACKGROUND SLCRS filters airborne radioactivity from the containment building (Unit 1 only) and the fuel building (both Units) following a fuel handling accident involving recently irradiated fuel. This ensures that, prior to release to the environment, the exhaust from these areas in the event of a fuel handling accident is limited to radioactive releases within 10 CFR 50.67 (Ref. 1) limits. For Unit 1, the SLCRS train consists of a prefilter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), a high efficiency particulate air (HEPA) filter, and a filter exhaust fan. Ductwork, valves or dampers, and instrumentation also form part of the system. For Unit 2, the SLCRS train consists of a heater, a demister, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a filter exhaust fan. Ductwork, valves or dampers, and instrumentation also form part of the system, as well as demisters functioning to reduce the relative humidity of the air stream. For Unit 2 only, a second bank of HEPA filters follows the adsorber section to collect carbon fines and provides a backup in case the main HEPA filter bank fails. The downstream HEPA filter is not credited in the accident analysis, but serves to collect charcoal fines, and to back up the upstream HEPA filter should it develop a leak.

The SLCRS is discussed in References 2 and 3. The SLCRS may be used for normal, as well as post accident, atmospheric cleanup functions.

During normal operation, the SLCRS provides ventilation to the areas it serves.

APPLICABLE During fuel handling operations, the postulated event that results in the SAFETY most severe radiological consequences is a fuel handling accident ANALYSES (Ref. 4). The limiting fuel handling accident analyzed in Reference 4, includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decay time prior to moving irradiated fuel.

The applicable limits for offsite and control room dose from a fuel handling accident are specified in 10 CFR 50.67. Standard Review Plan, Section 15.0.1, Rev 0 (Ref. 5) provides an additional offsite dose criteria of 6.3 rem total effective dose equivalent (TEDE) for fuel handling accidents.

Beaver Valley Units 1 and 2 B 3.7.12 - 1 Revision 0

SLCRS B 3.7.12 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

The water level requirements of LCO 3.7.15, "Fuel Storage Pool Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensure the resulting offsite and control room dose from the limiting fuel handling accident is within the limits required by 10 CFR 50.67 and within the acceptance criteria of Reference 5 without the need for containment and fuel building closure or filtration.

Therefore, the SLCRS requirements contained in LCO 3.7.12 are only applicable during refueling operations involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />). Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel. However, the requirements for SLCRS are retained in the Technical Specifications in case these requirements are necessary to support fuel movement involving recently irradiated fuel consistent with the guidance of NUREG-1431 (Ref. 6).

The SLCRS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO limits the consequences of a fuel handling accident involving recently irradiated fuel in the containment (Unit 1 only) and the fuel storage pool (both units) by limiting the potential escape paths for fission product radioactivity. One train of the SLCRS exhausting from the fuel building and/or for Unit 1, the containment is required to be OPERABLE and in operation during fuel movement involving recently irradiated fuel with the required area exhaust flow discharging through the SLCRS HEPA filters and charcoal adsorbers. This ensures that air, prior to release to the environment, is being filtered during fuel movement within the fuel storage pool and/or, for Unit 1 only, during fuel movement within the containment when required in accordance with LCO 3.9.3.c.3.

System failure could result in the atmospheric release from SLCRS exceeding 10 CFR 50.67 limits in the event of a fuel handling accident involving recently irradiated fuel. The SLCRS is considered OPERABLE when individual components ensure the radioactivity released in the areas of the containment (Unit 1 only) and the fuel building is filtered through the SLCRS and that fuel building doors are closed.

A SLCRS train is considered OPERABLE when its associated:

a. Fan is OPERABLE,

b. HEPA filter and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions, and

c. Heater (Unit 2 only), demister (Unit 2 only), ductwork, valves, and dampers are OPERABLE and air flow can be maintained.

Beaver Valley Units 1 and 2 B 3.7.12 - 2 Revision 29

SLCRS B 3.7.12 FOR INFORMATION ONLY BASES LCO (continued)

The SLCRS is considered in operation whenever the required area(s) exhaust flow is discharging through at least one train of the SLCRS HEPA filters and charcoal adsorbers. The LCO is modified by a Note allowing the fuel building boundary to be opened intermittently under administrative controls. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when fuel building isolation is required to support SLCRS operation.

As clarified in the LCO 3.7.14 NOTE, applicable to Unit 2 only, Specification 3.7.12 applies to the fuel cask area when a fuel assembly is in the cask area during the installation phase of the Unit 2 rerack project.

APPLICABILITY When required in accordance with LCO 3.9.3.c.3 (for Unit 1), one train of SLCRS is required to be OPERABLE and in operation to alleviate the consequences of a fuel handling accident inside containment. This Applicability applies only to Unit 1 in accordance with the provisions of LCO 3.9.3, "Containment Penetrations" when the Containment Purge and Exhaust System penetrations are open coincident with fuel movement involving recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) within containment.

During movement of recently irradiated fuel assemblies (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) within the fuel storage pool or during movement of fuel assemblies over recently irradiated fuel assemblies within the fuel storage pool, one train of SLCRS is required to be OPERABLE and in operation to alleviate the consequences of a potential fuel handling accident.

Since SLCRS is not credited in any existing DBA analysis applicable in MODES 1, 2, 3, 4, 5, and 6 the SLCRS is not required to be OPERABLE in these MODES (except as required to support fuel movement involving recently irradiated fuel assemblies described above).

ACTIONS A.1 A Note modifies Condition A since this Condition is only applicable to Unit 1. Only Unit 1 relies on SLCRS to filter the exhaust from the containment building to mitigate a fuel handling accident involving the movement of recently irradiated fuel.

Beaver Valley Units 1 and 2 B 3.7.12 - 3 Revision 16

SLCRS B 3.7.12 FOR INFORMATION ONLY BASES ACTIONS (continued)

This Condition is only applicable when a Unit 1 SLCRS train is required OPERABLE and in operation in accordance with the provision of the containment penetrations LCO requirement 3.9.3.c.3. If the required SLCRS train is inoperable or not in operation, the requirements of LCO 3.9.3 are not met. Immediate action must be taken to place the unit in a condition in which LCO 3.9.3 does not apply. The applicable Conditions and Required Actions of LCO 3.9.3, "Containment Penetrations" must be entered immediately. The Required Actions of LCO 3.9.3 provide the appropriate precautions, for this condition, to preclude a fuel handling accident involving recently irradiated fuel inside containment for which the SLCRS train is required.

B.1 and B.2 A Note indicating that LCO 3.0.3 does not apply modifies Required Action B.1 and B.2.

With SLCRS inoperable or not in operation the requirements of the LCO cannot be met during fuel movement involving recently irradiated fuel within the fuel storage pool. Immediate action must be taken to place the unit in a condition in which the LCO does not apply. Immediate action must be taken to suspend movement of recently irradiated fuel assemblies and the movement of fuel assemblies over recently irradiated fuel assemblies in the fuel storage pool. This will preclude a fuel handling accident involving recently irradiated fuel. The requirements of this action do not preclude the movement of fuel assemblies to a safe position.

If fuel movement involving recently irradiated fuel takes place in MODES 1, 2, 3, or 4, LCO 3.0.3 is applicable. However, fuel movement is independent of reactor operation. Therefore, a plant shutdown in accordance with LCO 3.0.3 is not required if this Required Action is not met.

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS This SR requires verification that the required portion (fuel building exhaust or containment exhaust (Unit 1)) of the SLCRS train is in operation with the required area exhaust flow discharging through the SLCRS HEPA filters and charcoal adsorbers. Verification includes operation of fans, alignment of dampers, and discharge flow paths from the fuel building or containment (Unit 1 only). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Beaver Valley Units 1 and 2 B 3.7.12 - 4 Revision 29

SLCRS B 3.7.12 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.2 This SR verifies that the required SLCRS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorbers efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.12.3 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the SLCRS. During fuel movement involving recently irradiated fuel assemblies in the fuel storage pool, the SLCRS must be OPERABLE and in operation. To ensure performance during a fuel handling accident the fuel pool storage area must be maintained at a negative pressure relative to atmospheric pressure during system operation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

A Note that states this Surveillance is only required to be met during fuel movement involving recently irradiated fuel assemblies within the fuel storage pool modifies this SR. This Note is necessary as the Unit 1 SLCRS is also required in accordance with LCO 3.9.3.c.3 during fuel movement involving recently irradiated fuel inside containment. As SR 3.7.12.3 has nothing to do with fuel movement inside containment, it is not required in order to confirm the OPERABILITY of a Unit 1 SLCRS train for compliance with LCO 3.9.3.c.3.

REFERENCES 1. 10 CFR 50.67.

2. UFSAR, Section 6.6 (Unit 1) and Section 6.5.3.2 (Unit 2).

3. UFSAR, Section 9.13.2 (Unit 1) and Section 9.4 (Unit 2).

4. UFSAR Section 14.2.1 (Unit 1) and Section 15.7.4 (Unit 2).

5. NUREG-0800, Section 15.0.1, Rev 0.

Beaver Valley Units 1 and 2 B 3.7.12 - 5 Revision 29

SLCRS B 3.7.12 FOR INFORMATION ONLY BASES REFERENCES (continued)

6. NUREG-1431, Rev. 2, Standard Technical Specifications for Westinghouse Plants.

Beaver Valley Units 1 and 2 B 3.7.12 - 6 Revision 29

AC Sources - Shutdown B 3.8.2 FOR INFORMATION ONLY B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of irradiated fuel assemblies or movement of fuel ANALYSES assemblies over irradiated fuel assemblies for Unit 1 (which includes recently irradiated fuel) and during movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The current fuel handling accident safety analysis does not rely on the automatic actuation of any systems or components to mitigate the accident. Furthermore, the current fuel handling accident analysis does not assume isolation or filtration to mitigate the event. However, in order to limit the control room dose following a fuel handling accident, Unit 1 must purge the control room atmosphere for 30 minutes following termination of the release (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the accident). The required Unit 1 purge is a manual action for which the Technical Specifications require power (LCO 3.8.2) and ventilation system (LCO 3.7.11)

OPERABILITY when moving any irradiated fuel assemblies or fuel assemblies over any irradiated fuel assemblies. The Unit 1 requirement to purge the control room after a fuel handling accident involving any type of irradiated fuel is the reason for the difference in theUnit 1 fuel movement applicability for each unit in LCO 3.8.2 and LCO 3.7.11.

Although not a specific assumption of the safety analyses, this Specification requires that the DG automatically start, connect to the emergency bus, and automatically sequence the required loads. This capability in conjunction with the loss of voltage relays required OPERABLE by LCO 3.3.5, "Loss of Power (LOP) DG Start and Bus Separation Instrumentation," assures that a reliable source of AC power Beaver Valley Units 1 and 2 B 3.8.2 - 1 Revision 0

AC Sources - Shutdown B 3.8.2 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued) is promptly available in the event offsite power is lost. In addition, this capability provides automatic protection against degraded voltage conditions (via the degraded voltage sensing relays required OPERABLE in LCO 3.3.5) that could damage equipment required to maintain the unit in a safe shutdown condition. Therefore, the prompt availability of reliable backup emergency power provides additional assurance that the unit can be maintained in a safe shutdown condition in the event the grid becomes unstable.

Current TS LCO 3.9.7 requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />).

However, the Technical Specifications continue to address fuel movement involving recently irradiated fuel to support requirements for isolation or filtration that may be necessary to mitigate a fuel handling accident involving recently irradiated fuel. The retention of requirements within the Technical Specifications, in case the requirements are necessary to support fuel movement involving recently irradiated fuel, is consistent with the guidance of Reference 1.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

Beaver Valley Units 1 and 2 B 3.8.2 - 2 Revision 0

AC Sources - Shutdown B 3.8.2 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions. These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with the distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving irradiated fuel for Unit 1(Unit 1) and recently irradiated fuel (Unit 2)).

The qualified offsite circuit must be capable of maintaining nominal frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es).

Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the unit.

During normal plant operation, electrical power for the onsite circuits comes from either the main generator through 22 kV to 4.36 kV unit station service transformers or from the two independent offsite 138 kV buses through 138 kV to 4.36 kV system station service transformers.

Beaver Valley Units 1 and 2 B 3.8.2 - 3 Revision 0

AC Sources - Shutdown B 3.8.2 FOR INFORMATION ONLY BASES LCO (continued)

The secondary windings of the transformers are connected to four separate 4.16 kV normal buses, A, B, C, and D. Buses A and D provide power for the two redundant Class 1E 4.16 kV emergency buses AE and DF, respectively. During plant shutdown, the emergency buses receive power from the system station service transformers, or may receive power from the unit station service transformers by backfeeding the main transformer.

The DG must be capable of starting, accelerating to nominal speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. This sequence must be accomplished within 10 seconds.

The 10 second timing requirement begins when the DG start signal is received by the DG start circuit and does not include the time it takes the instrumentation to detect a loss of voltage on the emergency busses. The DG must be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.

Proper sequencing of required loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 (which includes recently irradiated fuel) and during movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 provides assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core,

b. Systems needed to mitigate a fuel handling accident involving irradiated fuel (Unit 1) and recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> (Unit 2) are available,

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and Beaver Valley Units 1 and 2 B 3.8.2 - 4 Revision 4

AC Sources - Shutdown B 3.8.2 FOR INFORMATION ONLY BASES APPLICABILITY (continued)

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 An offsite circuit would be considered inoperable if it were not available to the necessary portions of the electrical power distribution subsystem(s).

One train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, A.2.4, A.2.5, B.1, B.2, B.3, and B.4, and B.5 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Beaver Valley Units 1 and 2 B 3.8.2 - 5 Revision 0

DC Sources - Shutdown B 3.8.5 FOR INFORMATION ONLY B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the UFSAR, Chapter 6 (Ref. 1) and Reference 2, assume that ANALYSES Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of irradiated fuel assemblies or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving handling irradiated fuel. For Unit 2 only, due to radioactive decay, DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. In future discussions, the term fuel assemblies will include "irradiated" and "recently irradiated" as applicable for each unit.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are Beaver Valley Units 1 and 2 B 3.8.5 - 1 Revision 0

DC Sources - Shutdown B 3.8.5 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued) analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The DC electrical power subsystem, the required subsystem consisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling within the train, is required to be OPERABLE to support one train of the distribution systems required OPERABLE by LCO 3.8.10, "Distribution Systems - Shutdown." This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving irradiatedhandling fuel).

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DC Sources - Shutdown B 3.8.5 FOR INFORMATION ONLY BASES APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of fuel assemblies for Unit 1, provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core,

b. Required features needed to mitigate a fuel handling accident involving handling fuel are available,

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2.1, A.2.2, A.2.3, and A.2.4, and A.2.5 By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of fuel assemblies, and operations involving positive reactivity additions) that could result in loss of required shutdown margin (SDM)

(MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the Reactor Coolant System (RCS) for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining Beaver Valley Units 1 and 2 B 3.8.5 - 3 Revision 0

Inverters - Shutdown B 3.8.8 FOR INFORMATION ONLY B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the UFSAR, Chapter 6 (Ref. 1) and Reference 2, assume ANALYSES Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 and 6 and during movement of irradiated fuel or movement of fuel assemblies over irradiated fuel assemblies fuel movement for Unit 1 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident involving handling irradiated fuel or movement of fuel assemblies over irradiated fuel assemblies for Unit 1. or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2. For Unit 2 only, due to radioactive decay, the inverters are only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

In future discussions, the term fuel assemblies will include "irradiated" and "recently irradiated" as applicable for each unit.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

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Inverters - Shutdown B 3.8.8 FOR INFORMATION ONLY BASES APPLICABLE SAFETY ANALYSES (continued)

The rationale for this is based on the fact that many DBAs that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The inverters with battery backup power provide uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. OPERABILITY of the inverters require that the AC vital bus be powered by the inverter. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents involving handling irradiated fuel).

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Inverters - Shutdown B 3.8.8 FOR INFORMATION ONLY BASES APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 and during movement of fuel assemblies for Unit 1 provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,

b. Systems needed to mitigate a fuel handling accident involving irradiatedhandling fuel are available,

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations.

Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2.1, A.2.2, A.2.3, and A.2.4, and A.2.5 If two trains are required by LCO 3.8.10, "Distribution Systems -

Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive reactivity additions. By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of fuel assemblies, and operations involving positive reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive Beaver Valley Units 1 and 2 B 3.8.8 - 3 Revision 0

Distribution Systems - Shutdown B 3.8.10 FOR INFORMATION ONLY B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in SAFETY the UFSAR, Chapter 6 (Ref. 1) and Reference 2, assume Engineered ANALYSES Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6, and during movement of irradiated fuel assemblies or movement of fuel assemblies over irradiated fuel assemblies for Unit 1 or movement of recently irradiated fuel assemblies or movement of fuel assemblies over recently irradiated fuel assemblies for Unit 2 ensure that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident involving handling irradiated fuel (Unit 1). For Unit 2 only, due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />). In future discussions, the term fuel assemblies will include "irradiated" and "recently irradiated" as applicable for each unit.

The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

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Distribution Systems - Shutdown B 3.8.10 FOR INFORMATION ONLY BASES LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents involving irradiatedhandling fuel).

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,

b. Systems needed to mitigate a fuel handling accident involving irradiatedhandling fuel are available,

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

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Distribution Systems - Shutdown B 3.8.10 FOR INFORMATION ONLY BASES ACTIONS (continued)

A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5, and A.2.6 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.45 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.56 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

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Containment Penetrations B 3.9.3 FOR INFORMATION ONLY B 3.9 REFUELING OPERATIONS B 3.9.3 Containment PenetrationsDeleted BASES BACKGROUND During movement of fuel involving recently irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, restricting the release of radioactivity from containment is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained within the requirements of 10 CFR 50.67. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. During movement of fuel involving recently irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During movement of recently irradiated fuel assemblies or the movement of fuel assemblies over recently irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed.

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Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES BACKGROUND (continued)

The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted to within regulatory limits.

The Containment Purge and Exhaust System includes a 42 inch purge penetration and a 42 inch exhaust penetration. During MODES 1, 2, 3, and 4, the two valves in each of the purge and exhaust penetrations are secured in the closed position. The Containment Purge and Exhaust System is not subject to a Specification in MODE 5.

In MODE 6, the Containment Purge and Exhaust System is used for containment ventilation.

The radiation monitors associated with the Unit 1 Containment Purge and Exhaust System are not mounted in a seismically qualified ventilation duct. Therefore, Unit 1 can not credit containment isolation when necessary to mitigate the radiological consequences of a design bases fuel handling accident. Unit 1 must rely on filtration of the purge exhaust by an OPERABLE Supplemental Leak Collection and Release System (SLCRS) filter train.

The Unit 2 Containment Purge and Exhaust System credits containment isolation when necessary to mitigate the radiological consequences of a design bases fuel handling accident. The limit placed on the containment purge and exhaust flow (7500 cfm) ensures the Unit 2 purge and exhaust isolation valves close before any radioactivity is released from containment.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

Functionally equivalent isolation methods must be approved by an engineering evaluation and may include use of a material that can provide a temporary, atmospheric pressure, ventilation barrier for the other containment penetrations during recently irradiated fuel movements and the movement of fuel assemblies over recently irradiated fuel assemblies (Reference 1).

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Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES APPLICABLE During refueling operations, the postulated event that results in the most SAFETY severe radiological consequences is a fuel handling accident (Ref. 2).

ANALYSES The limiting fuel handling accident analyzed in Reference 2, includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decay time prior to moving irradiated fuel.

The applicable limits for offsite and control room dose from a fuel handling accident are specified in 10 CFR 50.67. Standard Review Plan, Section 15.0.1, Rev 0 (Ref. 3) provides an additional offsite dose criteria of 6.3 rem total effective dose equivalent (TEDE) for fuel handling accidents.

The water level requirements of LCO 3.9.6, "Refueling Cavity Water Level," in conjunction with a minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to irradiated fuel movement, ensure that the resulting offsite and control room dose from the limiting fuel handling accident is within the limits required by 10 CFR 50.67 and within the acceptance criteria of Reference 3 without the need for containment closure.

Therefore, the containment closure requirements of LCO 3.9.3, "Containment Penetrations," are only applicable during refueling operations involving recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />). Current requirements based on the decay time of the fuel prevent the movement of recently irradiated fuel. However, the requirements for containment closure are retained in the Technical Specifications in case these requirements are necessary to support fuel movement involving recently irradiated fuel consistent with the guidance of Reference 4.

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO limits the consequences of a fuel handling accident involving handling recently irradiated fuel in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and exhaust penetrations which may be open if the exhaust airflow is lined up to an OPERABLE SLCRS train (Unit 1) or capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System (Unit 2).

For Unit 2, an OPERABLE Containment Purge and Exhaust Isolation System includes purge and exhaust valves that isolate within the required time and a purge exhaust flow that is within the required limit. The Unit 2 Beaver Valley Units 1 and 2 B 3.9.3 - 3 Revision 0

Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES LCO (continued) purge and exhaust valve isolation time and purge exhaust flow requirements provide assurance that, in the event of a limiting fuel handling accident, the purge and exhaust penetrations will be isolated prior to the resulting radioactivity being released from containment.

For the OPERABLE containment purge and exhaust penetrations for Unit 2, this LCO ensures that these penetrations are isolable by the Containment Purge and Exhaust Isolation System and for Unit 1 that the purge exhaust is lined up to an OPERABLE SLCRS train when moving recently irradiated fuel and during movement of fuel assemblies over recently irradiated fuel assemblies. The OPERABILITY requirements for this LCO ensure that the Unit 2 automatic purge and exhaust valve closure times specified in the Licensing Requirements Manual (LRM) can be achieved and, therefore, meet the assumptions used in the safety analysis to ensure that releases through the valves are prevented, or for Unit 1, that the releases are filtered such that radiological doses are within the acceptance limit.

APPLICABILITY The containment penetration requirements are applicable during movement of recently irradiated fuel assemblies or the movement of fuel assemblies over recently irradiated fuel assemblies within containment because this is when there is a potential for the limiting fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1, "Containment Operability" and LCO 3.6.3, "Containment Isolation Valves." In MODES 5 and 6, when movement of irradiated fuel assemblies within containment is not being conducted, the potential for a fuel handling accident does not exist.

Additionally, due to radioactive decay, a fuel handling accident that does not involve recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) will result in doses that are well within the guideline values specified in 10 CFR 50.67 even without containment closure capability. Therefore, under these conditions no requirements are placed on containment penetration status.

Although movement of recently irradiated fuel is not currently permitted, the requirements for containment closure are retained in the Technical Specifications in case these requirements are necessary to support fuel movement involving recently irradiated fuel consistent with the guidance of Reference 4.

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Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES ACTIONS A.1 and A.2 If the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the Unit 2 Containment Purge and Exhaust Isolation System not capable of automatic actuation when the purge and exhaust valves are open or the Unit 1 purge exhaust not lined up to an OPERABLE SLCRS train, the unit must be placed in a condition where the isolation or filtration function is not needed. This is accomplished by immediately suspending movement of recently irradiated fuel assemblies and the movement of any fuel assemblies over recently irradiated fuel assemblies within containment.

Performance of these actions shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS The Surveillance requires that the Unit 2 containment purge exhaust flow rate be verified to be 7500 cfm. The Surveillance is necessary to verify the Containment Purge and Exhaust Isolation System is OPERABLE.

LCO 3.9.3.c.2 requires that the containment purge and exhaust penetrations are capable of being isolated by an OPERABLE Containment Purge and Exhaust Isolation System. Verifying the purge exhaust flow is within the limit provides assurance that, in the event of a limiting fuel handling accident, the purge and exhaust penetrations will be isolated prior to the resulting radioactivity being released from containment.

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

The Surveillance is modified by two Notes that specify the Surveillance is only applicable to Unit 2 and that the Surveillance is only required to be met when the containment purge and exhaust is operating in accordance with LCO 3.9.3.c.2. The Surveillance is only applicable to Unit 2 because Unit 1 does not credit purge and exhaust isolation and instead relies on filtration of the purge exhaust flow.

SR 3.9.3.2 This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open Unit 2 purge and exhaust valves will demonstrate that the Beaver Valley Units 1 and 2 B 3.9.3 - 5 Revision 29

Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued) valves are not blocked from closing and that each valve operator has motive power, which will ensure that each valve is capable of being closed by an OPERABLE automatic containment purge and exhaust isolation signal. The Surveillance on the open Unit 1 purge and exhaust valves will confirm that the purge exhaust is lined up to an OPERABLE SLCRS filtration train.

This Surveillance ensures that a postulated fuel handling accident involving handling recently irradiated fuel that releases fission product radioactivity within the containment will not result in a release of significant fission product radioactivity to the environment in excess of those recommended by Standard Review Plan Section 15.0.1 (Reference 3). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.3.3 This Surveillance demonstrates that each Unit 2 containment purge and exhaust valve actuates to its isolation position on manual initiation and on an actual or simulated high radiation signal. The Frequency maintains consistency with other similar ESFAS instrumentation and valve testing requirements that ensure the valves are capable of closing after a postulated fuel handling accident involving handling recently irradiated fuel to limit a release of fission product radioactivity from the containment.

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

The SR is modified by two Notes stating that this Surveillance is only applicable to Unit 2 and that this Surveillance is not required to be met for valves in isolated penetrations. The LCO provides the option to close penetrations in lieu of requiring automatic actuation capability. The Surveillance is not applicable to Unit 1 because Unit 1 does not credit purge and exhaust isolation and relies on filtration instead.

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Containment Penetrations B 3.9.3 FOR INFORMATION ONLY BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.3.4 The Surveillance requires that the Unit 2 containment purge and exhaust valve isolation time be verified within the limit. The required isolation time for the containment purge and exhaust valves is specified in the LRM.

The Surveillance is necessary to verify the Containment Purge and Exhaust Isolation System is OPERABLE. LCO 3.9.3.c.2 requires that the containment purge and exhaust penetrations are capable of being isolated by an OPERABLE Containment Purge and Exhaust Isolation System. Verifying the purge and exhaust valve isolation time is within the limit provides assurance that, in the event of a limiting fuel handling accident, the purge and exhaust penetrations will be isolated prior to the resulting radioactivity being released from containment.

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

The Surveillance is modified by two Notes that specify the Surveillance is only applicable to Unit 2 and that the Surveillance is only required to be met when the containment purge and exhaust is operating in accordance with LCO 3.9.3.c.2. The Surveillance is only applicable to Unit 2 because Unit 1 does not credit purge and exhaust isolation and instead relies on filtration of the purge exhaust flow.

REFERENCES 1. GPU Nuclear Safety Evaluation SE-0002000-001, Rev. 0, May 20, 1988.

2. UFSAR, Section 14.2.1 (Unit 1) and UFSAR, Section 15.7.4 (Unit 2).

3. NUREG-0800, Section 15.0.1, Rev. 0, July 2000.

4. NUREG-1431, "Standard Technical Specifications for Westinghouse Plants," Rev. 2, April 2001.

Beaver Valley Units 1 and 2 B 3.9.3 - 7 Revision 29

Decay Time FOR INFORMATION ONLY B 3.9.7 B 3.9 REFUELING OPERATIONS B 3.9.7 Decay Time BASES BACKGROUND The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay time is consistent with the assumptions used in the radiological accident analyses.

Also, in order to meet the thermal-hydraulic design calculation assumptions for the fuel storage pool, movement of irradiated fuel assemblies from the reactor vessel to the fuel pool requires a minimum subcritical decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. This requirement is based on cooling water inlet temperature to the fuel storage pool heat exchanger as described in a BVPS letter to the NRC (L-01-113), dated October 29, 2001. After 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, in order to maintain the fuel pool heat load within the assumptions of the analysis, irradiated fuel assembly movement from the vessel to the fuel pool is limited to a rate equivalent to six assemblies per hour.

APPLICABLE During refueling operations, the postulated event that results in the most SAFETY severe radiological consequences is a fuel handling accident (Reference ANALYSES 2). The limiting fuel handling accident analyzed in Reference 2, includes dropping a single irradiated fuel assembly and handling tool (conservatively estimated at 2500 pounds) directly onto another irradiated fuel assembly resulting in both assemblies being damaged. The analysis assumes a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decay time prior to moving irradiated fuel.

Decay Time satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The reactor is required to be subcritical for greater than or equal to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to ensure that the radiological consequences of a postulated fuel handling accident inside containment are within acceptable limits as provided by 10 CFR 100.

Beaver Valley Units 1 and 2 B 3.9.7 - 1 Revision

Refueling Cavity Water Level B 3.9.7 FOR INFORMATION ONLY BASES APPLICABILITY The decay time restriction is applicable only during movement of irradiated fuel within containment and during movement of fuel assemblies over irradiated fuel within containment following a reactor shutdown. Once this restriction is met following shutdown, any subsequent fuel movement will also meet the decay time restrictions. Thus, all subsequent movements involving irradiated fuel will meet the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> decay time limit and be consistent with the fuel handling accident assumptions.

ACTIONS A.1 With the reactor subcritical less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, all movement of irradiated fuel within containment and movement of fuel assemblies over irradiated fuel within containment must be suspended immediately. Fuel movement involving irradiated fuel within containment is prohibited during the first 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> following reactor shutdown since the plant is not analyzed for a fuel handling accident during this period.

Suspension of fuel movement shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.7.1 REQUIREMENTS Since movement of irradiated fuel within containment and movement of fuel assemblies over irradiated fuel within containment is prohibited during the first 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> following reactor shutdown, a verification of time subcritical must be made prior to movement of irradiated fuel within the reactor core. This is done by confirming the time and date of subcriticality, and verifying that at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> have elapsed. The Frequency of prior to movement of irradiated fuel in the reactor core ensures operation within the design basis assumption for decay time in the refueling accident analysis.

REFERENCES 1. Regulatory Guide 1.183, July 2000.

2. UFSAR, Section 14.2.1 (Unit 1).

3. UFSAR, Section 15.7.4 (Unit 2).

Beaver Valley Units 1 and 2 B 3.9.7 - 2 Revision