LIC-14-0074, Supplement to License Amendment Request (LAR) 14-01

Supplement to License Amendment Request (LAR) 14-01

ML14163A417
Person / Time
Site:	Fort Calhoun
Issue date:	06/09/2014
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 14-01, LIC-14-0074
Download: ML14163A417 (32)

Text

w*ll m - -

Omaha PublicPower Disrict 444 South 1e Street Mall Omaha, NE 68102-2247 10 CFR 50.90 LIC-14-0074 June 9, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), License Amendment Request (LAR) 14-01, One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3, dated February 10, 2014 (LIC 0011)

2. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), 10 CFR 50.55a Request Number RR- 13, Omaha Public Power District(OPPD) Request for Relief from Certain In-service Testing (IST) Requirements, dated May 16, 2014 (LIC-14-0040)

SUBJECT:

Supplement to License Amendment Request (LAR) 14-01 Pursuant to 10 CFR 50.90, the Omaha Public Power District (OPPD) hereby requests an amendment to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No. 1. The proposed amendment would revise the surveillance frequency for the pressurizer safety valves from a refueling frequency (i.e., 18 months +25%) to be consistent with the Inservice Testing Program.

The proposed change is necessary due to the extended shutdown of Fort Calhoun Station for the refueling outage that commenced in April 2011. Testing of the safety valves is performed by shipping the valves offsite to a vendor facility. The last performance of the test was completed on January 14, 2013.

Due to the extended shutdown, the valves will be required to be tested prior to the next scheduled refueling outage of April 13, 2015. As a result of discussions with NRC staff it was identified that a relief request for 10 CFR 50.55a would also be required and that it was more appropriate to revise the Technical Specification to reflect the Inservice Testing Program frequency versus requesting a one-time extension to the testing frequency. This supplement incorporates those changes. A Relief Request was submitted in Reference 2 for NRC review and approval in order to allow testing of the pressurizer safety valves during the next scheduled refueling outage.

Aoo 0 a Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LIC-14-0074 Page 2 OPPD has determined that this LAR does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The enclosure contains a description of the proposed changes, the supporting technical analyses, and the significant hazards consideration determination. Attachment 1 of the enclosure provides the existing TS pages marked-up to show the proposed changes. Attachment 2 of the enclosure provides the retyped (clean) TS pages.

OPPD requests approval of the proposed amendment by November 1, 2014. Once approved, the amendment shall be implemented upon issuance.

There are no regulatory commitments associated with this proposed change.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at (402) 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 9, ?20 Louis P. Cortopassi Site Vice President and CNO LPC/brh

Enclosure:

OPPD's Evaluation of the Proposed Change c: M. L. Dapas, NRC Regional Administrator, Region IV J. W. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-1 4-0074 Enclosure Page 1 OPPD's Evaluation of the Proposed Change License Amendment Request (LAR) 14-01, Supplement -

Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions 5.0 ENVIRONMENTAL-CONSIDERATION

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification Page Markups

2. Technical Specification Bases Page Markups (For Information Only)

3. Retyped ("Clean") Technical Specifications Pages

4. Retyped ("Clean") Technical Specifications Bases Pages (For Information Only)

LIC-14-0074 Enclosure Page 2 1.0

SUMMARY

DESCRIPTION License amendment request (LAR) 14-01 proposes a change to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No. 1. The Omaha Public Power District (OPPD) proposes to revise the surveillance frequency for the pressurizer safety valves from a refueling frequency (i.e., 18 months +25%) to be in accordance with the Inservice Testing Program.

In addition to this application, a Relief Request (Reference 6.2) was submitted for NRC review and approval in order to allow testing of the pressurizer safety valves during the next scheduled refueling outage in April 2015.

2.0 DETAILED DESCRIPTION The proposed TS changes for LAR 14-01 are as follows:

SR 3.2, Table 3-5, Item 3 Change the frequency from "R" to "In accordance with the Inservice Testing Program1 "

Add footnote "' The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply."

The asterisks currently used as footnotes in Table 3-5 are being revised to numbers and appear at the end of the table. As a result, text currently on 3.2 - Page 10 and subsequent pages is pulled forward.

3.0 TECHNICAL EVALUATION

The Fort Calhoun Station, Unit No. 1 (FCS) has two installed pressurizer safety valves. Technical Specification (TS) 3.2, Table 3-5, Item 3, requires that the pressurizer safety valves be tested to "Verify each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program. Following testing, lift settings shall be 2485 psig +/-1% and 2530 psig +/-1% respectively."

The table specifies a frequency of "R", designating a "Refueling" interval which is defined in TS 3.0.1 as every 18 months +/- 25 % allowing for a maximum of 22.5 months between tests. This frequency is inconsistent with the requirements of the Inservice Testing Program.

The FCS Inservice Testing Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda. Appendix I of the ASME OM Code specifies frequency requirements for testing of pressure relief valves. Requirements applicable to the Fort Calhoun Station pressurizer safety valves appear in Section 1-1330, Test Frequencies, Class 1 Pressure Relief Valves. This section specifies that the test interval for any individual valve shall not exceed 5-years. In addition, it indicates that at least 20% of the valves from each valve group shall be tested within any 24-month interval. Testing requirements may be satisfied by installing pre-tested valves if certain additional requirements are met regarding testing of the removed valves.

Both FCS pressurizer safety valves were removed from service in April 2011 at the end of the last operating cycle (i.e., Operating Cycle 26). At that time, both valves were tested and found to open within the lift settings specified in TS 2.1.6(1) (i.e., 2485 psig +1%/-3% and 2530 psig +1%/-3%

respectively). In January 2013, in anticipation of plant restart in 2013, the two pressurizer safety valves that had been removed and tested in April 2011 were re-tested. The as-left lift settings for these two valves were demonstrated by testing at a vendor facility on January 14, 2013, and January 15, 2013 respectively. The lift settings of both valves were within a tolerance of +/-1% of setpoint, as discussed in the TS 2.1.6 Basis. These pre-tested replacement valves were subsequently installed and are now inservice.

LIC-14-0074 Enclosure Page 3 The proposed frequency change would allow performance of the next valve tests consistent with the Inservice Testing Program interval of 24 months. In addition, a relief request from the 24 month testing requirement submitted by Reference 6.2, will be required in order to perform the testing during the next scheduled refueling outage that is scheduled to begin April 13, 2015. The proposed footnote to TS 3.2, Table 3-5, Item 5, states that TS 3.0.1 that allows up to a 25 % extension to a surveillance frequency, and TS 3.0.5 that allows an extension to the surveillance frequency if the test is missed, are not applicable to this surveillance. As documented in NRC Regulatory Issue Summary 2012-10, NRC STAFF POSITION ON APPLYING SUREVEILLANCE REQUIREMENTS 3.0.2 AND 3.0.3 TO ADMINISTRATIVE CONTROLS PROGRAM TESTS, (Reference 6.4) the NRC staff has determined that these delay periods do not apply to components tested under 10 CFR 50.55a(f).

Technical Specification 2.1.6(1), requires two pressurizer safety valves to be operable in Modes 1 and 2. The valves were required to be operable beginning in December 2013, when the plant was first returned to Mode 2 after the extended plant shutdown.

As the valves are sent offsite to a vendor facility, the setpoints were last set in January 2013 with the expectation of startup from the refueling outage in the spring of 2013; therefore, the need for this extension was not expected.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.1.1 Regulations Code of Federal Regulations 10 CFR Part 50.55a Codes and Standards 4.1.2 Design Basis As stated in USAR Section 4.3.10, two safety valves located on the pressurizer provide overpressure protection for the reactor coolant system. They are totally enclosed, backpressure-compensated, spring-loaded safety valves meeting ASME Code requirements.

4.1.3 Approved Methodologies The approved testing methods as contained in the Inservice Testing Program are:

ASME Code for Operation and Maintenance of Nuclear Power Plants, 1998 Edition (ASME OM Code - 1998), through 2000 Addenda ASME SECTION XI, 1989 Edition, Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices and the ASME/ANSI O&M Manual, Part 1, 1987 Edition 4.1.4 Analysis No analyses were conducted in support of the proposed amendment.

LIC-14-0074 Enclosure Page 4 4.2 Precedent As noted in 10 CFR 50.55a(f)(5):

5)(i) The inservice test program for a boiling or pressurized water-cooled nuclear power facility must be revised by the licensee, as necessary, to meet the requirements of paragraph(f)(4) of this section.

(ii) If a revised inservice test program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program.

The current surveillance frequency is more conservative than the Inservice Testing Program in that it requires testing every refueling +25 percent for a maximum period of 22.5 months. The code requires testing every 24 months. The proposed change will make the Technical Specification consistent with the code as stated in 10 CFR 50.55a.

4.3 Sicqnificant Hazards Consideration The proposed change would revise the surveillance frequency for the pressurizer safety valves from refueling frequency (18 months +25%) to be in accordance with the Inservice Testing Program.

The Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment 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.

The requested change revises the performance interval of one TS surveillance requirement to be consistent with the Inservice Testing Program as stated in 10 CFR 50.55a(g)(5). The performance of the surveillance, or the failure to perform the surveillance, is not a precursor to an accident. Performing the surveillance or failing to perform the surveillance does not affect the probability of an accident. Even with the requested extension, the period during which the plant is in Modes 1 or 2 and the valves are required to be operable will be no longer than a typical operating cycle. Also, the proposed interval between tests will be consistent with the interval for this type of valve specified by the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda, Appendix I, frequency requirements for testing of pressure relief valves.

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

LIC-14-0074 Enclosure Page 5

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

Response: No.

The proposed change does not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Hence, the proposed change does not introduce any new accident initiators, nor does it reduce or adversely affect the capabilities of any plant structure or system in the performance of their safety function.

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 revises the performance interval for one surveillance requirement to be consistent with the test interval for this type of valve specified by the ASME OM Code, 1998 Edition, through 2000 Addenda as required by 10 CFR 50.55a. This change does not alter any safety margins.

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

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

4.4 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 effluent 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.

LIC-14-0074 Enclosure Page 6

6.0 REFERENCES

6.1 10CFR50.55a 6.2 Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), 10 CFR 50.55a Request Number RR-13, Omaha Public Power District (OPPD) Request for Relief from Certain In-service Testing (IST) Requirements, dated May 16, 2014 (LIC-1 4-0040)

LIC-14-0074 Enclosure, Attachment 1 Page 1 Technical Specification Page Markups

[Word-processormark-ups using "double underline/IAWkeeWt" feature for "new text/deleted text" respectively.]

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

1. Control Element Drop times of all full-length CEA's Prior to reactor criticality after each 7.5.3 Assemblies removal of the reactor vessel closure head

2. Control Element Partial movement of all CEA's Q 7 Assemblies (Minimum of 6 in)

3. Pressurizer Safety Verify each pressurizer safety valve 7 Valves is OPERABLE in accordance with the Inservice Testing Program.

Following testing, lift settings shall be 2485 psig +/-_1% and 2530 psig +/-1%

respectively.

4. Main Steam Safety Set Point R 4 Valves

5. DELETED

6. DELETED

7. DELETED 8a. Reactor Cool' N Evaluate 4 System Lea kgj:v, Continuous process 4 Leakae radiation monitors or radiochemical grab sampling 9a Diesel Fuel Supply Fuel Inventory M 8.4 9b. Diesel Lubricating Oil Lube Oil Inventory M 8.4 Inventory 9c. Diesel Fuel Oil T est Properties In accordance with the Diesel Fuel 8.4 Properties Oil Testing Program 9d. Required Diesel A ir Pressure M 8.4 Generator Air Start Receiver Bank Pressure 3.2 - Page 8 Amendment No. 15,24,128,160,166,169,171,219, 229, 246, 2-&7

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS

• WheneVer the system is at oe above operating temperatur and pre.sue.

Not applicable to prirnar; to 6eGonda~' lEFAKAGF.

Verif' primnar' to secondan,' LEAKA~GE is 9 150 gallons per day through any onRe SG.

This su'emillance is, not required to be pe~fGFmed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

3.2 - Page 9 Amendment No. 246, 2-5

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 9e. Check for and Check for Water and Remove Q 8.4 Remove Accumulated Water from Each Fuel Oil Storage Tank 10a. Charcoal and HEPA 1. In-Place Testi) 9.10 Filters for Control Charcoal adsorl7rs and HEPA On a refueling frequency or every 720 Room Air Filteration filter banks shall be leak hours of system operation or after each System (CRAFS) tested and show >99.95% complete or partial replacement of the Freon (R-11 or R-112) and charcoal adsorber/HEPA filter banks, or cold DOP particulates after any major structural maintenance on removal, respectively. the system housing or following significant painting, fire or chemical releases in a ventilation zone communicating with the system.

2. Laborator Testi Verify, within 31 after removal, On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

0.175% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C (86°F) and a relative humidity of 70%.

=**Tests shall be peFfeFFned Onar.r.ord-ann-e- with appliGable seGt'9R(r,) ef AN-S! N5 3.2 - Page 10 Amendment No. 15,24,128,169,198,229,246, 2A7

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 10a. (continued) 3. Overall System Operation

a. Each train shall be operated. Ten continuous hours every month with heaters operating.

b. The pressure drop across the R combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 9 inches of water at system design flow rate.

c. Fan shall be shown to operate R within + 10% design flow.

4. Automatic and manual initiation of each train shall be demonstrated.

10b. Charcoal Adsorbers 1. In-Place Testiq-for Spent Fuel Charcoal adso shall be On a refueling frequency or every 720 6.2 Storage Pool Area leak tested and shall show hours of system operation, or after 9.10

>99% Freon (R-11 or R-112) each complete or partial replacement of removal. the charcoal adsorber bank, or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in a ventilation zone communicating with the system.

2. Laboratory Testingq Verify, within 31 days after removal, On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

10% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C (86°F) and a relative humidity b.........e.

h...........a 6..........

6.............. . ....... .. .3 ,o a f, A .l ,2N

• .3 - Ka qe 11 Amendment No. 15,24.52,128,154,169,198,229,246, 245-7

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 1Ob. (continued) 3. Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate through R charcoal filter shall be shown to be between 4500 and 12,000 cfm.

4. Manual initiation of the R system shall be demon-strated.

1Oc. Charcoal Adsorbers 1. In-Place Test On a refueling frequency or every 9.10 for S.I. Pump Room Charcoal adsor-'"rs shall be 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or 6.2 leak tested and shall show after each complete or partial

>99% Freon (R-11 or R-112) replacement of the charcoal adsorber bank, removal. or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in any ventilation zone communicating with the system.

2. Laboratory Testing Verify, within 31 days after removal, On a refueling frequency or following 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the system.

methyliodide penetration less than 10% when tested in accordance with ASTM D3803-1989 at a temperature of 300C (86°F) and a relative humidity of 95%.

3. Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate shall be R shown to be between 3000 a 0 f

73. ý-agý - Amendment No. 15,24,52,128,169,19, 229,6 2-57

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 1Oc. (continued) 4. Automatic and/or manual initi- R ation of the system shall be demonstrated.

11. Containment 1. Demonstrate damper action. 1 year, 2 years, 5 years, and every 5 9.10 Ventilation System years thereafter.

Fusible Linked Dampers 2. Test a spare fusible link.

12. Diesel Generator Calibrat R 8.4.3 Under-Voltage Relays

13. Motor Operated Verify the contactor pickup value at R Safety Injection <85% of 460 V.

Loop Valve Motor Starters (HCV-31 1, 314, 317, 320, 327, 329, 331, 333, 312, 315, 318, 321)

14. Pressurizer Heaters Verify control circuits operation R for post-accident heater use.

15. Spent Fuel Pool Test neutron poison samples for 1,2, 4, 7, and 10 years after Racks dimensional change, weight, neutron installation, and every 5 years attenuation change and specific thereafter.

gravity change.

16. Reactor Coolant 1. Verify all manual isolation During each refueling outage just Gas Vent System valves in each vent path are prior to plant start-up.

in the open position.

2. Cycle each automatic valve in the R vent path through at least one complete cycle of full travel from the control room. Verification of valve cycling may be determined by observation of position indicating lights.

3. Verify flow through the reactor R coolant vent system vent paths.

3.2 - Page 13 Amendment No. 41,54,60,75,77.80,1 55,169,182,218,229,246, 2A

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

17. DELETED

18. Shutdown Cooling 1. Verify required shutdown cooling loops are S (when shutdown cooling is OPERABLE and one shutdown cooling loop is IN required by TS 2.8).

OPERATION.

2. Verify correct breaker alignment and indicated W (when shutdown cooling is power is available to the required shutdown cooling required by TS 2.8).

pump that is not IN OPERATION.

3.2 - Page 14 Amendment No. 138,1469,188, 246,250,2-57-, 2-74

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

19. Refueling Water Level Verify refueling water level is >_23 ft. above Prior to commencing, and daily during the top of the reactor vessel flange. CORE ALTERATIONS and/or REFUELING OPERATIONS inside containment.

20. Spent Fuel Pool Level Verify spent fuel pool water level is > 23 ft. Prior to commencing. and weekly during above the top of irradiated fuel assemblies seated REFUELING OPERATIONS in the in the storage racks. the spent fuel pool.

21. Containment Penetrations Verify each required containment penetration is Prior to commencing, and weekly during in the required status. CORE ALTERATIONS and/or REFUELING OPERATIONS in containment.

22. Spent Fuel Assembly Verify by administrative means that initial Prior to storing the fuel assembly in Storage enrichment and burnup of the fuel assembly is in Region 2 (including peripheral cells).

accordance with Figure 2-10.

23. P-T Limit Curve Verify RCS Pressure, RCS temperature, and This test is only required during RCS RCS heatup and cooldown rates are within heatup and cooldown operations and RCS the limits specified by the P-T limit Figure(s) inservice leak and hydrostatic testing. While shown in the PTLR. these operations are occurring, this test shall be performed every 30 minutes.

24. Spent Fuel Cask Loading Verify by administrative means that initial Prior to placing the fuel assembly in a spent enrichment and burnup of the fuel assembly fuel cask in the spent fuel pool.

is in accordance with Figure 2-11.

25. River Level Verify water level is within limits by measurement D 9.8 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when the water level is less than 1004 feet and greater than or equal to 976 feet 9 inches above mean sea levels.

3.2 - Page 15 Amendment No. 188, 221, 239,246,257, 2-74

TECHNICAL SPECIFICATIONS

'The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply.

2 Whenever the system is at or above operatina temperature and pressure.

Not applicable to primary to secondary LEAKAGE.

Verify primary to secondary LEAKAGE is < 150 gallons per day through any one SG. This surveillance is not required to be erformed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation, Tests shall be performed in accordance with applicable section(s) of ANSI N510-1 980

LIC-14-0074 Enclosure, Attachment 2 Page 1 Technical Specification Bases Markups (For Information Only)

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TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (continued)

The spent fuel storage-decontamination areas air treatment system is designed to filter the building atmosphere to the auxiliary building vent during refueling operations. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. In-place testing is performed to confirm the integrity of the filter system. The charcoal adsorbers are periodically sampled to insure capability for the rernoval of radioactive iodine.

The Safety Injection (SI) pump room air treatment system consists of charcoal adsorbers which are installed in normally bypassed ducts. This system is designed to reduce the potential release of radioiodine in SI pump rooms during the recirculation period following a DBA. The in-place and laboratory testing of charcoal adsorbers will assure system integrity and performance.

Pressure drops across the combined HEPA filters and charcoal adsorbers, of less than 9 inches of water for the control room filters (VA-64A & VA-64B) and of less than 6 inches of water for each of the other air treatment systems will indicate that the filters and adsorbers are not clogged by amounts of foreign matter that would interfere with performance to established levels.

If significant painting, fire or chemical release occurs such that the HEPA filters or charcoal adsorbers could become contaminated from the fumes, chemicals or foreign materials, testing will be performed to confirm system performance.

Demonstration of the automatic and/or manual initiation capability will assure the system's availability.

Verifying Reactor Coolant System (RCS) leakage to be within the LCO limits ensures the integrity of the Reactor Coolant Pressure Boundary (RCPB) is maintained. Pressure boundary leakage would at first appear as unidentified leakage and can only be positively identified by inspection. Unidentified leakage is determined by performance of an RCS water inventory balance. Identified leakage is then determined by isolation and/or inspection. Since Primary to Secondary Leakage of 150 galloV pr1fa t measured accurately by an RCS water inventory balance, ne, fotnote2 fo line item 8a on Table 3-5 states that the Reactor Coolant System aae suIla e sot applicable to Primary to Secondary Leakage. Primary to seconi r ge-'fs measured by performance of effluent monitoring within the secondary steam and feedwater systems.

3.2 - Page 2 Amendment No. 15,67,128,138,169,246, 257 TSTB07 003 01 TSBC-

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Samplingq Tests (continued)

Table 3-5, Item 8b verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. Ifthis surveillance requirement is not met, compliance with LCO 3.17, "Steam Generator Tube Integrity,"

should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individclal SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from ne SG.

The Surveillance is modified by a Nete footnote, hich states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> aftablish of steady state operation. For RCS primary to secondary LEAKAGE determination,6s Fy state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency of daily is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents.

The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 5).

Table 3-5, Item 25 verifies adequate measurements are taken to ensure that facility protective actions will be taken (and power operation will be terminated) in the event of high and/or low river level conditions. The high river level limit of less than 1004 feet mean sea level is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment (i.e., due to restricted access/egress to the intake structure veranda once the flood barriers are installed prior to river level reaching 1004 feet msl). A continuous watch will be established at 1002 feet mean sea level to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The river level surveillance requirement specified also ensures sufficient net positive suction head is available for operating the RW pumps.

The minimum river level of 976 feet 9 inches provides adequate suction to the RW pumps for cooling plant components. The surveillance frequency of "Daily" is a reasonable interval and models guidance provided in NUREG-0212, Revision 2, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Section 4.7.6. This surveillance requirement verifies that the Missouri River water level is maintained at a level greater than or equal to 976 feet 9 inches mean sea level. A continuous watch is established to monitor the river level when the river level reaches 980 feet mean sea level to assure no sudden loss of water supply occurs.

References

1) USAR, Section 9.10

2) ASTM D4057, ASTM D975, ASTM D4176, ASTM D2622, ASTM D287, ASTM 6217, ASTM D2709

3) ASTM D975, Table 1

4) Regulatory Guide 1.137

5) EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."

3.2 - Page 5 Amendment No. 229,246,2-7-T, 274 TSBC 09 003 0 TSBC 14 001 0 TSBC-

LIC-14-0074 Enclosure, Attachment 3 Page 1 Retyped ("Clean") Technical Specifications Pages

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

1. Control Element Drop times of all full-length CEA's Prior to reactor criticality after each 7.5.3 Assemblies removal of the reactor vessel closure head

2. Control Element Partial movement of all CEA's Q 7 Assemblies (Minimum of 6 in)

3. Pressurizer Safety Verify each pressurizer safety valve In accorc ance with the Inservice Testing 7 Valves is OPERABLE in accordance with Programl the Inservice Testing Program.

Following testing, lift settings shall be 2485 psig +/-1 /o and 2530 psig +/-1%

respectively.

4. Main Steam Safety Set Point R 4 Valves

5. DELETED

6. DELETED

7. DELETED 8a. Reactor Coolant 3 Evaluate 4 System Leakage 8b. Primary to 4 Secondary Continuous process D2 4 Leakage radiation monitors or radiochemical grab sampling 9a Diesel Fuel Supply Fuel Inventory M 8.4 9b. Diesel Lubricating Oil Lube Oil Inventory M 8.4 Inventory 9c. Diesel Fuel Oil Test Properties In accordance with the Diesel Fuel 8.4 Properties Oil Testing Program 9d. Required Diesel Air Pressure M 8.4 Generator Air Start Receiver Bank Pressure 3.2 - Page 8 Amendment No. 15,24,128,160,166,169,171,219, 229,216, 2-57

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 9e. Check for and Check for Water and Remove Q 8.4 Remove Accumulated Water from Each Fuel Oil Storage Tank 1Oa. Charcoal and HEPA 1. In-Place Testinq5 9.10 Filters for Control Charcoal adsorbers and HEPA On a refueling frequency or every 720 Room Air Filteration filter banks shall be leak hours of system operation or after each System (CRAFS) tested and show >99.95% complete or partial replacement of the Freon (R-11 or R-112) and charcoal adsorber/HEPA filter banks, or cold DOP particulates after any major structural maintenance on removal, respectively. the system housing or following significant painting, fire or chemical releases in a ventilation zone communicating with the system.

2. Laboratory Testinq5 Verify, within 31 days after removal, On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

0.175% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C (86°F) and a relative humidity of 70%.

3.2 - Page 9 Amendment No. 11 4,128,169,198,229,246, 2i7-

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 10a. (continued) 3. Overall System Operation

a. Each train shall be operated. Ten continuous hours every month with heaters operating.

b. The pressure drop across the R combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 9 inches of water at system design flow rate.

c. Fan shall be shown to operate R within + 10% design flow.

4. Automatic and manual initiation of each R train shall be demonstrated.

10b. Charcoal Adsorbers 1. In-Place Testinq5 for Spent Fuel Charcoal adsorbers shall be On a refueling frequency or every 720 6.2 Storage Pool Area leak tested and shall show hours of system operation, or after 9.10

>99% Freon (R-11 or R-112) each complete or partial replacement of removal. the charcoal adsorber bank, or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in a ventilation zone communicating with the system.

2. Laboratory Testing Verify, within 31 days after removal, On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

10% when tested in accordance with ASTM D3803-1989 at a temperature of 30 0C (86°F) and a relative humidity of 95%.

3.2 -Page 10 Amendment No. 15,2,52.,'28,155,169,198,229,246, 24

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 1Ob. (continued) 3. Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate through R charcoal filter shall be shown to be between 4500 and 12,000 cfm.

4. Manual initiation of the R system shall be demon-strated.

1Oc. Charcoal Adsorbers 1. In-Place Testinq5 On a refueling frequency or every 9.10 for S.I. Pump Room Charcoal adsorbers shall be 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or 6.2 leak tested and shall show after each complete or partial

>99% Freon (R-11 or R-112) replacement of the charcoal adsorber bank, removal. or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in any ventilation zone communicating with the system.

2. Laboratory Testin~q Verify, within 31 days after removal, On a refueling frequency or following 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the system.

methyliodide penetration less than 10% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C (86°F) and a relative humidity of 95%.

3. Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate shall be R shown to be between 3000 and 6000 cfm.

3.2 - Page 11 Amendment No. 5,24,52,12,169,19*, 229,2-6,52-

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 1Oc. (continued) 4. Automatic and/or manual initi- R ation of the system shall be demonstrated.

11. Containment 1. Demonstrate damper action. 1 year, 2 years, 5 years, and every 5 9.10 Ventilation System years thereafter.

Fusible Linked Dampers 2. Test a spare fusible link.

12. Diesel Generator Calibrate R 8.4.3 Under-Voltage Relays

13. Motor Operated Verify the contactor pickup value at R Safety Injection <85% of 460 V.

Loop Valve Motor Starters (HCV-311, 314, 317, 320, 327, 329, 331, 333, 312, 315, 318, 321)

14. Pressurizer Heaters Verify control circuits operation R for post-accident heater use.

15. Spent Fuel Pool Test neutron poison samples for 1, 2, 4, 7, and 10 years after Racks dimensional change, weight, neutron installation, and every 5 years attenuation change and specific thereafter.

gravity change.

16. Reactor Coolant 1. Verify all manual isolation During each refueling outage just Gas Vent System valves in each vent path are prior to plant start-up.

in the open position.

2. Cycle each automatic valve in the R vent path through at least one complete cycle of full travel from the control room. Verification of valve cycling may be determined by observation of position indicating lights.

3. Verify flow through the reactor R coolant vent system vent paths.

3.2 - Page 12 Amendment No. -1,54 40,75,77. 80 55,169,182,218,229,246, 2,W

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

17. DELETED

18. Shutdown Cooling 1. Verify required shutdown cooling loops are S (when shutdown cooling is OPERABLE and one shutdown cooling loop is IN required by TS 2.8).

OPERATION.

2. Verify correct breaker alignment and indicated W (when shutdown cooling is power is available to the required shutdown cooling required by TS 2.8).

pump that is not IN OPERATION.

19. Refueling Water Level Verify refueling water level is > 23 ft. above Prior to commencing, and daily during the top of the reactor vessel flange. CORE ALTERATIONS and/or REFUELING OPERATIONS inside containment.

20. Spent Fuel Pool Level Verify spent fuel pool water level is ->23 ft. Prior to commencing, and weekly during above the top of irradiated fuel assemblies seated REFUELING OPERATIONS in the in the storage racks. the spent fuel pool.

21. Containment Penetrations Verify each required containment penetration is Prior to commencing, and weekly during in the required status. CORE ALTERATIONS and/or REFUELING OPERATIONS in containment.

22. Spent Fuel Assembly Verify by administrative means that initial Prior to storing the fuel assernbly in Storage enrichment and burnup of the fuel assembly is in Region 2 (including peripheral cells).

accordance with Figure 2-10.

23. P-T Limit Curve Verify RCS Pressure, RCS temperature, and This test is only required during RCS RCS heatup and cooldown rates are within heatup and cooldown operations and RCS the limits specified by the P-T limit Figure(s) inservice leak and hydrostatic testing. While shown in the PTLR. these operations are occurring, this test shall be performed every 30 minutes.

24. Spent Fuel Cask Loading Verify by administrative means that initial Prior to placing the fuel assembly in a spent enrichment and burnup of the fuel assembly fuel cask in the spent fuel pool.

is in accordance with Figure 2-11.

3.2 -Page 13 Amendment No. 4-.8,169,188, 24-,250,27-97-2-74

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS Test Frequency USAR Section Reference

25. River Level Verify water level is within limits by measurement D 9.8 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when the water level is less than 1004 feet and greater than or equal to 976 feet 9 inches above mean sea levels.

1 The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply.

2 Whenever the system is at or above operating temperature and pressure.

3 Not applicable to primary to secondary LEAKAGE.

4 Verify primary to secondary LEAKAGE is < 150 gallons per day through any one SG. This surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

s Tests shall be performed in accordance with applicable section(s) of ANSI N510-1980.

3.2 -Page 14 Amendment No. 188, 221, 23",246,25-7, 274

LIC-14-0074 Enclosure, Attachment 4 Page 1 Retyped ("Clean") Technical Specification Bases Pages (For Information Only)

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (continued)

The spent fuel storage-decontamination areas air treatment system is designed to filter the building atmosphere to the auxiliary building vent during refueling operations. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. In-place testing is performed to confirm the integrity of the filter system. The charcoal adsorbers are periodically sampled to insure capability for thle removal of radioactiv,, iodine.

The Safety Injection (SI) pump room air treatment system consists of charcoal adsorbers which are installed in normally bypassed ducts. This system is designed to reduce the potential release of radioiodine in Sl pump rooms during the recirculation period following a DBA. The in-place and laboratory testing of charcoal adsorbers will assure system integrity and performance.

Pressure drops across the combined HEPA filters and charcoal adsorbers, of less than 9 inches of water for the control room filters (VA-64A & VA-64B) and of less than 6 inches of water for each of the other air treatment systems will indicate that the filters and adsorbers are not clogged by amounts of foreign matter that would interfere with performance to established levels.

If significant painting, fire or chemical release occurs such that the HEPA filters or charcoal adsorbers could become contaminated from the fumes, chemicals or foreign materials, testing will be performed to confirm system performance.

Demonstration of the automatic and/or manual initiation capability will assure the system's availability.

Verifying Reactor Coolant System (RCS) leakage to be within the LCO limits ensures the integrity of the Reactor Coolant Pressure Boundary (RCPB) is maintained. Pressure boundary leakage would at first appear as unidentified leakage and can only be positively identified by inspection. Unidentified leakage is determined by performance of an RCS water inventory balance. Identified leakage is then determined by isolation and/or inspection. Since Primary to Secondary Leakage of 150 gallons per day cannot be measured accurately by an RCS water inventory balance, note, footnote 2 for line item 8a on Table 3-5 states that the Reactor Coolant System Leakage surveillance is not applicable to Primary to Secondary Leakage. Primary to secondary leakage is measured by performance of effluent monitoring within the secondary steam and feedwater systems.

3.2 - Page 2 Amendment No. 15,67,128,138,169,246, 257 TSBC 07 003 01 TSBC-

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (continued)

Table 3-5, Item 8b verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this surveillance requirement is not met, compliance with LCO 3.17, "Steam Generator Tube Integrity,"

should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to a ssign the LEAKAGE to amn iridividi tl SG, all tho primar y t_,A/\,,AGE s-cnry should be conservatively assumed to be from one SG.

The Surveillance is modified by a footnote, which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency of daily is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents.

The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 5).

Table 3-5, Item 25 verifies adequate measurements are taken to ensure that facility protective actions will be taken (and power operation will be terminated) in the event of high and/or low river level conditions. The high river level limit of less than 1004 feet mean sea level is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment (i.e., due to restricted access/egress to the intake structure veranda once the flood barriers are installed prior to river level reaching 1004 feet msl). A continuous watch will be established at 1002 feet mean sea level to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The river level surveillance requirement specified also ensures sufficient net positive suction head is available for operating the RW pumps.

The minimum river level of 976 feet 9 inches provides adequate suction to the RW pumps for cooling plant components. The surveillance frequency of "Daily" is a reasonable interval and models guidance provided in NUREG-0212, Revision 2, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Section 4.7.6. This surveillance requirement verifies that the Missouri River water level is maintained at a level greater than or equal to 976 feet 9 inches mean sea level. A continuous watch is established to monitor the river level when the river level reaches 980 feet mean sea level to assure no sudden loss of water supply occurs.

References

1) USAR, Section 9.10

2) ASTM D4057, ASTM D975, ASTM D4176, ASTM D2622, ASTM D287, ASTM 6217, ASTM D2709

3) ASTM D975, Table 1

4) Regulatory Guide 1.137

5) EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."

3.2 - Page 5 Amendment No. 229,246,257-, 274 TSBC 09 003-0 TSBC 14 001 0 TSBC-