L-MT-05-081, License Amendment Request for Establishment of Emergency Service Water Technical Specification

License Amendment Request for Establishment of Emergency Service Water Technical Specification

ML052130205
Person / Time
Site:	Monticello
Issue date:	07/25/2005
From:	Conway J Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-05-081
Download: ML052130205 (30)

Text

SPA Monticello Nuclear Generating Plant NMC Operated by Nuclear Management Company, LLC Committed to Nuclear Excellence July 25, 2005 L-MT-05-081 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 License No. DPR-22 License Amendment Request for Establishment of Emerciency Service Water Technical Specification Pursuant to 10 CFR 50.90, the Nuclear Management Company, LLC (NMC) proposes to revise the Monticello Nuclear Generating Plant (MNGP) Technical Specifications (TS) to add an Emergency Service Water (ESW) System specification.

Adding an ESW System specification provides specific direction to the Operators for when an ESW subsystem is inoperable. No longer will it be necessary to enter Specification 3.5.A.4 (which requires the plant to be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) when Emergency Core Cooling Systems components are affected solely by an inoperable ESW subsystem. The proposed change is consistent with TS requirements for the ESW System for nuclear reactors licensed after MNGP. It will provide time to restore inoperable ESW components, consistent with the licensing basis, and avoid unnecessary plant shutdowns. provides the summary, description of the proposed change, system description and design, technical analysis, and the regulatory safety analysis and environmental consideration evaluations. Enclosure 2 provides a copy of TS sections 3.18 and 4.18, entitled, "Emergency Service Water System." Enclosure 3 provides the draft Bases forTS sections 3.18 and 4.18.

NMC requests approval of the proposed amendment by July 30, 2006, with an implementation period of 45 days following approval.

The MNGP Operations Committee has reviewed this application. A copy of this submittal, including the No Significant Hazards Consideration determination, is being forwarded to our appointed state official pursuant to 10 CFR 50.91 (b)(1).

This letter contains no new commitments and makes no revisions to existing commitments.

2807 West County Road 75

• Monticello, Minnesota 55362-9637 Telephone: 763.295.5151

• Fax: 763.295.1454

USNRC Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on

_1 _

o n T. Conway C

Site Vice President, Monticello ear Generating Plant Nuclear Management Company, LLC Enclosures (3) cc:

Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE 1 LICENSEE'S EVALUATION OF PROPOSED CHANGE Section No.

Title Page No.

1.0

SUMMARY

1

2.0 PROPOSED CHANGE

1 2.1 Addition of Specifications 3.18 /4.18 3

Emergency Service Water 2.2 Addition of Bases for Specifications 3.18 /4.18 4

Emergency Service Water 3.0 SYSTEM DESCRIPTION / DESIGN 5

4.0 TECHNICAL ANALYSIS

.6 4.1 General Safety Analysis 6

4.2 Discussion of Support System Operability 7

4.3 Discussion of the Basis for Not Including 8

Actions / Conditions in the ESW Specification for when the Reactor Water Temperature is Less than or Equal to 2120F 4.4 Safety Analysis for Each Specification Attribute 9

Summary 1 5 5.0 REGULATORY SAFETY ANALYSIS 16 5.1 No Significant Hazards Consideration 16 5.2 Applicable Regulatory Requirements/Criteria 18

6.0 ENVIRONMENTAL CONSIDERATION

19

7.0 REFERENCES

20 Page 1 of 1

ENCLOSURE I 1.0

SUMMARY

Pursuant to 10 CFR 50.90, the Nuclear Management Company, LLC (NMC) proposes to revise the Monticello Nuclear Generating Plant (MNGP) Technical Specifications to add an Emergency Service Water (ESW) System specification. The following changes are proposed:

1)

Add a new specification section 3.18 entitled, "Emergency Service Water System," to provide Limiting Conditions for Operation (LCO) and conditions and action statements for the system.

2)

Add corresponding Surveillance Requirements (SR) through the addition of specification section 4.18, entitled, "Emergency Service Water System."

3)

Provide corresponding changes to the Bases under Specification 6.8.K, "Technical Specifications (TS) Bases Control Program," upon approval of this license amendment. (Draft Bases changes are presented in Enclosure 3 for information.)

The new ESW System specification is based on plant-specific design considerations.

The MNGP 'custom' TS pre-date the development of the 'original' Standard Technical Specifications (STS) (Reference 1), i.e., NUREG-0123, but are similar to them in form, style and usage. Therefore, the original STS served as the primary basis in development of the new proposed specification. Also, the 'improved' STS, i.e.,

NUREG-1433 (Reference 2), was reviewed and considerations from it were applied in development of the proposed specification. This change is consistent; in as far as the MNGP custom TS construction conventions allow, with the June 29, 2005 (Reference 3), submittal for conversion to the improved STS.

2.0 PROPOSED CHANGE

Two Emergency Service Water Systems provide a safety-related source of cooling water for the removal of heat from equipment; i.e., the Emergency Diesel Generators (EDGs), Residual Heat Removal (RHR) and Core Spray (CS) pump motor thrust bearings, Emergency Core Cooling System (ECCS) room coolers, and the Control Room Ventilation air conditioning condensers, that are required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient.

These ESW Systems are support systems for several other systems as described herein. The MNGP custom TS do not currently include any separate specific requirements, i.e., LCOs, actions, and associated surveillance requirements for these ESW Systems. Operability of these ESW support systems is therefore addressed under the definition of operability in the TS as an implicit requirement for the operability of the systems they support. Operability is defined under Definition 1.0.L as:

Page 1 of 21

ENCLOSURE 1 "Operable - A system, subsystem, train, component or device shall be Operable or have Operability when it is capable of performing its specified function(s).

Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s). [emphasis added]

When a system, subsystem, train, component or device is determined to be inoperable soley [sic] because its emergency power source is inoperable, or soley [sic] because its normal power source is inoperable, it may be considered operable for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation provided: (1) its corresponding normal or emergency power source is operable: and (2) all of its redundant system(s), subsystem(s),

train(s), component(s), and device(s) are Operable, or likewise satisfy the requirements of this paragraph."

The two Emergency Service Water Systems are:

a.

Emergency Diesel Generator-Emergency Service Water (EDG-ESW)

The EDG-ESW System is a support system for only the EDGs; thus, when an EDG-ESW subsystem is inoperable, the associated EDG (the supported system) is declared inoperable and action is taken in accordance with Specification 3.9.B.3, "Auxiliary Electrical Systems - Standby Diesel Generators," consistent with the definition of operable. Specification 3.9.B.3.a.1) specifies a 7-day allowable out-of-service time (AOT) for one EDG being inoperable. A 7-day AOT was determined to be acceptable time period for an EDG to be out-of-service by the NRC during the licensing of MNGP.

Since the EDG-ESW System is a support system only for the EDGs, it is not described in the TS, and does not require its own specification.

b.

Emergency Service Water (ESW) System #

The ESW System is a support system for the Control Room Ventilation (CRV) air conditioning condensers and the ECCS. MNGP Specification 3.17.A, "Control Room Habitability - Control Room Ventilation System," provides the actions to be taken when a ventilation train(s) of the CRV System is inoperable. Specification 3.17.A.2.a specifies a 30-day AOT for a ventilation train. A 30-day AOT was determined to be acceptable time period for restoring an inoperable ventilation train by the NRC during the licensing of MNGP.

Also referred to at MNGP as the Emergency Filtration Train-Emergency Service Water (EFT-ESW) System.

Page 2 of 21

ENCLOSURE I The ESW System is also a support system for the ECCS. MNGP Specification 3.5.A.3, "Core and Containment Spray/Cooling Systems - ECCS Systems,"

provides AOTs for various combinations of inoperability of ECCS equipment, injection paths, and subsystems. When an ESW subsystem is inoperable, because there is no ESW System LCO to prescribe the proper action, the associated ECCS division; i.e., a Core Spray and the two RHR pumps, and associated ECCS room coolers; in accordance with the definition of operability are considered inoperable, and Specification 3.5.A.4 directs that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the reactor is to be placed in a condition in which the affected equipment is not required to be operable, requiring the plant to be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Therefore, an inoperable ESW subsystem (due to it being a support system to ECCS, without an LCO providing appropriate controls on ESW inoperability) results in a 24-hour shutdown of the unit. This constraint is overly restrictive, not in agreement with the plant design, and is inconsistent with the conditions applied to later licensed Boiling Water Reactor (BWR) plants. Both the STS and the improved STS (References 1 and 2) do not direct a plant shutdown under these conditions. Note, that without this proposed change the MNGP is at a substantial risk of a plant shutdown because if an ESW subsystem were to become inoperable, a 24-hour shutdown condition is imposed. However, the design of the plant and later operating requirements, as imposed in both the STS and ITS, provide a time period that has been determined acceptable for restoring an ESW subsystem to operable status. Adding an ESW System specification will provide specific direction to the Operators when a subsystem(s) of ESW is inoperable. It will no longer be necessary to enter Specification 3.5.A.4 when ECCS components are affected solely by an inoperable ESW subsystem. The implementation of this 7-day AOT for restoring an ESW subsystem is consistent with current industry standards.

NMC proposes to revise the MNGP TS to add a specification only for the ESW System.

This new specification will be referred to as the "Emergency Service Water System."

This specification will provide the appropriate controls for the ESW System in accordance with current industry practice.

2.1 Addition of Specifications 3.18 / 4.18 - Emergency Service Water NMC proposes to add new Specifications 3.18 /4.18, entitled, "Emergency Service Water System." These specifications will provide the Applicability, Objective, LCOs, action statements, and Surveillance Requirements for the system. A discussion of each specification requirement / attribute is provided in Section 4.0 of this letter. Specification 3.18 reads:

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ENCLOSURE I "3.18 EMERGENCYSERVICE WATER ApplicabiliEv Applies to the operating status of the Emergency Service Water System.

Obiective:

To provide a water supply for the ECCS System room coolers and the ECCS pump motors as well as the control room air conditioning units.

Specification:

A. Emergency Service Water (ESW) System

1. Except as specified in 3.18.A.2, both subsystems of the ESW System shall be operable, whenever irradiated fuel is in the reactor vessel and reactor water temperature is greater than 212"F.

2. One ESW subsystem may be inoperable for 7 days, provided the ECCS components supplied cooling water by the redundant ESW subsystem are operable.

3. If Specifications 3.18.A. I or 3.18.A.2 cannot be met, an orderly shutdown of the reactor will be initiated and the reactor water temperature shall be reduced to less than 212"F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Specification 4.18, providing the proposed surveillance requirements will read:

4.18 EMERGENCY SERVICE WATER Applicability:

Applies to the periodic testing requirements for the Emergency Service Water System.

Objective:

To verify the operability of the Emergency Service Water (ESW) System.

Specification:

A. The operability of the Emergency Service Water System shall be verified by performance of the following tests:

1. Monthly verify each ESW subsystem manual and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

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ENCLOSURE I Note: Isolation of flow to individual components does not render the ESW system/subsystem inoperable.

2. Each operating cycle verify each ESWsubsystem actuates on an actual or simulated initiation signal.

2.2 Addition of Bases for Specifications 3.18 14.18 - Emergency Service Water provides draft corresponding changes to the TS Bases for the new ESW specification prepared in accordance with Specification 6.8.K, "Technical Specifications (TS) Bases Control Program." Upon approval of this license amendment the proposed changes will be implemented in accordance with this program.

3.0 SYSTEM DESCRIPTION / DESIGN Two MNGP ESW Systems remove the heat rejected by equipment that must operate under accident conditions. One supplies the EDGs; the other system supplies the remaining ESW loads. The systems are:

1.

The Emergency Diesel Generator-Emergency Service Water (EDG-ESW)

System consists of two pumps that provide cooling water to the EDGs. Each of the pumps is in a separate subsystem supplying one EDG.

Note: The EDG-ESW System is mentioned only for completeness. Because it is a support system for only the EDGs, no specification is required.

2.

Emergency Service Water (ESW) System consists of two pumps, each in a separate subsystem, that provide cooling water to a division of ECCS pumps electric motors and the ECCS room coolers during accident situations. This system also supplies cooling water to the Control Room Ventilation air conditioning system.

The ESW System is designed to provide cooling water for removal of heat from the following equipment required for safe shutdown following a DBA or transient.

2 - Core Spray (CS) Pump motor thrust bearings, 2 - Residual Heat Removal (RHR) Pump motor thrust bearings*

• Two of the four RHR pump motors (P-202A and B), one in each ECCS division, have been replaced with models that do not require cooling water.

2 - RHR Pump room coolers, 2 - High Pressure Coolant Injection (HPCI) room coolers**, and

• • Each ESW subsystem supplies a separate HPCI room cooler.

Page 5of21

ENCLOSURE I 2 - Control Room Ventilation (CRV) air conditioning condensers.

The ESW System provides cooling to the condensers of the Control Room air conditioning units upon a loss of offsite power. The ESW pump in each subsystem automatically starts upon receipt of an EDG breaker closure or a 4.16 kV essential bus transfer to the alternate offsite power source.

The ESW System consists of two independent and redundant subsystems. Each of the two ESW subsystems is made up of a header, two 200 gpm pumps, a suction source, valves, piping and associated instrumentation. The two ESW subsystems are separated from each other so failure of one subsystem will not affect the operability of the other subsystem. Either of the two subsystems is capable of providing the required cooling capacity to support the systems assumed in the safety analysis. Since only essential loads are supplied from the ESW subsystems, and check valves prevent ESW flow diversion to the normal Service Water System, no automatic cooling load shed or system isolation is required.

Cooling water is pumped from the Mississippi River by the ESW pumps to essential components through the two main headers. After removing heat from the components, the water is discharged by the Circulating Water System discharge line.

4.0 TECHNICAL ANALYSIS

4.1 General Safety Analysis The Mississippi River is the ultimate heat sink for the MNGP. The Mississippi River supplies sufficient water inventory for the ESW System post-accident cooling requirements. Two 100-percent capacity ESW pump subsystems provide emergency cooling to the emergency loads previously discussed. The ESW pumps are credited in the Updated Final Safety Analysis Report (USAR) accident analyses for providing cooling to ECCS equipment utilized to respond to loss-of-coolant accidents (LOCAs) and are needed for loss of offsite power events. These analyses also include the evaluation of the long-term primary containment response after a design basis LOCA.

The non-safety grade Service Water is the normal source of cooling water to components.

The ability to provide onsite emergency AC power is independent of the availability of the ESW System, since the EDGs are supplied by the independent EDG-ESW subsystem. The ESW System design provides long-term cooling capability to two of the four RHR System pumps, both of the Core Spray System pumps, and the HPCI and the RHR pump room coolers. Long-term cooling of the Control Room is also provided by the ESW System.

Page 6 of 21

ENCLOSURE 1 4.2 Discussion of Support System Operability The MNGP custom TS do not provide direction regarding support system inoperability impacts on the supported system(s). It has been the practice within the industry and at MNGP to enter only the most directly applicable action statement for an inoperable system, structure, or component. For support systems not in TS (e.g., ventilation systems) this typically means entering the supported systems action statement.

However, when the support system is in TS (e.g., the EDG, ECCS instruments, etc.)

only the directly applicable support system TS is entered and not the TS for the supported system. This is a position that the NRC has accepted as discussed below.

Some confusion has existed between the industry and the NRC over the intent and interpretation of combined support / supported inoperability over the years. (See NRC memorandum from B. K. Grimes to S. E. Bryan dated June 13, 1979, Generic Letter 80-30, and Generic Letter 91-18; References 4, 5, and 6; respectively.) As described in licensee submittals and NRC Safety Evaluations for conversions to the improved STS, there was an inconsistent and ambiguous approach with respect to combined support I supported system inoperability. The improved STS addresses this situation by adding LCO 3.0.6 and the Safety Function Determination Program (SFDP) to clarify and provide consistency across the industry regarding the appropriate actions to take when a single inoperability in a support system (an ESW subsystem in this case) also results in the inoperability of one or more related systems (supported system(s), in this case ECCS components and subsystems supported by the inoperable ESW subsystem(s)).

The MNGP custom TS and the original STS do not include program requirements for a SFDP. The concept of the SFDP was met, prior to development of the ITS by 'pointer' specifications which directed the actions (or verified conditions) in other specifications as required. Implicit in these actions were cross train checks of support components, in accordance with the definition of operability, to ensure a loss of safety function assumed in the accident analysis did not go undetected without the proper actions being taken in accordance with the LCO for the lost safety function. ITS LCO 3.0.6 and the SFDP codify and formalize this process. ITS LCO 3.0.6 and the SFDP also clarify a point of ambiguity prior to the formalization under ITS by having LCO 3.0.6 clearly state that

'When a supported svstem LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered." [emphasis added]

Page 7 of 21

ENCLOSURE I The present custom TS and original STS, defines the actions required to be taken as a result of the inoperability of a support system. The NRC in their Safety Evaluations for conversions to the improved STS indicate that licensee TS that pre-date the conversion do not contain differing positions with respect to the inoperability of systems and support systems. As an example, the NRC SE (Reference 7) for the D.C. Cook conversion to the improved STS in "Table A - Administrative Changes, ITS Section 3.0 - LCO and SR Applicability," state that Revision 2 of the ITS "was developed with Industry input and approval of the NRC to include LCO 3.0.6 and a new program, Specification 5.5.13, "Safety Function Determination Program (SFDP). This change is administrative since its function is to clarify existing ambiguities and to maintain actions that are equivalent.

[emphasis added] This change is administrative because it does not technically change the CTSs."

Therefore, by including the proposed ESW System specification in the MNGP TS, it will no longer be necessary to enter the ECCS specification (Specification 3.5.A.4) when the sole reason for entry was caused by ESW component inoperability. The converse is also true (as described in Section 4.3 below). When conditions are present that are not directly within the applicability of the ESW System specification (i.e., when reactor water temperature is less than or equal to 2120F) the supported systems specifications (i.e., in this case, the ECCS and Control Room Ventilation System specifications) actions apply in accordance with the definition of Operability.

4.3 Discussion of the Basis for Not Including Actions / Conditions in the ESW Specification for When the Reactor Water Temperature is Less Than or Equal to 2120F Volume S2, UBWR/4 STS - Updated Comparison" document (Reference 8) explains the basis for the transfer and disposition of TS requirements from the original STS to the improved STS. The updated comparison document provides the rationale for why there are no ESW System specification requirements in the improved STS low Modes* of operation (generally corresponds to the condition at MNGP where the reactor water temperature is less than or equal to 2120F).

DOC A.1 for the improved STS specification corresponding to the MNGP ESW specification (i.e., Specification 3.7.1.2, the Plant Service Water Specification) states:

'The explicit requirements for OPERABILITY of this [ESW] system in the non-operating MODES (i.e., MODES 4, 5, and any special conditions such as when handling irradiated fuel in the primary or secondary containment) have been removed. Since this system is a support system for other required equipment, and this other equipment has explicit Specifications, the definition of OPERABILITY will provide sufficient requirements to assure the [ESW] system can perform its required support function. The system design and system Operational Conditions 4, 5, and when handling irradiated fuel in the secondary containment.

Page 8 of 21

ENCLOSURE 1 operation for the support systems are also described in the FSAR [Final Safety Analysis Report]. Changes to the FSAR and implementing procedures are controlled under the provisions of 10 CFR 50.59. Because the STS ACTIONS simply repeat the essence of the definition of OPERABILITY as applicable to these support systems, this change is considered administrative....

Historically, the PWR Technical Specifications have not contained LCOs on service water systems for the shutdown MODES (while they do have LCOs for the operating MODES). In an effort for consistency in approach, the NRC agreed to remove the BWR LCOs for service water, allowing the definition of OPERABILITY to suffice."

Therefore, the proposed MNGP ESW System specification does not specify actions for conditions where the reactor water temperature is less than or equal to 2120F. This is consistent with the improved STS (Reference 2) and consistent with the MNGP improved STS submittal (Reference 3).

4.4 Safety Analysis for Each Specification Attribute The ESW System satisfies Criterion 3 of the NRC Policy Statement for inclusion in technical specifications. As such, a new plant undergoing initial licensing would be required to propose a specification for the ESW System. The new ESW System specification is based on the present MNGP plant design. The MNGP TS pre-date the development of the original STS, but are similar to them in form, style and usage.

Industry and NRC accepted usage has resulted in the STS (and before them, the custom TS) directing any necessary required actions from the most applicable specification, i.e., one that most directly pertains to the equipment in question, via

'pointer' references to other specifications where necessary within the original STS.

The ITS handles this situation by different means. Therefore, the original STS served as the primary basis in development of the ESW specification as it was most similar to the existing MNGP TS. However, considerations from ITS were applied, particularly with regard to loss of safety function considerations, and wording of surveillance requirements. The rationale and safety assessment for each new specification attribute-requirement is provided below.

a.

Applicability (3.18)

"Applies to the operating status of the Emergency Service Water System."

The Applicability indicates that this specification is concerned with the operating status of the ESW System.

b.

Obiective (3.18)

"To provide a water supply for the ECCS System room coolers and the ECCS pump motors as well as the control room air conditioning units. "

Page 9 of 21

ENCLOSURE I Explains the design objective for the ESW System to be a safety-related source of water to the ECCS room coolers and the ECCS pump motors as well as the Control Room air conditioning units.

c.

Specification 3.18.A.1 "Except as specified in 3.18.A.2, both subsystems of the ESW System shall be operable, whenever irradiated fuel is in the reactor vessel and reactor water temperature is greater than 212°F."

The ESW System is required to be operable whenever irradiated fuel is in the reactor vessel and reactor water temperature is greater than 21 20F. There are two independent, completely redundant ESW subsystems.

Each ESW subsystem consists of a piping system with separate controls and power supplies. In the event of a DBA, one ESW subsystem is required to operate to provide the minimum heat removal capability assumed in the safety analysis for the systems to which it supplies cooling water (i.e., ECCS room coolers and the ECCS pump motors as well as the Control Room air conditioning units). Therefore, to accommodate a single failure both ESW subsystems are required to be operable in accordance with this specification. This ensures that at least one ESW subsystem will operate, if the worst single failure occurs coincident with a loss of offsite power.

d.

Specification 3.18.A.2 "One ESW subsystem may be inoperable for 7 days, provided the ECCS components supplied cooling water by the redundant ESW subsystem are operable."

Specification 3.18.A.2 provides two limitations on ESW subsystem inoperability.

First, inoperability of a subsystem is limited to 7 days. Second, the division of ECCS components supplied by the operable ESW subsystem, must be operable.

These two limitations are discussed separately below.

1. Limited Duration for ESW Subsystem Inoperability This specification provides the allowance for an ESW subsystem to be out-of-service for a limited period. This action specifies that with one ESW subsystem inoperable, the inoperable subsystem is required to be restored to operable status within 7 days. With the unit in this condition, the capability of the operable ESW subsystem is adequate to perform the heat removal function for the supported division of ECCS components and associated room coolers (also the Control Room air conditioning units). Overall reliability is reduced, however, because a single failure in the remaining operable ESW subsystem could result in loss of the heat removal function, preventing the supported ECCS components and associated room coolers from performing Page 10 of 21

ENCLOSURE I their safety functions. However, additional single failures are not postulated during time periods in an action statement.

The determination of an AOT for a support system is based upon the assumptions in the accident analyses in concert with the AOTs for the supported systems. Specification 3.1 7.A.2.A for the Control Room Ventilation System states: "With one control room ventilation train inoperable, restore the inoperable train to operable status within 30 days." One train of the Control Room Ventilation System (an ESW supported system) may therefore be inoperable for any reason, including a loss of ESW to the air conditioning condensers for 30 days. Therefore, a 7-day AOT for an ESW subsystem out-of-service would be more limiting than the 30-day AOT for an affected train of the Control Room Ventilation System.

The 7-day AOT for an ESW subsystem is based on the results of the USAR accident analyses, where the worst single failure postulated involves, a loss of off-site power and an inoperable EDG, resulting in a loss of power to one division of ECCS, rendering that division; i.e., a Core Spray and the two RHR pumps, and the associated ECCS room coolers; inoperable, and unavailable for accident mitigation. HPCI space cooling would still be available since each HPCI room cooler is supplied by a separate ESW subsystem. Note, that in the event that off-site power was not lost during the accident, normal plant service water would remain in operation to supply the ESW loads.

Therefore, the safety-related source of power, assuming a loss of off-site power, for accident mitigation purposes for each ESW subsystem is an EDG.

The time requirement for restoring an inoperable EDG is specified in the current TS for the EDGs as 7 days. Therefore, a 7-day AOT for the ESW subsystem was chosen based on the redundant ESW cooling water supply capabilities afforded by the operable ESW subsystem, the low probability of an accident occurring during this time period, and the time allowed (7 days) for restoring an inoperable EDG (the emergency power supply to the ESW pumps).

The MNGP ESW System design consists of two, 100 percent capacity, independent ESW subsystems each containing a single ESW pump.

The STS and ITS specifications both assume the ESW System design consists of two independent ESW subsystems each containing two ESW pumps in parallel (References 1, 2 and 8). Both the. STS and ITS specify an AOT of 30-days with one ESW pump inoperable, 7-days with an ESW pump in each subsystem inoperable, and 72-hours with one subsystem inoperable (i.e., constrained by the 72-hour AOT assumed for an inoperable EDG).

Note, that for both the STS and ITS assumed ESW System design, the inoperability of one EDG results in the inoperability of both ESW pumps (i.e.,

one entire ESW subsystem becomes inoperable).

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ENCLOSURE 1 The AOT for a loss of one ESW subsystem corresponds to this limiting AOT, which is for an EDG out-of-service. Therefore, for both the STS and ITS, the 72-hour basis assumed for the loss of an EDG, is also applied to an inoperable ESW subsystem. The NRC approved AOT for an EDG being inoperable at MNGP TS is 7-days. The AOT assumed for the loss of one ESW subsystem at MNGP is consistent with the AOT for its limiting support system, the EDG. Therefore, a 7-day AOT for the inoperability of one ESW subsystem at MNGP is appropriate. Note that other plants of similar design and vintage to MNGP have the same 7-day AOT for an inoperable EDG, e.g.,

Peach Bottom (Reference 9).

2. Limited by the Operability of the Associated ECCS Components A verification step has been added to the standard wording of Specification 3.18.A.2 saying:

"One ESW subsystem maybe inoperable for 7 days, provided the ECCS components supplied cooling water by the redundant ESW subsystem are operable." [emphasis added]

ITS LCO 3.0.6 requires a Safety Function Determination Program (SFDP).

This program ensures a loss of safety function is detected and appropriate actions taken. An evaluation is performed to determine if a loss of safety function exists. Additionally, other appropriate actions are taken as a result of support system inoperability with the corresponding exceptions to entering supported system required conditions and actions. The MNGP custom TS do not include the program requirements for a SFDP. The concept of the SFDP was met, prior to development of the ITS (i.e., within the STS) by 'pointer' specifications directing actions (or verifying conditions) in other specifications as required. What must be verified as not occurring is a loss of safety function, resulting when one or more ECCS component(s) (i.e., an RHR or Core Spray pump or ECCS room coolers) are out-of-service, AND the ESW subsystem supplying the other division of ECCS components is also out-of-service. A cross train check of ECCS is required to ensure that the loss of the capability to perform the safety function assumed in the accident analysis does not go undetected.

Therefore, this limitation requiring the operators to verify that the "ECCS components supplied cooling water by the redundant ESW subsystem are operable' assures that the TS required ECCS components (the other ECCS division) supplied cooling water by the redundant ESW subsystem are operable. Providing a conditional 'pointer' specification step has been common practice in both the custom TS and in the original STS. Finally, this limitation contains the applicable requirements of the improved STS SFDP by:

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ENCLOSURE I

• Providing for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected, Ensuring the plant is maintained in a safe condition if a loss of function condition exists, and Providing other appropriate limitations and remedial or compensatory actions.

e.

Specification 3.18.A.3 "If Specifications 3.18.A. I or 3.18.A.2 cannot be met, an orderly shutdown of the reactor will be initiated and the reactor water temperature shall be reduced to less than 212"F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

When both ESW subsystems are inoperable, a loss of heat removal capability has occurred for both divisions of ECCS, resulting in a complete loss of a safety function. Therefore, shutting down the unit in accordance with this specification is required.

The wording of this action and the time period for performance are the same as in the current MNGP TS for the most limiting supported system, the ECCS (see specification action 3.5.A.4).

f.

Applicability (4.18)

'Applies to the periodic testing requirements for the Emergency Service Water System."

The Applicability indicates that this specification is concerned with periodic testing requirements for the ESW System.

g.

Obiective (4.18)

"To verify the operability of the Emergency Service Water (ESL49 System."

The surveillance requirements verify the operability of the ESW System.

h.

Specification 4.18.A.1 "The operability of the Emergency Service Water System shall be verified by performance of the following tests:

Monthly verify each ESW subsystem manual and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

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ENCLOSURE I Note: Isolation of flow to individual components does not render the ESW system/subsystem inoperable."

Verifying the correct alignment for each manual and automatic valve in each ESW subsystem flow path provides assurance that the proper flow paths will exist for ESW System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, searing, or securing. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This SR is modified by a Note clarifying that isolation of the ESW System to supplied components or systems may render them, but does not affect the operability of the ESW System (or subsystems).

The monthly frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. This SR is the same as the ITS SR, which is consistent with the former STS SR for the GE BWR/4 design.

i.

Specification 4.18.A.2 "The operability of the Emergency Service Water System shall be verified by performance of the following tests:

Each operating cycle verify each ESW subsystem actuates on an actual or simulated initiation signal."

This SR verifies the automatic start capability of the ESW pump in each subsystem. This is demonstrated by the use of an actual or simulated initiation signal. A once per operating cycle frequency is based on the similar TS contained in both the STS and ITS for this function. This surveillance is currently performed as part of the integrated ECCS test already performed on a cyclic basis. Operating experience has shown that these components usually pass the SR when performed at this frequency. Therefore, the frequency is concluded to be acceptable from a reliability standpoint.

This SR is the same as the ITS SR, which is consistent with the former STS SR for the GE BWR/4 design.

Page 14 of 21

ENCLOSURE I Summary An inoperable ESW subsystem (due to it being a support system to ECCS) without an LCO to provide appropriate controls on ESW subsystem(s) inoperability results in a 24-hour shutdown of the unit. This constraint is overly restrictive, not in agreement with the plant design, and is inconsistent with the conditions applied to later licensed BWR plants. Both the STS and the improved STS do not direct a plant shutdown under these conditions.

Adding an ESW System specification will provide specific direction to the operators for when an ESW subsystem is inoperable. No longer will it be necessary to enter Specification 3.5.A.4 (which requires the plant to be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) when ECCS components are affected solely by an inoperable ESW subsystem.

The safety assessment for the inclusion of the ESW System specification and the allowed out-of-service time is based upon similar specifications and industry experience. It demonstrates that operation with an ESW subsystem inoperable for a limited time period is acceptable. The proposed change is consistent with the TS requirements for the ESW System for nuclear reactors licensed after MNGP. Also, this proposed change provides time for restoration of inoperable ESW components, consistent with the plant licensing basis, and enhances plant safety by avoiding potential transients and unnecessary unit shutdowns. Therefore, this proposed change is acceptable.

Page 15 of 21

ENCLOSURE I 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration A license amendment is proposed to change the Technical Specifications to add a specification for the Emergency Service Water System.

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

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The Emergency Service Water (ESW) System is not an accident initiator. The proposed change provides operability requirements and surveillance requirements to ensure the ESW System is operable as required for accident mitigation. The proposed operability requirements and allowed outage time is consistent with the requirements for the systems supported by the ESW System.

The dose to the public and the Control Room operators are unaffected by the proposed change. The proposed LCO provides direction with respect to actions to be taken when support systems are inoperable.

The proposed Technical Specification does not introduce new equipment operating modes, nor does the proposed change alter existing system relationships. The proposed amendment does not introduce new failure modes.

Therefore, the proposed amendment will not significantly increase the probability or the consequences of an accident previously evaluated.

2.

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

Response: No.

The proposed changes do not introduce new equipment operating modes, nor do they alter existing system relationships. The proposed changes do not introduce new failure modes. They do not alter the equipment required for accident mitigation and they appropriately consider the effects on supported systems when a support system is inoperable. When support systems are inoperable, actions are specified consistent with safe plant operation.

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

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ENCLOSURE I

3.

Does the proposed change involve a significant reduction in the margin of safety?

Response: No.

The proposed change provides specifications for the ESW System that are consistent with current Technical Specification requirements for other equipment.

The proposed changes ensure that the ESW and other support systems will be available when required and provides adequate alternative actions when the support systems are not available. The allowed outage times for the ESW subsystem is consistent with that allowed for other equipment required for accident mitigation. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above, NMC has determined that operation of the facility in accordance with the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that they: (1) do not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) do not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) do not involve a significant reduction in a margin of safety.

Page 17 of 21

ENCLOSURE I 5.2 Applicable Regulatory RequirementslCriteria This section describes how the proposed changes and NMC's technical analyses satisfy applicable regulatory requirements and acceptance criteria. MNGP was constructed before the General Design Criteria (GDC) of 10 CFR 50 was promulgated. However, the concept(s) expressed by the GDC(s) below are applicable.

GDC 44 - Cooling Water, specifies that a system to transfer the heat from structures, systems, and components (SSCs) important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these SSCs under normal operating and accident conditions. The ESW System satisfies this criterion for the safety related systems that is supports.

The two independent ESW subsystems provide suitable redundancy in components and features, and suitable interconnections, and isolation capabilities to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

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.

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ENCLOSURE I

6.0 ENVIRONMENTAL CONSIDERATION

NMC has evaluated the proposed changes against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21, "Criteria for identification of licensing and regulatory actions requiring environmental assessments." NMC has determined that the proposed changes meet the criteria for a categorical exclusion as set forth in 10 CFR 51.22(c)(9), and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b), "Issuance of amendment." This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or that changes an inspection or surveillance requirement, and the amendment does not result in the following:

(i)

A significant hazards consideration, The proposed amendment does not involve a significant hazard. See the no significant hazards consideration determination evaluation.

(ii)

A significant change in the type or significant increase in the amounts of any effluent that may be released offsite, or The proposed amendment is consistent with and does not change the design basis of the plant. The proposed amendment will not result in an increase in power level, will not increase the production of radioactive waste and byproducts, and will not alter the flow path or method of disposal of radioactive waste or byproducts. Therefore, the proposed amendment does not involve any change in the type or amount of any effluent that may be released offsite.

(iii)

A significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not result in changes in the level of control or methodology used for processing radioactive effluents or handling of solid radioactive waste. There will be no change to the normal radiation levels within the plant. Therefore, the amendment does not involve an increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.52(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment is not required.

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ENCLOSURE I

7.0 REFERENCES

1.

NUREG-0123, Revision 3, "Standard Technical Specifications, for General Electric Boiling Water Reactors (BWR/5)," Revision Issued Fall 1980, Supercedes NUREG-0123, Rev. 2.

2.

NUREG-1433, Revision 3, "Standard Technical Specifications, General Electric Plants, BWR/4."

3.

Letter from NMC to NRC, "License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS),"

(L-MT-05-072), dated June 29, 2005.

4.

NRC Internal Memorandum from Brian K. Grimes (Assistant Director for Engineering and Projects) to Samuel E. Bryan (Assistant Director for Field Coordination) dated June 13, 1979.

5.

U.S. NRC Generic Letter 80-30, described as "Clarification of the Term "Operable" as It Applies to Single Failure Criterion for Safety Systems Required by TS," dated April 10,1980.

6.

U.S. NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," and Revision 1 issued 1997.

7.

U.S. NRC Safety Evaluation for Amendment No. 287 to Facility Operating License No. DPR-58; and Amendment No. 269 to Facility Operating License No.

DPR-74; for the Donald C. Cook Nuclear Plant, Units 1 and 2, "D.C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments for the Conversion to the Improved Technical Specifications with Beyond Scope Issues," (TAC Nos.

MC2629, MC2630, MC2653 through MC2687, MC2690 through MC2695, MC3152 through MC3157, MC3432 through MC3453), dated June 1, 2005.

8.

Letter OG94-730-32A transmitting uUpdated Tech. Spec. Comparison Documents," to the BWR Owners' Group Technical Specifications Committee -

A, dated October 5,1994. Document entitled, BWR Owners' Group, "Improved BWR Technical Specifications," dated September 1994, Volume S2, BWR/4, Standard Technical Specifications - Updated Comparison. (Updated Comparison Document, Discussion of Change from STS Draft Rev. 4 to ITS Rev. 1).

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7.0 REFERENCES

9.

U.S. NRC Safety Evaluation for Amendment Nos. 231 and 236 to Facility Operating Licenses DPR-44 and DPR-56, for the PECO Energy Company, "Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 - Issuance of Amendment RE: One-Time Extension to the Completion Time for One Emergency Service Water ESW Subsystem Inoperable from 7 to 14 Days," (TAC Nos. MA8320 and MA8322), dated April 25, 2000.

Page 21 of 21

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES This enclosure consists of the proposed Technical Specification page(s). The page(s) included in this enclosure are listed below:

Specification Paragraph No. (Title if Applicable)

Page(s)

Specifications EMERGENCY SERVICE WATER 229aa 3.18 and 4.18 (entire specification)

Page 1 of 1

3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS 3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS

.9.

3.18 EMERGENCY SERVICE WATER 4.18 EMERGENCY SERVICE WATER Applicability:

Applies to the operating status of the Emergency Service Water System.

Obiective:

To provide a water supply for the ECCS System room coolers and the ECCS pump motors as well as the control room air conditioning units.

Soecification:

A. Emergency Service Water (ESW) System

1. Except as specified in 3.18.A.2, both subsystems of the ESW System shall be operable, whenever irradiated fuel is in the reactor vessel and reactor water temperature is greater than 212 0F.

2. One ESW subsystem may be inoperable for 7 days, provided the ECCS components supplied cooling water by the redundant ESW subsystem are operable.

3. If Specifications 3.18.A.1 or3.18.A.2 cannot be met, an orderly shutdown of the reactor will be initiated and the reactor water temperature shall be reduced to less than 2120F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.18/4.18 Applicability:

Applies to the periodic testing requirements for the Emergency Service Water System.

Obiective:

To verify the operability of the Emergency Service Water (ESW) System.

Specification:

A. The operability of the Emergency Service Water System shall be verified by performance of the following tests:

1. Monthly verify each ESW subsystem manual and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Note: Isolation of flow to individual components does not render the ESW system/subsystem inoperable.

2. Each operating cycle verify each ESW subsystem actuates on an actual or simulated initiation signal.

229aa Amendment No.

ENCLOSURE 3 PROPOSED TECHNICAL BASES CHANGES This enclosure consists of the revised Technical Specification Bases page(s) that incorporate the proposed change(s). The page(s) included in this enclosure are listed below:

Specification Paragraph No. (Title if Applicable)

Page(s)

Bases for Specifications 3.18 and 4.18 EMERGENCY SERVICE WATER (entire specification) 229ab through 229ad

Bases 3.18 The ESW (EFT-ESW) System is designed to provide cooling water for removing heat from the Control Room Ventilation (CRV) air conditioning condensers, Residual Heat Removal (RHR) Pump and room coolers, High Pressure Coolant Injection (HPCI) room coolers, and the Core Spray (CS) Pump motors. These components are designed to provide cooling for a safe reactor shutdown following a Design Basis Accident (DBA) or transient. The components cooled by ESW System are supplied from the normal Service Water System during plant operation, as required. The ESW pump in each subsystem automatically starts upon receipt of an Emergency Diesel Generator (EDG) breaker closure or a 4.16 kV essential bus transfer to the alternate offsite power source (Transformer 1AR). Since only essential loads are supplied from the ESW System and check valves prevent ESW flow diversion to the normal Service Water System, no automatic cooling load shed or system isolation is required.

The ESW System consists of two independent and redundant subsystems. Each of the two ESW subsystems is made up of a header, a 200 gpm pump, a suction source, valves, piping and associated instrumentation. The two ESW subsystems are separated from each other so failure of one subsystem will not affect the operability of the other.

Cooling water is pumped from the Mississippi River by the ESW pumps to the essential components through the two main headers. After removing heat from the components, the water is discharged to the discharge canal through the Circulating Water System. A description of the ESW System is included in the Monticello USAR, Chapter 10.

The Mississippi River is the ultimate heat sink (UHS) that supplies sufficient water inventory for all ESW System post-accident cooling requirements. The ability of the ESW System to support long-term cooling of the reactor containment is assumed in evaluations of the equipment required for safe reactor shutdown presented in the USAR, Chapter 14. These analyses include the evaluation of the long-term primary containment response after a design basis LOCA.

The ability of the ESW System to provide adequate cooling to the identified safety equipment is an implicit assumption for the safety analyses evaluated in the USAR.

The long-term cooling capability of the ECCS components assumed in the accident analyses is provided by the ESW System.

Long-term cooling of the Control Room is also provided by the ESW System.

The ESW System is required to be operable to support operability of the equipment serviced by the ESW System in the specified conditions (i.e., whenever irradiated fuel is in the vessel and reactor water temperature is greater than 212 0F). In other conditions (i.e., below 212'F, or during operations with the potential for draining the reactor vessel, or during movement of irradiated fuel in the secondary containment, or during core alterations) the operability requirements of the ESW System are determined by the systems it supports, because the ESW System specification is not applicable.

3.18/4.18 229ab Amendment No.

Specification 3.18.A.1: The ESW subsystems are independent of each other to the degree that each has separate controls, power supplies, and the operation of one does not depend on the other. In the event of a DBA, one subsystem of ESW is required to provide the minimum heat removal capability assumed in the safety analysis for the systems to which it supplies cooling water. To ensure this requirement is met, two subsystems of ESW must be operable. At least one subsystem will operate, if the worst single active failure occurs coincident with the loss of offsite power.

A subsystem is considered operable when it has an operable ultimate heat sink, an operable pump, and an operable flow path capable of taking suction from the intake structure and transferring the water to the appropriate equipment.

The isolation of the ESW System to components or systems may render those components or systems inoperable, but does not affect the operability of the ESW System.

Specification 3.18.A.2: With one ESW subsystem inoperable, the inoperable subsystem must be restored to operable status within 7 days. With the unit in this condition, the remaining operable ESW subsystem is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the operable ESW subsystem could result in loss of ESW function. The 7 day allowed outage time is based on the redundant ESW System capabilities afforded by the operable division, the low probability of an accident occurring during this time period, and is consistent with the allowed completion time for restoring an inoperable EDG (the power supply to the ESW Pumps and equipment supplied by ESW).

With one ESW subsystem are inoperable, it is required to verify that all ECCS equipment supported by the redundant ESW subsystem is operable. This 'cross train check' is required whenever an ESW subsystem is out-of-service in accordance with this specification to immediately, identify, minimize and take appropriate action if a loss of safety function is identified. If a loss of safety function were identified, i.e., both divisions of an ECCS component(s) inoperable, action is taken by Specification 3.5.A.4 Specification 3.18.A.3: If an inoperable ESW subsystem is not restored to service in the allowed completion time, or if both trains of ESW are inoperable, an orderly shutdown is commenced such that the reactor water temperature is reduced to less than 21 2'F in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The allowed time for completion is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. The time is consistent with other similar specifications.

3.18/4.18 229ac Amendment No.

Bases 4.18 Specification 4.18.A.1: This surveillance verifies the correct alignment for each manual and automatic valve in each ESW subsystem flow path to provide assurance that the proper flow path will exist for ESW System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR is modified by a Note clarifying that isolation of the ESW System to supplied components or systems may result in them being inoperable, but does not affect the operability of the ESW System (or subsystems).

Specification 4.18.A.2: This surveillance verifies that the ESW System automatically provides cooling water to the safety related equipment during an accident. This is demonstrated by the use of an actual or simulated signal. This surveillance also verifies the automatic start capability the ESW pump in each subsystem. This surveillance is currently performed as part of the integrated ECCS test already performed on a cyclic basis. Operating experience has shown that these components usually pass the SR when performed at this frequency. Therefore, the frequency is concluded to be acceptable from a reliability standpoint.

3.18/4.18 229ad Amendment No.