LR-N20-0060, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
ML20274A097
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 09/29/2020
From: Casulli E
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H20-05, LR-N20-0060
Download: ML20274A097 (34)
v • d • e


Text

10 CFR 50.90 LR-N20-0060 LAR H20-05 September 29, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Pursuant to 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Hope Creek Generating Station.

PSEG requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked to show the proposed changes. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only. PSEG will provide the camera ready TS pages at a later date.

PSEG requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by March 31, 2021. Once approved, the amendment shall be implemented within 60 days.

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

There are no regulatory commitments contained in this letter.

10 CFR 50.90 LR-N20-0060 Page 2 If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208.

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

Executed on (Date)

Sinu Edward T. Casulli Site Vice President Hope Creek Generating Station Attachments:

1. Description and Assessment
2. Proposed Technical Specification Changes (Mark-up)
3. Proposed Technical Specification Bases Changes (Mark-up) (for information only) cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Site Compliance Commitment Tracking Coordinator

LR-N20-0060 Attachment 1 Description and Assessment

LR-N20-0060 Description and Assessment

1.0 DESCRIPTION

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

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

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

2.2 Optional Changes and Variations PSEG is proposing the following variations from the TS changes described in the TSTF-582 or the applicable parts of the NRC staffs safety evaluation. These variations do not affect the applicability of TSTF-582 or the NRC staff's safety evaluation to the proposed license amendment.

The following variations are administrative and do not affect the applicability of TSTF-582 to the Hope Creek TS

a. The Hope Creek TS utilize different numbering and titles than the BWR/4 Standard Technical Specifications (STS) on which TSTF-582 was based. Specifically, the following table shows the differences between the plant-specific TS numbering and/or titles and the TSTF-582 numbering and titles. These differences are administrative and do not affect the applicability of TSTF-582 to the Hope Creek TS.

TSTF-582 STS Hope Creek TS Comments 1.1 Definitions 1.0 Definitions DRAIN TIME 1.11.1 - DRAIN TIME For Hope Creek, each definition is individually numbered 3.3.5.2A, Reactor Pressure 3/4.3.12, RPV Water Vessel (RPV) Water Inventory Inventory Control Control Instrumentation Instrumentation 1

LR-N20-0060 TSTF-582 STS Hope Creek TS Comments 3.3.8.1A, Loss of Power (LOP) 3/4.3.3, Emergency Core Instrumentation Cooling System Actuation Instrumentation 3.5, Emergency Core Cooling 3/4.5, Emergency Core Systems (ECCS), RPV Water Cooling Systems (ECCS)

Inventory Control, and Reactor and RPV Water Inventory Core Isolation Cooling System Control (RCIC) 3.5.3, RCIC System 3/4.7.4, Reactor Core No changes required Isolation Cooling System to Hope Creek 3.6.1.3, Primary Containment 3/4.6.3 Primary No changes required Isolation Valves Containment Isolation to Hope Creek Valves 3.8.2, AC Sources - Shutdown 3.8.1.2, AC Sources -

Shutdown

b. The Hope Creek TS also differ in format from the Standard Technical Specifications on which TSTF-582 was based. In general, the TS Limiting Condition for Operation (LCO),

APPLICABILITY, ACTION and SURVEILLANCE REQUIREMENTS are provided in an outline format. These differences are administrative and do not affect the applicability of TSTF-582 to the Hope Creek TS.

c. TSTF-582 deletes Instrumentation functions and Surveillance Requirements and renumbers subsequent functions and SRs. Hope Creek has instead marked the deleted steps/rows as deleted to maintain the current numbering. These differences are administrative and do not affect the applicability of TSTF-582 to the Hope Creek TS
d. The STS Table 1.1-1 defines MODES of Operation for STS plants (1 through 5) while Hope Creek TS Table 1.2 defines Operational Conditions (1 through 5). The differences in the definitions of OPCONs 4 and 5 vs. MODEs 4 and 5 are as follows:

Hope Creek has an Average Reactor Coolant Temperature limit of 140°F for OPCON 5, Refueling, and STS does not.

Hope Creek has notes which describe allowances for repositioning the reactor mode switch and refers to Special Test Exception TS 3.10.1, 3.10.3 and 3.10.8 while STS does not.

These differences have no impact on the TSTF-582 changes or the applicability of the model Safety Evaluation. Therefore, the STS MODEs 4 and 5 and the Hope Creek OPCONs 4 and 5 are considered equivalent.

e. The TSTF-582 model application contains a verification that states:

[LICENSEE] verifies that the required ECCS injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) from the control room following plant procedures. The LCO 3.5.2 Bases are revised to state that an 2

LR-N20-0060 operable ECCS injection/spray subsystem must be capable of being aligned and started from the control room in less than one hour.

Manual starting of a standby ECCS injection/spray pump may include removing the pump from Pull-to-Lock (PTL). In MODE 5, pumps not in operation are placed in PTL to prevent inadvertent start up and the potential for overflowing Refuel Floor Pools. Hope Creeks Bailey Logic design does not allow for removing the ECCS pumps from PTL from the control room. This function is performed locally at the breaker. Therefore, the words, from the control room will not be used in the Hope Creek TS Bases. This variation is justified because the location of the breakers is readily accessible in the same safety structure as the control room; and removal of the pump from PTL is an action that can be easily achieved within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drain time following plant procedures. These differences have no impact on the TSTF-582 changes or the applicability of the model Safety Evaluation.

f. TSTF-582, "RPV WIC Enhancements," states:

The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, "AC Sources - Shutdown," requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, "AC Sources - Operating," SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1.

TSTF-582 revises Technical Specification (TS) 3.8.2, "AC Sources - Shutdown,"

Surveillance Requirement (SR) 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

The NRC Safety Evaluation for TSTF-582 (ADAMS Accession No. ML20219A333, dated, 08/13/2020), Section 3.6, "Alternating Current Sources - Shutdown, STS 3.8.2,"

states:

STS 3.5.2, Reactor Pressure Vessel Water Inventory Control (RPV WIC), does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS. Because the automatic ECCS initiation and related ECCS initiation signal in Modes 4 and 5 are eliminated, the automatic start of the DG on an ECCS initiation signal is not required in Modes 4 and 5. [T]he NRC staff finds that STS 3.5.2 provides enough time from the onset of the [loss of offsite power] LOOP event for the operator to manually start the DG required to 3

LR-N20-0060 supply power to the water injection equipment to mitigate the draining event in Modes 4 and 5. In addition, STS 3.5.2 does not require the automatic initiation of the ECCS injection/spray subsystem or the additional method of water injection.

Therefore, since STS 3.5.2 allows enough time to manually start the DG and the equipment for water injection, the NRC staff finds that the automatic start and loading of the DG are not necessary on a LOOP signal or LOOP concurrent with an ECCS initiation signal to mitigate a draining event in Modes 4 and 5.

Furthermore, the NRC staff notes that other events postulated in Modes 4 and 5 (e.g., FHA, waste gas tank rupture) and during movement of [recently] irradiated fuel assemblies in the [primary and secondary containment] do not assume a LOOP event or an automatic ECCS initiation.

TSTF-582 did not include all of the TS changes needed to reflect that TS 3.8.1.2 should not require automatic start and loading of a diesel generator on an ECCS initiation signal or a loss of offsite power signal.

i. TS Tables 3.3.3-1, "Emergency Core Cooling System Actuation Instrumentation,"

and 4.3.3.1-1, Emergency Core Cooling System Actuation Instrumentation Surveillance Requirements, trip function 5, Loss of Power is currently applicable in OPCONs 1, 2, and 3 and when ESF equipment is required to be OPERABLE.

TSTF-582 revised TS 3.8.1.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal. Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.1.2.

The Operational Condition For Which Surveillance Required of Tables 3.3.3-1 and 4.3.3.1-1 is revised to not include OPCONs 4 and 5 for the loss of power trip functions and deletes the associated note which states, Required when ESF equipment is required to be OPERABLE."

ii. TS SR 4.8.1.1.2.g and SR 4.8.1.1.2.k.2 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual diesel generator start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 4.8.1.1.2.g and SR 4.8.1.1.2.k.2 are added to the list of TS 3.8.1.1 SRs that are not applicable under SR 4.8.1.2.

iii. TS SR 4.8.1.1.2.h.13 requires each DG to be demonstrated OPERABLE by verifying that "the automatic load sequencer timer is OPERABLE with the interval between each load block within +/- 10% of its design interval." TSTF-582 retained SR 4.8.1.1.2.h.13 as a test that must be met. The load sequencer is only used for the automatic start and loading of the diesel generator and is not used during a manual diesel generator start. Therefore, SR 4.8.1.1.2.h.13 is added to the list of TS 3.8.1.1 SRs that are not applicable under SR 4.8.1.2.

iv. TS SR 4.8.1.1.2.h.11 requires each DG to be demonstrated OPERABLE by verifying that "with the diesel generator operating in a test mode and connected to its bus, a simulated ECCS actuation signal overrides the test mode by (1) returning the diesel generator to standby operation, and (2) automatically energizes the emergency loads with offsite power. This Hope Creek SR essentially performs the same function as 4

LR-N20-0060 SR 4.8.1.1.2.h.5, which states, Verifying that on an ECCS actuation test signal, without loss of offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. TSTF-582 justifies removing the SR corresponding to 4.8.1.1.2.h.5 (ITS SR 3.8.1.12) based on the auto-start feature no longer being required. Therefore, the same justification for removal can be used for SR 4.8.1.1.2.h.11 and it is added to the list of TS 3.8.1.1 SRs that are not applicable under SR 4.8.1.2.

v. The TS 3.8.1.2 LCO Bases were not updated by TSTF-542 or TSTF-582 to reflect that automatic start and loading of a diesel generator is not required. The LCO 3.8.1.2 Bases are revised to reflect the TS requirements. This variation provides consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.1.2

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis PSEG Nuclear LLC (PSEG) requests adoption of TSTF 582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." TSTF-582 includes the following changes to the technical specifications (TS):

1. The TS are revised to eliminate the requirement for a manual ECCS initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.
2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.
3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."
4. The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.
5. A Surveillance Requirement (SR) that requires operating the required Emergency Core Cooling System (ECCS) injection/spray subsystem for at least 10 minutes through the recirculation line is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.
6. TS 3.8.1.2, "AC Sources - Shutdown," SR 4.8.1.2, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

5

LR-N20-0060

7. The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

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

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

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

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

None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in OPCONs 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will affect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an 6

LR-N20-0060 unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

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

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

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

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.4. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.

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

Based on the above, PSEG concludes that the proposed change 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.

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

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 change.

7

LR-N20-0060 Attachment 2 Proposed Technical Specification Changes (Mark-up)

The following Technical Specification pages for Renewed Facility Operating License NPF-57 are affected by this change request:

1-2a 3/4 3-34 3/4 3-40 3/4 3-111 3/4 3-112 3/4 3-113 3/4 3-114 3/4 3-115 3/4 5-6a 3/4 5-7 3/4 8-11

DEFINITIONS DRAIN TIME 1.11.1 The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

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

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or
3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

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

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

E-AVERAGE DISINTEGRATION ENERGY 1.12 E shall be the average, weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling, of the sum of the average beta and gamma energies per disintegration, in MeV, for isotopes, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.

HOPE CREEK 1-2a Amendment No. 213 xxx

TABLE 3.3.3-1 (Cont'd)

EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION MINIMUM OPERABLE CHANNELS PER APPLICABLE TRIP OPERATIONAL TRIP FUNCTION FUNCTION(a) CONDITIONS ACTION

4. AUTOMATIC DEPRESSURIZATION SYSTEM##
e. RHR LPCI Mode Pump Discharge Pressure - High (Permissive) 2/pump 1,2, 3 31
f. Reactor Vessel Water Level - Low, Level 3 (Permissive) 2 1,2,3 31
g. ADS Drywell Pressure Bypass Timer 4 1,2,3 31
h. ADS Manual Inhibit Switch 2 1,2,3 31
i. Manual Initiation 4 1,2, 3 33 MINIMUM APPLICABLE TOTAL NO. CHANNELS CHANNELS OPERATIONAL OF CHANNELS(h} TO TRIP(h} OPERABLE{h} CONDITIONS ACTION
5. LOSS OF POWER
1. 4.16 kv Emergency Bus Under-voltage (Loss of Voltage) 4/bus 2/bus 3/bus 1, 2, 3, 4**, 5** 36
2. 4.16 kv Emergency Bus Under-voltage (Degraded Voltage) 2/source/ 2/source/ 2/source/ 1, 2, 3, 4-, 5- 36 bus bus .bus (a) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required surveillance without placing the trip system in the tripped condition provided at least one OPERABLE channel in the same trip system is monitoring that parameter.

(b) Also actuates the associated emergency diesel generators.

(c) One trip system. Provides signal to HPCI pump suction valve only.

(d) Provides a signal to trip HPCI pump turbine only.

(e) In divisions 1 and 2,the two sensors are associated with each pump and valve combination. In divisions 3 and 4,the two sensors are associated with each pump only.

( f) Division 1 and 2 only.

(g) In divisions 1 and 2, manual initiation is associated with each pump and valve combination; in divisions 3 and 4, manual initiation is associated with each pump only.

(h) Each voltage detector is a channel.

(I) Start time delay is applicable to LPCI Pump C and D only.

  • Deleted.

Required when ESF equipment is required to be OPERABLE. Deleted

  1. Not required to be OPERABLE when reactor steam dome pressure is less than or equal to 200 psig.
    1. Not required to be OPERABLE when reactor steam dome pressure is less than or equal to 100 psig.

HOPE CREEK 3/4 3-34 Amendment No. xxx 213

TABLE 4.3.3.1-1 (Continued)

EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL OPERATIONAL CONDITIONS CHANNEL FUNCTIONAL CHANNEL FOR WHICH SURVEILLANCE TRIP FUNCTION CHECK{*l TEST(*l CALIBRATION (*l REQUIRED

4. AUTOMATIC DEPRESSURIZATION SYSTEM1111
a. Reactor Vessel Water Level - Low Low Low, Level 1 1, 2, 3
b. Drywell Pressure - High 1, 2, 3
c. ADS Timer NA 1, 2, 3
d. Core Spray Pump Discharge Pressure - High 1,2, 3
e. RHR LPCI Mode Pump Discharge Pressure 1,2,3

-High

f. Reactor Vessel Water Level Low, Level 3 1, 2,3
g. ADS Drywell Pressure Bypass Timer NA 1, 2,3
h. ADS Manual Inhibit Switch NA NA 1,2, 3 i, Manual initiation NA NA 1,2, 3
5. LOSS OF POWER
a. 4.16 kv Emergency Bus Under-voltage (Loss NA NA of Voltage) 1, 2, 3, 4.., 5**
b. 4.16 kv Emergency Bus Under-voltage (Degraded Voltage) 1, 2, 3, 4**. 5..

Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

Deleted Required OPERABLE when ESF equipment is required to be OPERABLE. Deleted

  1. Not required to be OPERABLE when reactor steam dome pressure is less than or equal to 200 psig.
    1. Not required to be OPERABLE when reactor steam dome pressure is less than or equal to 100 psig.

HOPE CREEK 3/4 3-40 Amendment No. xxx 213

INSTRUMENTATION 3/4.3.12 RPVWATER INVENTORY CONTROL INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.12 The RPVWater Inventory Control (WIC) actuation instrumentation channels shown in Table 3.3.12-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3.12-1 ACTION:

a. With one or more channels inoperable, take the ACTION referenced in Table 3.3.12-1 for the channel immediately.

SURVEILLANCE REQUIREMENTS 4.3.12 Each RPVWIC actuation instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, and CHANNEL FUNCTIONAL TEST and LOGIC SYSTEM FUNCTIONAL TEST at the frequencies shown in Table 4.3.12.1-1.

HOPE CREEK 3/4 3-111 Amendment No. 213 xxx

TABLE 3.3.12-1 RPV WATER INVENTORY CONTROL INSTRUMENTATION MINIMUM OPERABLE CHANNELS APPLICABLE PER TRIP OPERATIONAL TRIP FUNCTION FUNCTION CONDITIONS ACTIONS

1. CORE SPRAY SYSTEM Deleted
a. Reactor Vessel Pressure - Low(Permissive) 4/division(a)(c) 4,5 83
b. Core Spray Pump Discharge Flow- Low 1/subsystem<a) 4,5 84 (Bypass)

C. Manual Initiation 1/division<a> 4,5 84

2. LOW eBESSUBE CQQLANI INJECIIQN MQOE QE Bl::IB SYSIEM Deleted
a. Reactor Vessel Pressure-Low (Permissive) 1/valve<aJ 4,5 83
b. LPCI Pump Discharge Flow- Low(Bypass) 1/pump{a)(d) 4,5 84 C. Manual Initiation 1/subsystem<a> 4,5 84
3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION
a. Reactor Vessel Water Level Low, Level 3 2/Valve (b) (a) 85
4. REACTOR WATER CLEANUP SYSTEM ISOLATION
a. Reactor Vessel Water Level - LowLow, Level 2 2Nalve (b) (a) 85 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."

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

( c) Division 1 and 2 only.

( d) Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated.

HOPE CREEK 3/4 3-112 Amendment No. 213 xxx

TABLE 3.3.12-1 (Continued)

RPV WATER INVENTORY CONTROL INSTRUMENTATION ACTION ACTION 83 - Place the channel in hip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Otherwise, immediately declare the associated low pressure ECCS injection/spray subsystem inoperable.Deleted ACTION 84 - Restore the channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, immediately declare the associated low pressure ECCS injection/spray subsystem inoperable. Deleted ACTION 85- Declare the associated flow path(s) incapable of automatic isolation and calculate DRAIN TIME immediately.

Immediately initiate action to place the channel in trip, or immediately declare the associated penetration flow path(s) incapable of automatic isolation and initiate action to calculate DRAIN TIME.

HOPE CREEK 3/4 3-113 Amendment No. 213 XXX

TABLE 3.3.12-2 RPV WATER INVENTORY CONTROL INSTRUMENTATION SETPOINTS ALLOWABLE TRIP FUNCTION VALUE

1. CORE SPRAY SYSTEM Deleted
a. Reactor Vessel Pressure - Low (Permissive)  ::;;4a1 psig
b. Core Spray Pump Discharge Flow - Low (Bypass) 650 gpm
c. Manual Initiation NA
2. LOW PRESSURE COOLANT INJECTION MODE OF RHR SYSTEM Deleted
a. Reactor Vessel Pressure - Low (Permissive)  ::;;450 psig
b. LPCI Pump Discharge Flow-Low (Bypass) 1100 gpm C. Manual Initiation NA
3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION
a. Reactor Vessel Water Level - Low, Level 3 11 inches
4. REACTOR WATER CLEANUP SYSTEM ISOLATION
a. Reactor Vessel Water Level - Low Low, - Level 2 -45 inches HOPE CREEK 3/4 3-114 Amendment No. 213 xxx

TABLE 4.3.12.1-1 RPVWATER INVENTORY CONTROL INSTRUMENTATION SURVEILLANCE REQUIREMENTS OPERATIONAL LOGIC CONDITIONS CHANNEL SYSTEM FOR WHICH CHANNEL FUNCTIONAL FUNCTIONAL SURVEILLANCE TRIP FUNCTION CHECl(<a> TESra> TEST<a> REQUIRED

1. CORE SPRAY SYSTEM Deleted
a. Reactor Vessel Pressure - N.A. 4,5 Low (Permissive)
b. Core Spray Pump Discharge N.A. 4,5 Flow- Low (Bypass)

C. Manual Initiation N.A. N.A. 4,5

2. LOW EBESSUBE CQQLA~I Deleted l~JECIIQ~ MOOE QE Bl::IB SYSIEM
a. Reactor Vessel Pressure-Low N.A. 4,5 (Permissive)
b. LPCI Pump Discharge Flow - N.A. 4,5 Low (Bypass)

C. Manual Initiation N.A. N.A. 4,5

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION
a. Reactor Vessel Water Level - N.A. (b}

Low, Level 3

4. REACTOR WATER CLEANUP SYSTEM ISOLATION
a. Reactor Vessel Water Level - N.A. (b}

Low Low, Level 2 (a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

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

HOPE CREEK 3/4 3-115 Amendment No. 213 xxx

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL LIMITING CONDITION FOR OPERATION <Continued}

ACTION:

c. With DRAIN TIME< 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and;? 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:
1. Verify secondary containment boundary is capable of being established in less than the DRAIN TIME, AND
2. Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME, AND
3. Verify one Filtration, Recirculation and Ventilation (FRVS) ventilation unit is capable of being placed in operation in less than the DRAIN TIME.

Otherwise, immediately initiate action to restore DRAIN TIME to;? 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

d. With DRAIN TIME< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and?. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately:
1. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for;? 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />... AND,
2. Initiate action to establish secondary containment boundary, AND
3. Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, AND
4. Initiate action to verify one FRVS ventilation unit is capable of being placed in operation.

Otherwise, immediately initiate action to restore DRAIN TIME to;? 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

e. With DRAIN TIME< 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately initiate action to restore DRAIN TIME to
? 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
      • Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

HOPE CREEK 3/4 5-6a Amendment No. 213 xxx

EMERGENCY CORE COOLING SYSTEMS (ECCS) AND RPV WATER INVENTORY CONTROL SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the Surveillance Frequency Control Program.

4.5.2.2 Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression chamber indicated water level is 5.0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required Core Spray (CS) subsystem, the Suppression chamber indicated water level is 5.0 inches or condensate storage tank contains at least 135,000 available gallons of water in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve in accordance with the Surveillance Frequency Control Program.

4.5.2.5 Verify, for the required ECCS injection/spray subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position, in accordance with the Surveillance Frequency Control Program. # Deleted 4.5.2.6 Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes, in accordance with the Surveillance Frequency Control Program. # ###

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, in accordance with the. Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated actuates on a manual initiation signal, in accordance with the Surveillance Frequency Control Program. ##

  1. Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation. Operation may be through the test return line.
    1. Vessel injection/spray may be excluded.
      1. Credit may be taken for normal system operation to satisfy this SR.

HOPE CREEK 3/4 5-7 Amendment No. 213 xxx

ELECTRICAL POWER SYSTEMS A.C. SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and
b. Two diesel generators, one of which shall be diesel generator A or diesel generator B, each with:
1. A separate fuel oil day tank containing a minimum of 360 gallons of fuel.
2. A fuel storage system consisting of two storage tanks containing a minimum of 44,800 gallons of fuel.
3. A separate fuel transfer pump for each storage tank.

APPLICABILITY: OPERATIONAL CONDITIONS 4, 5 and*.

ACTION:

a. With less than the above required A.C. electrical power sources OPERABLE, suspend CORE ALTERATIONS, handling of recently irradiated fuel in the secondary containment, and crane operations over the spent fuel storage pool when fuel assemblies are stored therein. In addition, when in OPERATIONAL CONDITION 5 with the water level less than 22'-2" above the reactor pressure vessel flange, immediately initiate corrective action to restore the required power sources to OPERABLE status as soon as practical.
b. The provisions of Specification 3.0.3 are not applicable.
c. With one fuel oil transfer pump inoperable, realign the flowpath of the affected tank to the tank with the remaining operable fuel oil transfer pump within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and restore the inoperable transfer pump to OPERABLE status within 14 days, otherwise declare the affected emergency diesel generator (EDG}

inoperable. This variance may be applied to only one EDG at a time.

SURVEILLANCE REQUIREMENTS 4.8.1.2 At least the above required A.C. electrical power sources shall be demonstrated OPERABLE per Surveillance Requirements 4.8.1.1.1, 4.8.1.1.2, and 4.8.1.1.3, except for the requirements of 4.8.1.1.2.a.5, 4.8.1.1.2.g, 4.8.1.1.2.h.4, 4.8.1.1.2.h.5, 4.8.1.1.2.h.6, 4.8.1.1.2.h.7, 4.8.1.1.2.h.11, 4.8.1.1.2.h.13 and 4.8.1.1.2.k.2.

HOPE CREEK 3/4 8-11 Amendment No. 213 xxx

LR-N20-0060 ATTACHMENT 3 Proposed Technical Specifications Bases Changes (Mark-ups)

(For Information Only)

Proposed Technical Specifications Bases Revised Pages B 3/4 3-13 B 3/4 3-14 B 3/4 3-15 B 3/4 3-16 B3/4 5-2a B3/4 5-2b B3/4 5-2e B3/4 5-2f B3/4 5-3 B 3/4 8-1d

INSTRUMENTATION BASES 3/4.3.11 DELETED 3/4.3.12 RPV WATER INVENTORY CONTROL INSTRUMENTATION The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation.

Safety Limit 2.1.4 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded."

The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in OPERATIONAL CONDITIONS 1, 2, and 3 in TABLE 3.3.2-2, "ISOLATION ACTUATION INSTRUMENTATION SETPOINTS".and TABLE 3.3.3-2, ECCS ACTUATION INSTRUMENTATION SETPOINTS.

With the unit in OPERATIONAL CONDITION 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in OPERATIONAL CONDITIONS 4 and 5 to protect Safety Limit 2.1.4 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCO 3.5.2, RPV Water Inventory Control (WIC), and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal (RHR) subsystem and Reactor Water Cleanup (RWCU) system penetration flow path(s) on low RPV water level.

The RPV W ater Inventory Control Instrumentation supports operation of the Core Spray System (CSS) and the Low Pressure Coolant Injection (LPCI) system. The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.4 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered postulated in OPERATIONAL CONDITIONS 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered postulated in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, (e.g., seismic event, loss of normal power, or single human error). It is assumed, based on HOPE CREEK B 3/4 3-13 Amendment No. 213 xxx (PSEG Issued)

INSTRUMENTATION BASES 3/4.3.12 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION (Continued) engineering judgment, that while in OPERATIONAL CONDITIONS 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

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

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

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function-by-Function basis.

1.a, 2.a. Reactor Steam Dome Pressure - Low (Injection Permissive) Deleted Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS subsystems. This ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. W hile it is assured during Modes 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Core Spray Reactor Steam Dome Pressure - Low signals are initiated from four pressure transmitters in Divisions 1 and 2 that sense the reactor dome pressure. The LPCI Reactor Vessel Pressure - Low (Permissive) is initiated from a pressure switch downstream of each LPCI injection valve.

Four channels of Reactor Steam Dome Pressure - Low Function per associated Division for Core Spray Divisions 1 and 2, and one channel of Reactor Steam Dome Pressure - Low Function per associated LPCI injection valve are required to be OPERABLE in MODES 4 and 5 when ECCS Manual Initiation is required to be OPERABLE, since these channels support the manual initiation Function. In addition, the channels are only required when the associated ECCS subsystem is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b. Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass) Deleted The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

One flow transmitter per ECCS pump is used to detect the associated subsystems' flow rates. The logic is arranged such that each transmitter causes its associated minimum flow valve to open. The logic will close the minimum flow valve once the closure setpoint is exceeded.

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

HOPE CREEK B 3/4 3-14 Amendment No 213 xxx (PSEG Issued)

INSTRUMENTATION BASES 3/4.3.12 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION (Continued) 1.c, 2.c Manual Initiation Deleted The Manual Initiation push button channels introduce signals into the appropriate ECCS logic to provide manual initiation capability. There is one push button for each Division of low pressure ECCS.

In Core Spray Divisions 1 and 2, manual initiation is associated with each pump and valve combination; in divisions 3 and 4, manual initiation is associated with each pump only.

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons. A channel of the Manual Initiation Function (one channel per Division) is required to be OPERABLE in OPERATIONAL CONDITIONS 4 and 5 when the associated ECCS subsystems are required to be OPERABLE per LCO 3.5.2.

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

Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters (two per valve) that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. W hile four channels (two channels per valve) of the Reactor Vessel Water Level - Low, Level 3 Function are available, only two channels (all in the same valve group) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, Level 3 Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Level 3 Allowable Value (TABLE 3.3.2-2), since the capability to cool the fuel may be threatened.

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

4.a. Reactor Water Cleanup System Isolation - Reactor Vessel W ater Level - Low Low, Level 2 The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by valves that will close automatically without offsite power RPV water level prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel W ater Level - Low Low, Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water Level - Low Low, Level 2 is initiated from two channels per valve group that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per valve group) of the Reactor Vessel Water Level - Low Low, Level 2 Function are available, only two channels (all in the same valve group) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

HOPE CREEK B 3/4 3-15 Amendment No 213 xxx (PSEG Issued)

INSTRUMENTATION BASES 3/4.3.12 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION (Continued)

ACTIONS ACTION a. provides direction following determination that an instrument channel trip setpoint is less conservative than the value shown in the Allowable Values column of Table 3.3.12-2.

ACTION b a. directs taking the appropriate ACTION referenced in Table 3.3.12-1. The applicable ACTION referenced in the Table is Function dependent.

TABLE 3.3.12-1 ACTION 83 Deleted Low reactor vessel pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

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

TABLE 3.3.12-1 ACTION 84 Deleted If a Core Spray or Low Pressure Coolant Injection Pump Discharge Flow - Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection valve to ensure the pump does not overheat. If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The allowed outage time is appropriate given the ability to manually start the ECCS pumps and open the injection valves and to manually ensure the pump does not overheat.

With the ACTION and associated allowed outage time of ACTION 83 or 84 not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

TABLE 3.3.12-1 ACTION 85 RHR System Shutdown Cooling Mode Isolation, Reactor Vessel W ater Level - Low, Level 3, and Reactor Water Cleanup System Isolation, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. Immediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flowpath on low water level. If both channels are operable and placed in trip, the penetration flowpath will be isolated. Alternately, ACTION 85 requires the associated penetration flowpaths to be immediately declared incapable of automatic isolation and directs initiating action to calculate DRAIN TIME. If the instrumentation is inoperable, ACTION 85 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation and requires calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

SURVEILLANCE REQUIREMENTS 4.3.12 states that each RPV W IC actuation instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and , CHANNEL FUNCTIONAL TEST and LOGIC SYSTEM FUNCTIONAL TEST at the frequencies shown in Table 4.3.12-1.

Amendment No 213 xxx HOPE CREEK B 3/4 3-16 (PSEG Issued)

EMERGENCY CORE COOLING SYSTEM (ECCS) AND RPV WATER INVENTORY CONTROL BASES 3/4 5.2 - REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL

Background:

The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.4 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Applicable Safety Analysis:

With the unit in OPERATIONAL CONDITION 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in OPERATIONAL CONDITIONS 4 and 5 to protect Safety Limit 2.1.4 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered postulated in OPERATIONAL CONDITIONS 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as e.g.,

seismic event, loss of normal power, or a single human error). It is assumed, based on engineering judgment, that while in OPERATIONAL CONDITIONS 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

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

Limiting Condition for Operation:

The RPV water level must be controlled in OPERATIONAL CONDITIONS 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.4.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A DRAIN TIME of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.4 and can be managed as part of normal plant operation.

HOPE CREEK B 3/4 5-2a Amendment No. 213 XXX (PSEG Issued)

EMERGENCY CORE COOLING SYSTEM (ECCS) AND RPV WATER INVENTORY CONTROL BASES RPV WATER INVENTORY CONTROL (Continued)

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started to provide defense-in-depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem. A low pressure ECCS injection/spray subsystem consists of either one Core Spray System (CSS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem. Each CSS subsystem consists of two motor driven pumps, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV.

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

Applicability:

RPV water inventory control is required in OPERATIONAL CONDITIONS 4 and 5.

Requirements on water inventory control are contained in LCO 3.3.12, RPV WATER INVENTORY CONTROL INSTRUMENTATION, and LCO 3.5.2, RPV WATER INVENTORY CONTROL. RPV water inventory control is required to protect Safety Limit 2.1.4 which is applicable whenever irradiated fuel is in the reactor vessel.

Actions:

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

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur.

HOPE CREEK B 3/4 5-2b Amendment No. 213 XXX (PSEG Issued)

EMERGENCY CORE COOLING SYSTEM (ECCS) AND RPV WATER INVENTORY CONTROL BASES RPV WATER INVENTORY CONTROL (Continued)

Surveillance Requirements:

Surveillance Requirement (SR) 4.5.2.1 verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.4 and can be managed as part of normal plant operation.

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

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths.

A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, the RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

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

Insert 1 TS 4.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

B 3/4 5-2e Amendment No. 213 XXX HOPE CREEK (PSEG Issued)

Insert 1 The exclusion of a single penetration flow path, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME should consider the effects of temporary alterations in support of maintenance (rigging, scaffolding, temporary shielding, piping plugs, freeze seals, etc.). If reasonable controls are implemented to prevent such temporary alterations from causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, controls consistent with the guidance in NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 4, NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," or commitments to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

EMERGENCY CORE COOLING SYSTEM (ECCS) AND RPV WATER INVENTORY CONTROL BASES RPV WATER INVENTORY CONTROL (Continued)

SRs 4.5.2.2 and 4.5.2.3 - The minimum water level of 5 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the Core Spray System (CSS) subsystem or LPCI subsystem pumps, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CSS is OPERABLE if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CSS pumps. Therefore, a verification that either the suppression pool water level is greater than or equal to 5 inches or that a CSS subsystem is aligned to take suction from the CST and the CST contains greater than or equal to 135,000 available gallons of water, ensures that the CSS subsystem can supply the required makeup water to the RPV.

SR 4.5.2.4 - The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS initiation signal actuation. One acceptable method of ensuring that the lines are full is to vent at the high points.

SR 4.5.2.5 - Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow paths provides assurance that the proper flow path will be available for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a non-accident position provided the valve will automatically reposition in the proper stroke time.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR is modified by a note that provides an exception when an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

SR 4.5.2.6 - Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two notes. Note 1 states that T testing the ECCS injection/spray subsystem may be done through the test return recirculation line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgment.

SR 4.5.2.7 - Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

HOPE CREEK B 3/4 5-2f Amendment No. 213 XXX (PSEG Issued)

EMERGENCY CORE COOLING SYSTEM (ECCS) AND RPV WATER INVENTORY CONTROL BASES RPV WATER INVENTORY CONTROL (Continued)

SR 4.5.2.8 - The required ECCS subsystem is required to actuate on a manual initiation signal.

This surveillance verifies that a manual initiation signal will cause the required CSS subsystem or LPCI subsystem can be manually aligned and started, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPV to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions. This SR is modified by a note that excludes vessel injection/spray during the surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the surveillance.

The Surveillance Frequencies in the above SRs are controlled under the Surveillance Frequency Controlled Program REFERENCES

1. Information Notice 84-81, "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.
2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.
3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f)," August 1992.
4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.
5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.
6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

3/4.5.3 SUPPRESSION CHAMBER The suppression chamber is required to be OPERABLE as part of the ECCS to ensure that a sufficient supply of water is available to the HPCI, CSS and LPCI systems in the event of a LOCA. This limit on suppression chamber minimum water volume ensures that sufficient water is available to permit recirculation cooling flow to the core. The OPERABILITY of the suppression chamber in OPERATIONAL CONDITIONS 1, 2 or 3 is also required by Specification 3.6.2.1.

HOPE CREEK B 3/4 5-3 Amendment No. 213 XXX (PSEG Issued)

3/4.8 ELECTRICAL POWER SYSTEMS BASES (Continued) 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES, D.C. SOURCES and ONSITE POWER DISTRIBUTION SYSTEMS (Continued)

Particulate concentration should be determined in accordance with ASTM D2276, Method A, or ASTM D5452. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. The 0.8 micron filters specified in ASTM D2276 or ASTM D5452 may be replaced with membrane filters up to 3.0 microns. This is acceptable since the closest tolerance fuel filter in the HC EDGs is a five micron particle retention duplex filter on the engine driven fuel oil pump. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. The total volume of stored fuel oil contained in two or more interconnected tanks must be considered and tested separately.

The frequency of this test takes into consideration fuel oil degradation trends that indicate the particulate concentration is unlikely to change significantly between frequency intervals.

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that (1) the facility can be maintained in the shutdown or refueling condition for extended time periods and (2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

With exceptions as noted in the Hope Creek UFSAR, the surveillance requirements for demonstrating the OPERABILITY of the diesel generators comply with the recommendations of Regulatory Guide 1.9, Selection, Design, and Qualification of Diesel Generator Units Used as Standby (Onsite) Electrical Power Systems at Nuclear Power Plants," Revision 2, December, 1979, Regulatory Guide 1.108, Periodic Testing of Diesel Generator Units Used as Onsite Electrical Power Systems at Nuclear Power Plants," Revision 1, August 1977 and Regulatory Guide 1.137 Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979 as modified by plant specific analysis, diesel generator manufacturers recommendations, and Amendment 59, to the Facility Operating License, issued November 22, 1993.

SR 4.8.1.2 requires the SRs from LCO 3.8.1.1 that are necessary for ensuring the OPERABILITY of the AC sources not in OPCONs 1, 2 and 3. SRs 4.8.1.1.2.a.5, 4.8.1.1.2.g, 4.8.1.1.2.h.4, 4.8.1.1.2.h.5, 4.8.1.1.2.h.6, 4.8.1.1.2.h.7, 4.8.1.1.2.h.13 and 4.8.1.1.2.k.2. are not applicable in OPCONs 4, 5 and

  • because EDG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required. SR 4.8.1.1.2.h.11 is not required to be met because the required OPERABLE EDG(s) is not required to undergo periods of being synchronized to the offsite circuit.

HOPE CREEK B 3/4 8-1d Amendment xxx 187 (PSEG Issued)

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