Text

ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown. Markup of Current Technical Specifications (CTS)
	ML011630370
Person / Time
Site:	FitzPatrick
Issue date:	04/07/1995
From:	; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	-RFPFR, JAFP-01-0133
	Download: ML011630370 (174)
	v • d • e

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1 MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

INSERT NEW SPECIFICATION 3.4.7 Insert new Specification 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown" as shown in the JAFNPP Improved Technical Specifications.

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown DISCUSSION OF CHANGES (DOCs) TO THE

.CTS "

DISCUSSION OF CHANGES ITS: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN ADMINISTRATIVE CHANGES None TECHNICAL CHANGES - MORE RESTRICTIVE M1 A Specification (ITS 3.4.7) is being added requiring two RHR shutdown cooling subsystems to be Operable in MODE 3 with reactor steam dome pressure less than the shutdown cooling permissive pressure.

In MODE 3, the RHR shutdown cooling subsystems are not required to mitigate any events or accidents in the safety analyses.

The RHR shutdown cooling subsystems were identified as important contributors to risk reduction and, therefore, included in the JAFNPP ITS in accordance with Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Appropriate Actions and a Surveillance Requirement are also being added.

The addition of the new Specification is a more restrictive change necessary to ensure residual heat removal capability is available.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

None TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

None TECHNICAL CHANGES - RELOCATIONS None Page 1 of 1 JAFNPP Revi si on A

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

NO SIGNIFICANT HAZARDS CONSIDERATION ITS: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

There are no plant specific less restrictive changes identified for this Specification.

Page 1 of 1 Revi si on A JAFNPP

RHR Shutdown Cooling System-Hot Shutdown 3.4p 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4,$

Residual Heat Removal (RHR)

Shutdown Cooling System-Hot Shutdown LCO 3.4.4)

Two RHR shutdown cooling subsystems shall be OPERABL aa

/w~ith nou pecruIFE4111on pang i a, 'Itio.,

o-,:....

t One RHR shutdown cooling subsystem may be inoperable frup to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

NT#--------------------------

)

APPLIABILTY:

MODE 3, with reactor steam dome pressure *the RiIR cut in permissive pressurSei ACT IONS NOTES

1.

LCO 3.0.4 is not applicab

2.

Separate Condition entry subsystem.

- -NOTES---

le.

is allowed for each RHR shutdown cooling CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable, cooling subsystem(s) to OPERABLE status.

AN(

(continued) 3.4-18 Tt, P.

A%1 e0je T W e 07"V Amemlwel't

RiR Shutdown Cooling System-Hot Shutdown 3.4ýý At?1'flU

gy I LUI.J CONDITION REQUIRED ACTION COIMPLETION TIME A.

(continued)

A.2 Verify an alternate I hour method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

A.3 Be in MODE 4.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. No RHR shutdown cooling subsystem in operation.

AND No recirculatio pump in operation.

Initiate action to restore one RHR shutdown cooling reiruato pumpAto recircul ation pumpt operation.

AND B.2 Verify reactor coolant circu tion by an altern e method.

AND B.3 Mon tor reactor co ant temperature a pressure.

I diately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of no reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Once per hour Rev 1, 04/07/95 BWR/4 STS

/B1 I

I 3.4-19

RHR Shutdown Cooling System-Hot Shutdown R

Rev 1, 04/07/95 3.4-20 BWR/4 STS

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 The requirement in ISTS LCO 3.4.8 (ITS LCO 3.4.7) associated with a recirculation pump or RHR shutdown cooling subsystem being in operation has been deleted.

The requirement that two RHR shutdown cooling subsystems are Operable is considered acceptable.

Requirements for RHR shutdown cooling subsystem operations are adequately controlled by JAFNPP plant operating procedures and policies.

There are no explicit requirements in the CTS for RHR shutdown cooling subsystem operability or that a recirculation pump should be in operation in Hot Shutdown.

However, ITS SR 3.4.9.1 will require the reactor coolant temperature to be monitored during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing while SR 3.4.9.2 will require these readings to be taken during a planned startup where the reactor will achieve criticality.

These SRs will necessitate placing either the recirculation pump or a RHR shutdown cooling subsystem in service to ensure circulation for temperature monitoring or cooling.

The RHR shutdown cooling subsystems remove decay heat to reduce temperature of the reactor coolant to < 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or for maintaining the reactor stable in the Hot Shutdown conditions.

Therefore, an RHR shutdown cooling subsystem will normally be in operation when a cooldown is in progress or to maintain reactor coolant temperature.

Without it an alternate will be necessary to achieve the plant objective.

During a heatup, the recirculation pumps will normally be in operation to ensure circul ation and temperature monitoring.

If plant conditions are maintained operations will consider the situation but normally either the recirculation pump will be in service or an RHR shutdown cooling subsystem will in operation to ensure adequate temperature monitoring.

This will ensure the plant objective is being met and to ensure the core is in a safe condition.

JAFNPP is operated in Hot Shutdown, in a safe manner to ensure decay heat is removed so that no core damage could result, therefore the system is normally continuously operated during these conditions.

The requirements in ISTS LCO 3.4.8 are not needed since the Surveillances in ITS 3.4.9 will clearly require temperature monitoring capability and this is accomplished with either any RHR shutdown cooling subsystem or recirculation pump in operation.

Furthermore, to be consistent with this modification, the allowances in ISTS LCO 3.4.7 Note 1 that both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, the requirements in ISTS 3.4.8 ACTION B for no RHR shutdown cooling subsystem and no recirculation pump in operation have been deleted.

ISTS SR 3.4.8.1 (ITS SR 3.4.7.1) requires the verification that one RHR shutdown cooling subsystem or recirculation pump is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the requirement to be in Page 1 of 2 JAFNPP Revision A

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 (continued) operation has been deleted this SR has been revised to verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is aligned or can be aligned to its correct position every 31 days.

The Frequency is consistent with similar Surveillances in other LCOs and is considered adequate for this condition.

In Hot Shutdown, the RHR shutdown cooling system is of prime focus of plant operations and since the controls for this system are in the control room the Frequency is considered adequate.

This Frequency is consistent with the same type of Surveillance in other LCOs ( e.g.,

ITS 3.5.1).

PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl NUREG-1433 Specification 3.4.5, "RCS Pressure Isolation Valve (PIV)

Leakage", is not incorporated in ITS.

Subsequent ITS Specifications and Bases have been renumbered accordingly.

PA2 Editorial change to maintain consistency with Restructured Technical Specifications.

PA3 The brackets have been removed and the proper nomenclature has been provided.

the Writer's Guide for the pl ant speci fic P1 ANT SPFCTFTCi flTFFFRENCF TN DFST(N AR flFSTN None DIFFERENCE BASED ON APPROVED TRAVELER (TA)

None DIFFERENCE BASED ON PENDING TRAVELER (TP)

None DIFFERENCE FOR OTHER REASONS THAN ABOVE (X)

None Page 2 of 2 RAqTq (fnR PLN SPCII DIFREC IN DEIG OR*

DESIGN*

mIV gl*V

@WV.

V*..

U*

JAFNPP Revision A

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown MARKUP OF NUREG-1433, REVISION 1, BASES

RiR Shutdown Cooling System-Hot Shutdown B 3.4*

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.41 Residual Heat Removal (RHR)

Shutdown Cooling System-Hot Shutdown BASES BACKGROUND Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant.

This decay heat must be

~L~.j~mped to reduce the temperature of the reactor coolant to Q*

T F

s in preparation for pe rming fuelini maintenanlceoperations5, or W

~

the actor n thHo ut condition.Al The two redundant, manually controlled shutdown cooling foo subsystem-51of the RHR System provide decay heat removal.

Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves.

Both loo s have a comon suction from the sam recirculation oap.

Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via

)

t e assocea recirculation loop.

The RHR heat exchangers transfer heat to the RHR Service Water System (LCO 3.7.1,

'Resdual Heat Removal Service Water (RHRSW) System").

APPLICABLE SAFETY ANALYSES LCO Decay heat removal by operation of the RHR System in the shutdown cooling mode is not required for mitigation of any event or accident evaluated in the safety analyses Decay heat removal is, however, an important safety fIn'm must be accomplished or core damage could result./&

Ahe RHR shutdown cooling subsystem mee Two RHR shutdown cooling subsystems are required to be OPERABLE RHR shutdown cooling subsystem consists of one OPERABLE RHR pump, one heat exchanger, and the associated piping and valves.

The two subsystems have a common suction source and are allowed to have a common heat exchanger and (continued) 4e.

A ll B 3.4-37 4~JP (c 0tnud

RHR Shutdown Cooling System-Hot Shutdoi B 3.4

('7, 7

LL ý,

ýfz -seý-rJe "W(

4-.r

ý-4Ai M1 BASES comon dscharge piping. Thus, to meet the LCO, both pumpsf in one loopi'or onr~e' -pu n each of the two loopsmust be OPERABLE.

Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems.

Each shutdown cooling subsyste is considered OPERABLE if it can be manually aligned jtEiWNjL 161M) in the shutdown cooling mode for removal of decay heat.

In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy.

Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Note I permits th RHR shutdown cooling s ystems to t0 shutdownfoa neried of 2 hnuri in an

.our -eriodi4'tlote wallows one RHR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some oelant system or component that necessitates placing tliRHRIM Lm in an inoperable status during the performance.

This is permitted because the core heat generation can be low enough and the heatup rate/l ow enough a,

0 st or^?L P..r 1::,

to _al ow some cnangg'ees to te Ilsubsystems or/ttherw operations requfring loss of redundancy.

I r

,e p,;..r I

MJ In MODE 3 with reactor steam/domepressure below

-- Min permissive pressuremj( i.e., the actual pre

-which thelinterlock s----)ethe RHRSystemXUT"Nw in the shutdown cooling e to remove decay heal or maintain coolant temperature.

Otherwise, a r pump It-ný In MODES 1 and 2, and in MODE 3 with rea or steam dome pressure-greater than or equal to fthe RHR cutf pressures; this LCO is not applicable.

Operation of System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping.

Decay heat removal at reactor pressures greater than or equal to the RHR cut in permissive pressure is typically accomplished by condensing (continued)

Rev 1, 04/07/95 BWR/4 STS 8 3.4-38 7*. tav A-.

/

0 h

l'

RHR Shutdown Cooling System-Hot Shutdown B 3. 4 BASES APPLICABILITY (continued)

ACTIONS the steam in the main condenser.

Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS)

(LCO 3.5.1, "ECCS-Operating') do not allow placing the RHR shutdown cooling subsystem into operation.

Ph The requirements forecay heat removal in NODES 4 and 5 are discussed in LCO 3.4 w,'Residual Heat Removal (R R) 1 Shutdown Cooling System-Cold Shutdown'; LCO 3.9.';

"Residual Heat Removal (RHR)-High Water Level'; and LCO 3.9.9, Residual Heat Removal (RHR)-Low Water Level.'

A Note to the ACTIONS excludes the MODE change restriction of LCO 3.0.4.

This exception allows entry into the applicable MODE(S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown.

This exception is acceptable due to the redundancy of the OPERABLE subsystems, the low pressure at which the plant is operating, the low probability of an event occurring during operation in this condition, and the availability of alternate methods of decay heat removal capability.

A second Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems.

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems.

As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1. A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by1CO Note 0, the inoperable subsystem must be restored to OPERABLE status (continued)

Rev 1, 04/07/95 BWR/4 STS B 3.4-39

RHR Shutdown Cooling System-Hot Shutdown B 3.4r BASES ACTIONS A.I. A.2. and A.3 (continued) without delay.

In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal.

The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability.

Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heatl removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration)

S 1its capability to maintain or reduce temperature.

Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to)

;*(0,**o*

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required cwfl P*J to reduce the reactor coolant temperature to the point where sew dr(.. 45A NODE 4 is entered.

e 6.V

-,1.

B.2-_and__. 3 tret~

iwef s

va With no RHR shutdown *ooltng subsystem and no re ~rculation\\

pump in operation, ecept as permitted by LCO Ite 1,

reactor coolant ci lation by the RHR shutdo cooling subsystem or recti tlation pump must be restored without UtlRHR or r cltion pump operation reetablished, an alternate 14hod of reactor coolant cir Ulaton must be placed into s ice.

This will provide t e necessary circvulation monitoring coolant temper ture.

The

(

hour Completion TrMe vis based on the coolant circulation function (continued)

Rev 1, 04/07/95 BWR/4 STS 8 3.4-40

RHR Shutdown Cooling System-Hot Shutdo V

B 3.

BASES ACTIONS

2. a (continued) and is modifi such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is app icable separately fo each occurrence involving a ass of coolant circulation.

Furthermore, verification oa the functioning of the alt ate method must be reconfi d every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafte.

This will provide assuran *of continued temperat e monitoring capability.

During he period when the reactor c olant is being circul ted by an alternate method (

her than by the requt RHR shutdown cooling subs tem or recirculat* n p

, the reactor coolant temper ure and pressure st be per odically monitored to ensure roper function of he al ernate method.

The once per our Completion Time is deemed appropri ate.

SURVEILLANCE REQUIREMENTS This Surveillance erifies that one RHR sh adown cooling subsystem or rec ulation pump is in ope ation and

/,1 circulating rea r coolant.

The requir d flow rate is determined by e flow rate necessary t provide suffi ent decay heat val capability.

The F quency of 12 urs is sufficient i view of other visual an audible indic tions St

( ~?

available t the operator for monito ing the RHR su system in the con 1 room.

This Surveillance is modified by a Note allowing su icient L

time to Q

RHR S shutdown cooling after clearing the pressure interlock that isolates the syst TWTDM yers A100 The Note takes exception to the requirements of the Surveillance being met (L.e.,

o not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period), which also Sallows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met' at the time of entry into the Applicability.

BREFERENTS

ýý c-es B 3.441.

Rev 1, 4/0/

B 3.4-41 Rev 1, 04/07/95 BWRI4 STS

INSERT SR 3.4.7.1 LIi Verifying the correct alignment for manual, power operated, and automatic valves in the RHR shutdown cooling flow path provides assurance that the proper flow paths will exist for RHR operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing.

A valve that can be manually (from the control room or locally) aligned is allowed to be in a non-RHR shutdown cooling position provided the valve can be repositioned.

This SR does not require any testing or valve manipulation: rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days.

The Frequency of 31 days is further justified because the valves are operated under procedural control.

This Frequency has been shown to be acceptable through operating experience.

Insert Page B 3.4-41

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1

-ITS BASES: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 The requirement in ISTS LCO 3.4.8 (ITS LCO 3.4.7) associated with a recirculation pump or RHR shutdown cooling subsystem being in operation has been deleted.

The requirement that two RHR shutdown cooling subsystems are Operable is considered acceptable.

Requirements for RHR shutdown cooling subsystem operations are adequately controlled by JAFNPP plant operating procedures and policies.

There are no explicit requirements in the CTS for RHR shutdown cooling subsystem operability or that a recirculation pump should be in operation in Hot Shutdown.

However, ITS SR 3.4.9.1 will require the reactor coolant temperature to be monitored during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing while SR 3.4.9.2 will require these readings to be taken during a planned startup where the reactor will achieve criticality. These SRs will necessitate placing either the recirculation pump or a RHR shutdown cooling subsystem in service to ensure circulation for temperature monitoring or cooling.

The RHR shutdown cooling subsystems remove decay heat to reduce temperature of the reactor coolant to < 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or for maintaining the reactor stable in the Hot Shutdown conditions.

Therefore, an RHR shutdown cooling subsystem will normally be in operation when a cooldown is in progress or to maintain reactor coolant temperature.

Without it an alternate will be necessary to achieve the plant objective.

During a heatup. the recirculation pumps will normally be in operation to ensure circulation and temperature monitoring.

If plant conditions are maintained operations will consider the situation but normally either the recirculation pump will be in service or an RHR shutdown cooling subsystem will in operation to ensure adequate temperature monitoring.

This will ensure the plant objective is being met and to ensure the core is in a safe condition.

JAFNPP is operated in Hot Shutdown, in a safe manner to ensure decay heat is removed so that no core damage could result, therefore the system is normally continuously operated during these conditions.

The requirements in ISTS LCO 3.4.8 are not needed since the Surveillances in ITS 3.4.9 will clearly require temperature monitoring capability and this is accomplished with either any RHR shutdown cooling subsystem or recirculation pump in operation.

Furthermore, to be consistent with this modification, the allowances in ISTS LCO 3.4.7 Note 1 that both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, the requirements in ISTS 3.4.8 ACTION B for no RHR shutdown cooling subsystem and no recirculation pump in operation have been deleted.

ISTS SR 3.4.8.1 (ITS SR 3.4.7.1) requires the verification that one RHR shutdown cooling subsystem or recirculation pump is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the requirement to be in Page 1 of 3 Revision A JAFNPP

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 (continued) operation has been deleted this SR has been revised to verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is aligned or can be aligned to its correct position every 31 days.

The Frequency is consistent with similar Surveillances in other LCOs and is considered adequate for this condition.

In Hot Shutdown, the RHR shutdown cooling system is of prime focus of plant operations and since the controls for this system are in the control room the Frequency is considered adequate.

This Frequency is consistent with the same type of Surveillance in other LCOs ( e.g.,

ITS 3.5.1).

PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl NUREG-1433 Specification 3.4.5. "RCS Pressure Isolation Valve (PIV)

Leakage," is not incorporated in ITS.

Subsequent ITS Specifications and Bases have been renumbered accordingly.

PA2 The Bases have been revised to be consistent with changes made to the Specifications.

PA3 Editorial changes have been made for enhanced clarification, correction, or improvement with no change in intent.

PA4 The Bases have been modified to reflect plant specific terminology.

PA5 The correct LCO number has been included.

PLANT SPECIFIC DIFFERENCE IN DESIGN OR DESIGN BASIS (DB)

DB1 The Bases have been modified to reflect JAFNPP specific References.

DB2 The Bases have been revised to reflect the JAFNPP specific design.

DIFFERENCE BASED ON APPROVED TRAVELER (TA)

None Page 2 of 3 Revision A JAFNPP

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.4.7 - RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN DIFFERENCE BASED ON PENDING TRAVELER (TP)

None DIFFERENCE FOR OTHER REASONS THAN ABOVE (X)

X1 NUREG-1433, Revision 1. Bases references to "the NRC Policy Statement" has been replaced with 10 CFR 50.36(c)(2)(ii), in accordance with 60 FR 36953 effective August 18, 1995.

Page 3 of 3 Revision A JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO

3.4.7 APPLICABILITY

Two RHR shutdown cooling subsystems shall be OPERABLE.

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

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

MODE 3, with reactor steam dome pressure less than the RHR cut in permissive pressure.

ACTIONS

..-.--- NOTES -----------------------------------

1.

LCO 3.0.4 is not applicable.

2.

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable, cooling subsystem(s) to OPERABLE status.

AND A.2 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

AND A.3 Be in MODE 4.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Amendment 3.4-14 JAFNPP

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 SR 3.4.7.1 I

SURVEILLANCE

---.NOTE -------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is aligned or can be aligned to its correct position.

Amendment CIIDUIPTI I AMIM DrnI ITDOMPINTq FREQUENCY 31 days 3.4-15 JAFNPP

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown BASES BACKGROUND APPLICABLE SAFETY ANALYSES LCO Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant.

This decay heat must be removed to reduce the temperature of the reactor coolant to s 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or the decay heat must be removed for maintaining the reactor in the Hot Shutdown condition.

The two redundant, manually controlled shutdown cooling subsystems (loops) of the RHR System provide decay heat removal.

Each loop consists of two motor driven pumps, a heat exchanger, and associated piping and valves.

Both loops have a common suction from the same reactor water recirculation loop.

Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via the associated reactor water recirculation loop.

The RHR heat exchangers transfer heat to the RHR Service Water System (LCO 3.7.1, "Residual Heat Removal Service Water (RHRSW) System").

Decay heat removal by operation of the RHR System in the shutdown cooling mode is not required for mitigation of any event or accident evaluated in the safety analyses (Ref. 1).

Decay heat removal is, however, an important safety function that must be accomplished or core damage could result.

The RHR shutdown cooling subsystem meets Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).

Two RHR shutdown cooling subsystems are required to be OPERABLE.

An OPERABLE RHR shutdown cooling subsystem consists of one OPERABLE RHR pump, one heat exchanger, and the associated piping and valves.

The two subsystems have a common suction source and are allowed to have a common heat exchanger and common discharge piping.

Thus, to meet the LCO, both RHR pumps (and two RHR service water pumps) in one loop or one RHR pump (and one RHR service water pump) in (continued)

Revision 0 B 3.4-35 JAFNPP

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES LCO (continued) each of the two loops must be OPERABLE.

Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems.

Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (from the control room or locally) in the shutdown cooling mode for removal of decay heat.

In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy.

Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

The Note allows one RHR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR shutdown cooling subsystems in an inoperable status during the performance.

This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR shutdown cooling subsystems or other operations requiring loss of redundancy.

APPLICABILITY In MODE 3 with reactor steam dome pressure below the RHR cut-in permissive pressure (i.e., the actual pressure at which the shutdown cooling suction valve isolation logic interlock resets (Function 6.a of LCO 3.3.6.1. Primary Containment Isolation Instrumentation)) the RHR System is required to be OPERABLE so that it may be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature.

Otherwise, a recirculation pump is normally in operation to circulate coolant to provide for temperature monitoring.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR cut-in permissive pressure, this LCO is not applicable.

Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping.

Decay heat removal (continued)

Revision 0 B 3.4-36 JAFNPP

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES APPLICABILITY at reactor pressures greater than or equal to the RHR cut in (continued) permissive pressure is typically accomplished by condensing the steam in the main condenser.

Additionally, in MODE 2 below this pressure. the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS)

(LCO 3.5.1.

"ECCS-Operating") do not allow placing the RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR)

Shutdown Cooling System-Cold Shutdown": LCO 3.9.7.

"Residual Heat Removal (RHR)-High Water Level": and LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level."

ACTIONS A Note to the ACTIONS excludes the MODE change restriction of LCO 3.0.4.

This exception allows entry into the applicable MODE(S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown.

This exception is acceptable due to the redundancy of the OPERABLE subsystems, the low pressure at which the plant is operating, the low probability of an event occurring during operation in this condition, and the availability of alternate methods of decay heat removal capability.

A second Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems.

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems.

As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

(continued)

Revision 0 JAFNPP B 3.4-37

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES ACTIONS (continued)

A.1, A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by the LCO Note, the inoperable subsystem must be restored to OPERABLE status without delay.

In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal.

The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature.

Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to) the Condensate and Main Steam Systems, Reactor Water Cleanup System (by itself or using feed and bleed in combination with the Control Rod Drive System or Condensate System), or a combination of an RHR pump and safety/relief valve(s).

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor coolant temperature to the point where MODE 4 is entered.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR shutdown cooling flow path provides assurance that the proper flow paths will exist for RHR operation.

This SR does not apply to valves that are (continued)

Revision 0 B 3.4-38 JAFNPP

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES SURVEILLANCE SR 3.4.7.1 (continued)

REQUIREMENTS locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing.

A valve that can be manually (from the control room or locally) aligned is allowed to be in a non-RHR shutdown cooling position provided the valve can be repositioned.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days.

The Frequency of 31 days is further justified because the valves are operated under procedural control.

This Frequency has been shown to be acceptable through operating experience.

This Surveillance is modified by a Note allowing sufficient time to verify RHR shutdown cooling subsystem OPERABILITY after clearing the pressure interlock that isolates the system.

The Note takes exception to the requirements of the Surveillance being met (i.e., valves are aligned or can be aligned is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period),

which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

REFERENCES

1.

UFSAR. Chapter-14.

2.

10 CFR 50.36(c)(2)(ii).

Revision 0 JAFNPP B 3.4-39

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

DISCUSSION OF CHANGES (DOCs) TO THE CTS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

FOR LESS RESTRICTIVE CHANGES MARKUP OF NUREG-1433, REVISION 1, SPECIFICATION JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION I MARKUP OF NUREG-1433, REVISION 1, BASES JUSTIFICATION FOR DIFFERENCES (JFDs) FROM NUREG-1433, REVISION 1, BASES RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS)

New Specification 3.4.8 Insert new ITS Specification 3.4.8, "Residual Heat Removal (RHR)

Shutdown Cooling System-Cold Shutdown" as shown in the JAFNPP Improved Technical Specifications.

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown DISCUSSION OF CHANGES (DOGs) TO THE CTS 1.

DISCUSSION OF CHANGES ITS: 3.4.8 - RHR SHUTDOWN COOLING SYSTEM-COLD SHUTDOWN ADMINISTRATIVE CHANGES None TECHNICAL CHANGES - MORE RESTRICTIVE M1 A Specification (ITS 3.4.8) is being added requiring two RHR shutdown cooling subsystems to be Operable in MODE 4.

In MODE 4. the RHR shutdown cooling subsystems are not required to mitigate any events or accidents in the safety analyses.

The RHR shutdown cooling subsystems were identified as important contributors to risk reduction and, therefore, included in the JAFNPP ITS in accordance with Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Appropriate Actions and a Surveillance Requirement have also been added.

The addition of the new Specification is a more restrictive change necessary to ensure residual heat removal capability is available.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

None TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

None TECHNICAL CHANGES - RELOCATIONS None Page 1 of 1 JAFNPP Revi si on A

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

NO SIGNIFICANT HAZARDS CONSIDERATION ITS: 3.4.8 - RHR SHUTDOWN COOLING SYSTEM-COLD SHUTDOWN TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

There are no plant specific less restrictive changes identified for this Speci fi cati on.

Page 1 of 1 Revi si on A JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION

RHR Shutdown Cooling System-Cold Shutdown 3.4$

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.§ sidual eat Removal (RHR)

Shutdown Cooling System-Cold Shutdown LCO 3.4Two RHR shutdown cooling subsystems shall be OPERABLE a

Ttur-no recirculptlon pump rn0per atL R

Vqhutdown cooliA subsystem sWll bein oerat' W "

Le @

coollng smusysr ved from operat;

__*.o_*0ne RHR shutdown cooling subsystem may be inoperable e1for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY:

MODE 4.

ACTIONS NOTE Seonarate Condition entry is allowed for each shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems inoperable, removal is available ANM for each inoperable RHR shutdown cooling Once per subsystem.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

Alt 3.4-21 vwT W

euc(wetzl

System-Cold Shutdown 3.4jý L ACTIONS continued

.R&nrTTAu LýIU MI auiý 1~~~

I I/

__________________________*q. ---------

B.

No RHR shutdown cooling subsystem operation.

SAND No recirculation in operation.

/

in ump B.1 Verify reactor coolant circulating by an alternate B.2 Monlt cooli

d.

or reactor knt temperatur C

LETION TIME

/hour from iscovery of no reactor coolant circulation Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Once per hour Rev 1, 04/07/95 BWR/4 STS ca5I metho RNR Shutdown cooling REQUIRED ACTION WWlUIUI 3.4-22

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.4.8 - RHR SHUTDOWN COOLING SYSTEM-COLD SHUTDOWN RETENTION OF EXISTING REQUIREMENt (CLB)

CLB1 The requirement in ISTS LCO 3.4.9 (ITS LCO 3.4.8) associated with a recirculation pump or RHR shutdown cooling subsystem being in operation has been deleted.

The requirement that two RHR shutdown cooling subsystems are Operable is considered acceptable.

Requirements for RHR shutdown cooling subsystem operations are adequately controlled by JAFNPP plant operating procedures and policies.

There are no explicit requirements in the CTS for RHR shutdown cooling subsystem operability or that a recirculation pump should be in operation in Cold Shutdown.

However, ITS SR 3.4.9.1 will require the reactor coolant temperature to be monitored during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing while SR 3.4.9.2 will require these readings to be taken during a planned startup where the reactor will achieve criticality.

These Surveillance will necessitate placing either the recirculation pump or a RHR shutdown cooling subsystem in service to ensure circulation for temperature monitoring or cooling.

The RHR shutdown cooling subsystems remove decay heat to reduce temperature of the reactor coolant to < 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or for maintaining the reactor stable in the Cold Shutdown conditions.

Therefore, an RHR shutdown cooling subsystem will normally be in operation when a cooldown is in progress or to maintain reactor coolant temperature.

Without it an alternate will be necessary to achieve the plant objective.

During a heatup, the recirculation pumps will normally be in operation to ensure circulation and temperature monitoring.

If the plant is maintaining plant conditions the plant will consider the situation but normally either the recirculation pump will be in service or an RHR shutdown cooling subsystem will in operation to ensure adequate temperature monitoring.

This will ensure the plant objective is being met and to ensure the core is in a safe condition.

JAFNPP is operated in Cold Shutdown, in a safe manner to ensure decay heat is removed so that no core damage could result, therefore the system is normally continuously operated during these conditions.

The requirements in ISTS LCO 3.4.9 are not needed since the Surveillances in ITS 3.4.9 will clearly require temperature monitoring capability and this is accomplished with either one RHR shutdown cooling subsystem or one recirculation pump in operation.

Furthermore, to be consistent with this modification, the allowances in ISTS LCO 3.4.9 Note 1 that both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, the requirements in ISTS 3.4.9 ACTION B for no RHR shutdown cooling subsystem and no recirculation pump in operation have been deleted.

ISTS SR 3.4.9.1 (ITS SR 3.4.8.1) requires the verification that one RHR shutdown cooling subsystem or recirculation pump is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the requirement to be in Page 1 of 2 Revision A JAFNPP

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.4.8 - RHR SHUTDOWN COOLING SYSTEM-COLD SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 (continued) operation has been deleted this SR has been revised to verify each required RHR shutdown cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is aligned or can be aligned to its correct position every 31 days.

The Frequency is consistent with similar Surveillances in other LCOs and is considered adequate for this condition.

In Cold Shutdown, the RHR shutdown cooling system is of prime focus of plant operations and since the controls for this system are in the control room the Frequency is considered adequate.

This Frequency is consistent with the same type of Surveillance in other LCOs

( e.g., ITS 3.5.1).

PLANT SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl NUREG-1433 Specification 3.4.5, "RCS Pressure Isolation Valve (PIV)

Leakage," is not incorporated in ITS.

Subsequent ITS Specifications and Bases have been renumbered accordingly.

PLANT SPECIFIC DIFFERENCE IN DESIGN OR DESIGN BASIS (DB)

None DIFFERENCE BASED ON APPROVED TRAVELER (TA)

None flTFFFRFNCF BASED ON PENDING TRAVELER (TP)

None DIFFERENCE FOR OTHER REASONS THAN ABOVE (X)

None Page 2 of 2 DIFFERENCE Revision A JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown MARKUP OF NUREG-1433, REVISION 1, BASES

RHR Shutdown Cooling System-Cold Shutdow n B 34 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4&) Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown BACKGROUtmperrdatefurel of the sudw reactor coolr.Ti eca heneratmust bhea ved to maintain the temperature of the reactor cool an Z%

FI 11in preparation for "Dpe armin reulnoeains, or 4M

~~ the reactor-in the Cold Shutdown condition.

The two redundant, manually controlled shutdown cooling sub ss ems of the RPIR System provide decay heat removal.

PAX Each loop consists of two motor driven pumps, a heat I

exchanger, and associated piping and valves.

Both loops have a common suction from the same recirculation lop Each pump discharges the reactor coolant, after circulation gh the respective heat exchanger, to the reactor via irecirculaton loop.

The RHR heat exchangers

"s Service Water System.

4,~~

rl NýtII APPLICABLE SAFETY ANALYSES Decay heat removal by operation of the RHR System in the shutdown cooling mode is not required for mitigatoi of any event or accident evaluated in the safety analyses.

Decay heat removal is, however, an important safety funcJn-that mist be accomplished or core damage could result./. ]

LCO Two RHR shutdown cooling subsystems are required to be E

OPERABLE RHR shutdown cooling subsystem consists of one p~(p,d*OERABLE RHR pump, one _he`tUFr

.qr`ýand the associated.

3 piping and valves.

The two subsystems have a common suction 6.44-4; *source and are allowed to have a common heat exchanger and Sh*exý ev 0

As common discharge piping.

Thus, to meet the LCO, both pumps jala44(continued)

B 3.4-42 zw 5

oi 14 V.

All) pole T eL4 dýý 4&D

RHR Shutdown Cooling System-Cold Shutdown 8.44 '

BASES LCO in one lool~or oneipumpin each of the two loops must be (continued)

OPERABLE.

Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems.

In MODE 4, the RHR cross tie v e (

1I-V may be opened to allow pumps in one loop vdiJ

\\ies 0 Mo0\\ -20 6

ischarge through the opposite recirculation loop to make

/

-Oat) a complete subsystem.

Additionally, each shutdown cooling subs st is considered OPERABLE if it can be manually a gned e

in the shutdown cooling mode for removal of decay heat.

In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide Cc -oL roo"*

/

redundancy.

Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

OY IOC.4"(Ij However, to ensure adequate core flow to allow for accurate S-average reactor coolant temperature monitoring, nearly continuous operation is required.

ote I permIttboth RHR s utdown coo n

sso he

[sut down fat1-mb -A of* 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months tia I hou~rpr*I Note<allows one RJR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some other plant system or c onen k*,

necessitates placing the RHR n an noperable status during the performance.

This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RH subsystems or other operations requiring loss-of redundancy.

(-LBI);

APPLICABILITY In NODE 4, the RHR-,.--e*:*.y in the shutdown cooling mode to remove maintain coolant te erature below0 recirculation pu-s--

__OM In NODES I and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR cut in permissive pressure, this LCO is not applicable.

Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping.

Decay heat removal at reactor pressures greater than or equal to the RHR cut in permissive pressure is typically accomplished by condensing (continued)

W V c-01 Rev 1, 04/07/95 B 3.4-43 BWR14 STS

RHR Shutdown Cooling System-Cold Shutdown B 3.

BASES APPLICABILITY the steam in the main condenser.

Additionally, in MODE 2 (continued) below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS)

(LCO 3.5.1, "ECCS-Operating') do not allow placing the RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODE 3 below the cut in ermissive pressure and in MODE 5 are discussed in "Residual Heat Removal (RHR)

Shutdown Cooling System-Hot Shutdown'; LCO 3.9.D, §Residual Heat Removal (RHR)-High Water Level"; and (LO 3.9A 'Residual Heat Removal (RHR)-Low Water Level.

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems.

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition.

Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems.

As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

With one of the two required RHR shutdown cooling subsystems inoperable, except as permitted by LCO Note 0, the remaining subsystem is capable of providing the required decay heat removal.

However, the overall reliability is reduced.

Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

Rev 1, 04/07/95 B 3.4-44 B'dR/4 STS

RHR Shutdown Cooling System-Cold Shutdown BASES ACTIONS Ad.

(continued)

Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature.

Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to) ooWplv-1-oo I nsolystem ano atJReaca ae, 4o~jyA& L OI=IUC*

With no RI4R shutdop cooling subsystem and no re irculation o'

pump in operation except as permitted by CO te 1, and ck ) ountil RHR or re rculation pump operation tisc established, alternate mohed of reactor coolant circulation must be PV TL u

placed into s ice.

This will provide the ecessary 5

rcirculation f r monitoring coolant tempera re. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months V-'

(Completion T

is based on the coolant c ulation function and is aodit ed such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is plicable separately or each occurrence involving a loss of coolant circulattoV. Furthermore, verification f the functioning of the al broate method must be reconfi every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereaft This will provide assuranc of continued tempera re monitoring capability.

Durin the period when the reactor co ant is being circu ated by an alternate method (o er than by the requ red RHR $hutdownCooling Syst or recirculatio pump),

the eactor coolant temperature an pressure must pe odically monitored to ensure oper function-o the a ernate method.

The once per h ur Completion T is emed appropriate.

(continued)

Rev 1, 04/07/95 8 3.4-45 BWR/4 STS

RHR Shutdown Cooling System--Cold Shutdown Arl B3.44.

BASES (conti nued)

SURVEILLANCE MM REQUIREMENTS i

This Surveillance veife-s--that-one PPRHR sht~own cool ing*

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subsystem or rectji lation pump is an opr n and

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~~circulating reacto/ coolant.

The requiredfo rue s

determined by th flow rate necessary to 4rovtde sufficient decay heat reso 1l capability.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is

'J suffficient in yew of other visual and audible indications available to *e operator for mmonittoria the RHR subsysteV

_the contq ro of' REFERENCES Rev 1, 04/07/95 B 3.4-46 BWR/4 STS

C1 Insert SR 3.4.8.1 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR shutdown cooling flow path provides assurance that the proper flow paths will exist for RHR operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing.

A valve that can be manually (from the control room or locally) aligned is allowed to be in a non-RHR shutdown cooling position provided the valve can be repositioned.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days.

The Frequency of 31 days is further justified because the valves are operated under procedural control.

This Frequency has been shown to be acceptable through operating experience.

Insert Page B 3.4-46

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433.

REVISION 1 ITS BASES: 3.4.8 - RHR SHUTDOWN COOLING SYSTEM-COLD SHUTDOWN RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 The requirement in ISTS LCO 3.4.9 (ITS LCO 3.4.8) associated with a recirculation pump or RHR shutdown cooling subsystem being in operation has been deleted.

The requirement that two RHR shutdown cooling subsystems are Operable is considered acceptable.

Requirements for RHR shutdown cooling subsystem operations are adequately controlled by JAFNPP plant operating procedures and policies.

There are no explicit requirements in the CTS for RHR shutdown cooling subsystem operability or that a recirculation pump should be in operation in Cold Shutdown.

However, ITS SR 3.4.9.1 will require the reactor coolant temperature to be monitored during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing while SR 3.4.9.2 will require these readings to be taken during a planned startup where the reactor will achieve criticality.

These Surveillance will necessitate placing either the recirculation pump or a RHR shutdown cooling subsystem in service to ensure circulation for temperature monitoring or cooling.

The RHR shutdown cooling subsystems remove decay heat to reduce temperature of the reactor coolant to ' 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations, or for maintaining the reactor stable in the Cold Shutdown conditions.