Text

ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIV
	ML011630394
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: ML011630394 (149)
	v • d • e

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

NO-SIGNIFICANT HAZARDS CONSIDERATIONS iTS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

Does the change involve a si'gni fi cant increase in the probability or consequences of an accident previously evaluated?

The phrase "actual or," in reference to the automatic initiation signal.

has been added to the system functional test surveillance test description.

This does not impose a requirement to create an "actual" signal, nor does it eliminate any restriction on producing an "actual" signal.

This change would allow an actual signal to be credited when evaluating the acceptance criteria for the system functional test requirements.

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

Since the method of initiation will not affect the acceptance criteria of the system functional test, the change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

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

The possibility of a new or.,different kind of accident from any accident previously evaluated is notkcreated because the proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant.

3.

Does this change involve a significant reduction in a margin of safety?

Use of an actual signal instead of the existing requirement, which limits use to a simulated signal, will not affect the performance or acceptance criteria of the surveillance test. Operability is adequately demonstrated in either case since the system itself cannot discriminate between "actual" or "simulated* signals.

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

JAFNPP Page 1 of 22 Revision E

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

.ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE Not Used.

Page 2 of 22 Revision E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

ITS 3.6.1.3 ACTION B to isolate the associated penetration flow path (restore the primary containment to Operable status) within one hour is proposed to be added.

The addition of one hour allows isolation of the penetration flow path within a period of time commensurate with the importance of maintaining primary containment Operability during MODES 1, 2, and 3.

Also, the one hour period to isolate the penetration flow path ensures that the probability of an accident (requiring primary containment Operability) occurring during periods where primary containment is inoperable is maintained at a minimal level.

This change to the Completion Times to isolate the penetration flow path is not assumed in the initiation of any analyzed event.

In addition, the consequences of an event occurring during the proposed penetration "imsolation Completion Time are the same as the consequences of an event occurring during the existing Completion Times.

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

2.

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

This change will not physically alter the plant (no new or different types of equipment wi 1 be installed).

The changes in methods governing normal plant operation are consistent with the current safety analysis assumptions.

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

JAFNPP Page 3 of 22 Revision E

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L3 CHANGE

3.

Does this change involve a significant reduction in a margin of safety?

The relaxation in the time allowed to initiate a plant shutdown (allowing one hour to attempt to isolate the penetration flow path prior to initiating a plant shutdown) represents a relaxation over the current provisions.

However, this relaxation is acceptable based on the small probability of an event requiring primary containment Operability and the desire to minimize transients.

It is the intent of the Technical Specifications to provide ACTION provisions, where appropriate, to avoid the use of a shutdown requirement.

This change will not affect a margin of safety because it has no impact on the safety analysis assumptions.

The Completion Time to isolate the penetration flow path is not assumed in any analyzed accidents.

The proposed change will enhance plant safety by providing an opportunity to avoid a shutdown transient by isolation of the penetration flow path within a reasonable amount of time.

Therefore, this change will not involve a significant reduction in a margin of safety.

Page 4 of 22 4

4s

I Revision E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

This change would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate a primary containment penetration in those penetrations with one PCIV and allow operation to continue after the penetration flow path is isolated.

Primary containment isolation is not an initiator of any previously analyzed accident.

Therefore, this change does not increase the probability of such accidents.

During the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed time, a limiting event would still be assumed to be within the bounds of the safety analysis since the isolation capability is still maintained by the closed system.

Allowing this extended time to potentially avoid a plant transient caused by the immediate forced shutdown, is reasonable based on the low probability of an event, and does not represent a significant decrease in safety.

The consequences of an event that may occur during the extended Completion Time would not be any different than during the currently allowed Completion Time.

Therefore, this change does not significantly increase the consequences of any previously analyzed accident.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Further, since the change impacts only the Completion Time for the penetration isolation and does not result in any change in the response of the equipment to an accident, the change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

3.

Does this change involve a significant reduction in a margin of safety?

This change impacts only the Completion Time for inoperable valves that provide containment isolation.

The methodology and limits of the accident analysis are not affected, nor is the containment response affected.

Therefore, the change does not involve a significant Revi si on E JAFNPP Page 5 of 22

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L4 CHANGE

3.

(continued) reduction in the margin of safety.

Page 6 of 22 Revision E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CHANGE The Licensee has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

This change would allow an additional 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months total, to isolate the main steam line penetrations with one main steam isolation valve (MSIV) inoperable in one or more penetrations. Primary containment isolation is not an initiator of any previously analyzed accident.

Therefore, this change does not increase the probability of such accidents. The proposed change allows additional temporary operation 4

with less than the required isolation capability.

The isolation capability of the main steam penetrations will still be maintained by another operable MSIV.

The consequences of an event that may occur during the extended Completion Time would not be any different than during the currently allowed Completion Time.

Therefore, this change does not significantly increase the consequences of any previously analyzed accident.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Further, since the change impacts only the Completion Time for the system and does not result in any change in the response of the equipment to an accident, the change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

Page 7 of 22 Revision E JAFNPP

NO -SIGNIFICANT HAZARDS CONSIDERATIONS 1TS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L5 CHANGE

3.

Does this change involve a significant reduction in a margin of safety?

This change impacts only the Completion Time for inoperable MSIVs that provide containment isolation.

The methodology and limits of the accident analysis are not affected, nor is the containment response affected.

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

Page 8 of 22 JAFNPP Revi si on E

NO SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES LESS RESTRICTIVE (SPECIFIC)

L6 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Check valves that serve as containment isolation valves are not assumed to be initiators of any analyzed event.

The role of these valves is to isolate containment during analyzed events, thereby limiting the potential for release of radioactive material.

The change establishes compensatory measures using a check valve as an isolation barrier which are equivalent to those already included in Technical Specifications.

The proposed actions will not allow continuous operation such that a single failure could allow a containment release through an unisolated path.

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

2.

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

The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation.

The proposed change will still ensure the containment boundary is maintained.

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

3.

Does this change involve a significant reduction in a margin of safety?

The check valves which would be used for this proposed compensatory measure are containment isolation valves leak tested per 10 CFR 50, Appendix J.

In addition, the proposed ACTION establishes the check valve as an isol ation barrier which cannot be adversely affected by a single active failure.

As a result, any reduction in a margin of safety will be insignificant and offset by the benefit gai ned by reducing unnecessary plant shutdown transients when equivalent compensatory measures exist to ensure the containment boundary is maintained.

Page 9 of 22 JAFNPP Revision E

/

.1 NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L7 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change does not increase the probability of an accident because the change extends the time allowed for the plant to reach Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Actions or Completion Times associated with inoperable PCIVs cannot be satisfied.

Shutdown Completion Times are not assumed in the initiation of any analyzed event.

The change will not allow continuous operation with an inoperable PCIV.

The consequences of an accident are not increased because ITS 3.6.1.3 Required Action F.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Actions or Completion Time associated with an inoperable PCIV cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

In addition.

the consequences of an event occurring during the proposed shutdown Completion Time are the same as the consequences of an event occurring during the existing shutdown Completion Time.

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

2.

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

The proposed change will not involve any physical changes to pl ant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected.

The change only increases the time to be in Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

JAFNPP Page 10 of 22 Revision E

ji NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L7 CHANGE

3.

Does this change involve a significant reduction in a margin of safety?

The change extends the time allowed for the plant to reach Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Actions or Completion Times associated with an inoperable PCIV cannot be satisfied.

There is no reduction in the margin of safety because ITS 3.6.1.3 Required Action F.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Actions or Completion Times associated with an inoperable PCIV cannot be satisfied.

This concurrent change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by providing additional time to reduce pressure in a controlled and orderly manner.

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

Page 11 of 22 Revision E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS I1TS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L8 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

This change would decrease the frequency of the isolated PCIV verification.

The proposed change does not affect the PCIV design or function.

Additionally, a failure of a PCIV is not identified as the initiator of any event.

Therefore, this proposed change does not involve an increase in the probability of an accident previously evaluated.

Further, since the change impacts only the frequency of verification and does not result in any change in the response of the equipment to an accident, the change does not increase the consequences of any previously analyzed accident.

2.

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

This change does not result in any changes to the equipment design or capabilities, or to the operation of the plant.

Further, since the change impacts only the frequency of verification and does not result in any change in the response of the equipment to an accident, the change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

3.

Does this change involve a significant reduction in a margin of safety?

This change impacts only the frequency of verification of the isolated PCIV.

Since the PCIVs are administratively controlled and their operation is a non-routine event, and industry experience has shown the valves are, with few exceptions, always found to be in the correct position, the proposed frequency will provide the same assurance as the daily verification.

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

Page 12 of 22 Revi si on E 3AFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L9 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

ITS 3.6.1.3 ACTION D to restore the MSIV leakage rate to within the limit within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is proposed to be added.

The addition of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allows restoration of primary containment within a period of time commensurate with the importance of maintaining the MSIV leakage rate within the limit during MODES 1, 2, and 3.

Also, the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period to restore the leakage rate within the limit ensures that the probability of an accident (requiring primary containment Operability) occurring during periods where primary containment leakage is above the limit is maintained at a minimal level.

This change allows the plant a more lenient shutdown path than currently exists, permitting the shutdown (if primary containment Operability cannot be restored) to proceed in a more orderly and controlled manner.

This change will not all ow continuous operation when components are inoperable or parameter limits are not met.

This change to the Completion Times to attempt to restore the primary containment leakage rate within the limit is not assumed in the initiation of any analyzed event.

In addition, the consequences of an event occurring during the proposed primary containment leakage rate restoration Completion Time are the same as the consequences of an event occurring during the existing Completion Times.

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

2.

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

This change will not physically alter the plant (no new or different types of equipment will be installed).

The changes in methods governing normal plant operation are consistent with the current safety analysis assumptions.

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

JAFNPP Page 13 of 22 Revision E

-a,

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L9 CHANGE

3.

Does this change involve a significant reduction in a margin of safety?

This change impacts only the Completion Time for MSIV leakage not within limits.

However, this relaxation is acceptable based on the small probability of an event requiring primary containment Operability (and MSIV leakage within limits) and the desire to minimize transients.

This change will not affect a margin of safety because it has no impact on the safety analysis assumptions.

The Completion Time to restore MSIV leakage rates to within limits is not assumed in any analyzed accidents.

The proposed change will enhance plant safety by providing an opportunity to avoid a shutdown transient by the restoration of MSIV leakage rate within the limit within a reasonable amount of time.

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

Page 14 of 22 Revi si on E JAFNPP

)

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L1O CHANGE The Licensee has evaluated the proposed Technical Specification change and has I

concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change will allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore leakage rate to within limits for one or more air operated testable check valves associated with the Low Pressure Coolant Injection and Core Spray Systems injection penetrations exceeding the specified limits.

The specified leakage limits ensures the radiation dose that would result if the reactor coolant were released to the reactor building at the specified rate will be small.

The associated penetrations are normally isolated during plant operations by a motor operated PCIV.

In addition, there is an additional motor operated valve (which is hydrostatically leak tested under the IST Program) available to isolate the penetration.

Therefore, excessive leakage will be minimized by this closed PCIV and therefore ALARA concerns in the reactor building will be minimized.

In the event of a pipe rupture outside of primary containment gross leakage is limited by the air operated testable check valve inside primary containment, however if it is inoperable the PCIV will also minimize the leakage.

The reactor building includes radiation monitors which will provide audible and visual alarms to the control room.

The Keep Full ow level alarms and the reactor building floor drain sump high level alarms are available to indicate excessive primary coolant leakage.

Therefore, since diverse isolation methods exists to limit the leakage and since the plant is instrumented with diverse methods to detect leaks within the reactor building the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowance is acceptable.

The consequences of an accident during this additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is bounded by the consequences during the current shutdown times.

Therefore this change does not increase the probability or consequences of an accident previously evaluated.

2.

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

This change will not result in any changes to equipment design or capabilities or the operation of the plant.

The proposed change will still require the leakage values to be restored to within limits.

Page 15 of 22 JAF'NPP Revi si on E

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

LIO CHANGE

2.

(continued)

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

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change will allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore leakage rate to within limits for one or more air operated testable check valves associated with the Low Pressure Coolant Injection and Core Spray Systems injection penetrations exceeding the specified limits.

The specified leakage limits ensures the radiation dose that would result if the reactor coolant were released to the reactor building at the specified rate will be small.

The associated penetrations are normally isolated during plant operations by a motor operated PCIV.

In addition, there is an additional motor operated valve (which is hydrostatically leak tested under the IST program) available to isolate the penetration.

Therefore, excessive leakage will be minimized by this closed PCIV and Ilk therefore ALARA concerns in the reactor building will be minimized.

In the event of a pipe rupture outside of primary containment gross leakage CA is limited by the air operated testable check valve inside primary V*

containment, however if it is inoperable the PCIV will also minimize the leakage.

The reactor building includes radiation monitors which will provide audible and visual alarms to the control room.

The Keep Full ow level alarms and the reactor building floor drain sump high level alarms are available to indicate excessive primary coolant leakage.

Therefore, since diverse isolation methods exists to limit the leakage and since the plant is instrumented with diverse methods to detect leaks within the reactor building the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowance is acceptable.

The consequences of an accident during this additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is bounded by the consequences during the current shutdown times.

The additional times will allow more time to repair the inoperable valve(s) and possibly avoid a shutdown.

Shutting down the plant is a transient which puts thermal stress on components which could increase the chances of challenging safety systems.

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

JAFNPP Page 16 of 22 Revision E

.o.!+

+

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

.ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L1i CHANGE The Licensee has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

This change will allow the verification of closure of isolation devices such as valves and blind flanges located in high radiation areas, and isolation devices that are locked, sealed, or otherwise secured, to be performed by the use of administrative means.

The entry into high L

radiation areas is restricted by plant procedures, therefore, the probability of any inadvertent opening of these devices is very low.

If a procedure or maintenance is performed and these valves are opened, closure would be required upon completion of the associated procedure or maintenance.

The function of locking, sealing, or securing components is to ensure that these devices are not inadvertently mispositioned.

Therefore, adequate measures are in place to ensure these valves remain closed.

The Required Action or Surveillance may be verified by reviewing that no work was performed in the radiation area since it was closed or if work was performed in the area that closure was verified upon completion of the work if the valve was opened.

This change does not cause a significant increase in the probability or consequences of any previously analyzed accident since administrative methods are in place to ensure the penetration is closed when required.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

Further, since the change impacts only the method of verification and does not result in any change in the response of the equipment to an accident, the change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

Page 17 of 22 Revision E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L11 CHANGE (continued)

3.

Does this change involve a significant reduction in a margin of safety?

This change continues to ensure by devices are closed when required.

involve a significant reduction in adequate means that the isolation Therefore, this change does not the margin of safety.

Page 18 of 22 Revision E JAFNPP 4'.

NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L12 CHANGE New York Power Authority has evaluated the proposed Technical Specification change identified as "Technical Changes - Less Restrictive" and has determined that it does not involve a significant hazards consideration.

This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the determination that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change deletes the specific valve numbers of the Low Pressure Coolant Injection and Core Spray System which must be tested for leakage.

The valves are not considered as an initiators of any previously evaluated accident.

The proposed change will not impact the ability of the valves to perform its intended function.

Therefore, the proposed change will not increase the probability of any accident previously evaluated.

Additionally, ITS SR 3.6.1.3.11 will still require the verification that the leakage rate of each air operated testable check valve associated with the Low Pressure Coolant Injection and Core Spray System vessel injection penetrations is < 10 gpm at 1035 psig when hydrostatically tested or 11 scfm when pneumatically tested.

This is sufficient to ensure the appropriate testing is performed.

Therefore, the proposed change will not increase the consequences of any accident previously evaluated.

2.

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

The proposed change does not involve physical modification to the plant.

The valves will be tested in the same manner and prescribe frequency as currently required.

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

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change deletes the specific valve numbers of the Low Pressure Coolant Injection and Core Spray System which must be tested for leakage. However, these details are not necessary to ensure the valves are maintained within the specified leakage rate.

Additionally, ITS SR 3.6.1.3.11 will still require the verification that the leakage rate of each air operated testable check valve associated with the Low Pressure Coolant Injection and Core Spray System vessel injection Revision E JAFNPP Page 19 of 22

-4, NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L12 (continued) penetrations is < 10 gpm at 1035 psig when hydrostatically tested or 11

-scfm when pneumatically tested. This is sufficient to ensure the appropriate testing is performed and the valves remain Operable.

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

Page 20 of 22 Revision E JAFNPP S........ --*

-d NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L13 CHANGE The Licensee has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change will allow periodic leakage rate testing of the Low Pressure Coolant Injection (LPCI)

System and Core Spray System injection penetration air operated testable check valves to be extended from "every 24 months" to "In accordance with the Primary Containment Leakage Rate Testing Program."

The Primary Containment Leakage Rate Testing Program implements the requirements of 10 CFR 50, Appendix J. Option B, and requires that valves subjected to "Type C" testing be tested every 30 months (with an extension to every 60 months if the performance of the valves meet certain standards).

Historical testing results (operating experience) associated with the testing every 24 months has shown the valves to leak tight and rarely require action to correct leakage deficiencies.

The probability of analyzed event is not changed because the frequency of leakage testing of the valves is not assumed in any analyzed event and the consequences of an event occurring during the extended test interval are the same as the consequences of an event occurring during the existing test interval.

Therefore this change does not increase the probability or consequences of an accident previously evaluated.

2.

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

The proposed change does not involve any physical alteration of plant systems, structures or components (SSCs).

changes in parameters governing normal plant operation, or methods of operation.

The proposed change will still require the leakage testing of the valves to be performed at intervals that demonstrate leak tightness and structural integrity of the valves.

Since the change impacts only the frequency of testing while maintaining the leakage limits unchanged and does not result in any change in the response of equipment to an accident, the proposed change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

Page 21 of 22 JAF'NPP Revi si on E

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L13 CHANGE (continued)

3.

Does this change involve a significant reduction in a margin of safety?

The proposed change will allow the interval of leakage rate testing of LPCI System and Core Spray System air operated testable check valves to be extended from 24 months to that specified in the Primary Containment Leakage Rate Testing Program for valves subjected to "Type C" tests.

The test interval specified in the Primary Containment Leakage Rate Testing Program (which is in accordance with 10 CFR 50, Appendix J, Option B) for valves subjected to Type C testing is based valve test results.

Since the valve test results provide the basis the interval until the next required test, an increase in the interval between successive tests will not have a significant effect on the probability of test failure due to excessive leakage.

In addition, since the leakage limits are not being changed, there exist other valves which can be used to isolate the same penetrations in the event of excessive leakage, and diverse means of detecting excessive leakage exist.

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

Page 22 of 22

'1

()

Revi si on E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.6 - REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

Li CHANGE (continued)

3.

-Does this change involve a significant reduction in a margin of safety?

The proposed change does not involve any physical alteration of plant systems, structures or components, changes in parameters governing normal plant operation, or methods of operation.

The change allows separate Condition entry for each vacuum relief line (vacuum breaker) inoperability.

As such, the change also allows the concurrent (or over lapping) inoperability of both vacuum relief lines to be addressed concurrently and thus potentially reduces the time period during which one or more lines is inoperable by allowing concurrent Required Actions (corrective actions) to be taken.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by allowing separate Condition entry for each line (which would be necessary in the event of conditions resulting in more than one line being inoperable at the same time) by reducing the potential for a required shutdown of the plant under ITS 3.0.3 due to none of the Conditions in ITS 3.6.1.6 being applicable.

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

Page 2 of 4 Revi si on E JAFNPP

NO-SIGNIFICANT HAZARDS CONSIDERATIONS

-- ITS: 3.6.1.6 - REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE New York Power Authority has evaluated the proposed Technical Specification change and has concluded that it does not involve a significant hazards consideration.

Our conclusion is in accordance with the criteria set forth in 10 CFR 50.92.

The bases for the conclusion that the proposed change does not involve a significant hazards consideration are discussed below.

1.

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

The proposed change does not increase the probability of an accident because the change extends the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Actions or Completion Times associated with an inoperable vacuum breaker(s) cannot be satisfied or if two reactor building-to-suppression chamber vacuum breakers are inoperable.

Shutdown Completion Times are not assumed in the initiation of any analyzed event.

The change will not allow continuous operation with excessive numbers of inoperable vacuum breakers.

The consequences of an accident are not increased because ITS 3.6.1.6, Required Action E.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Actions or Completion Time associated with an inoperable vacuum breaker(s) cannot be satisfied.

This change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

In addition, the consequences of an event occurring during the proposed shutdown Completion Time are the same as the consequences of an event occurring during the existing shutdown Completion Time.

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

2.

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

The proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are operated, maintained, modified, tested, or inspected.

The change increases the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

Page 3 of 4 JAFNPP Revi sion E

NO-SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.6 - REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

L2 CHANGE

3.

-Does this change involve a significant reduction in a margin of safety?

The change extends the time allowed for the plant to get to Cold Shutdown from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when the Required Actions or Completion Times associated with an inoperable vacuum breaker(s) cannot be satisfied or if two reactor building-to-suppression chamber vacuum breakers are inoperable.

There is no reduction in the margin of safety because ITS 3.6.1.6, Required Action E.1 will require that the plant be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once the determination is made that the Required Actions or Completion Times associated with an inoperable vacuum breaker(s) cannot be satisfied.

This concurrent change reduces the time the reactor would be allowed to continue to operate once the condition is identified.

The consequences of a LOCA are significantly mitigated when the reactor is shutdown and a controlled cooldown is already in progress.

In addition, this change provides the benefit of a reduced potential for a plant event that could challenge safety systems by providing additional time to reduce pressure in a controlled and orderly manner.

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

Page 4 of 4 JAFNPP Revision E

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION ii

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary APPLICABILITY:

Containment Isolation Valves (KIVs)

Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

MODES 1, 2, and 3, When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, 'Primary Containment Isolation Instrumentation."

ACTIONS OTES -

fl b

-h.

ma-Penetration flow paths a

ow aths may be unisolated interoittle-ntly under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, *Primary Containment," when PCIV leakage results in exceedin overall ontainment leakage rate acceptance criteria1,2 d

CONDITION A. --

NOTE-Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PC]JL--*-*

REQUIRED ACTION COMPLETION TIME A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except penetration flow path for main stem by use of at least line one closed and do-activated AND automatic valve, closed manual valve, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main blind flange, or stem l1 ne check valve with flow through the valve secured.

__(continued) 3.6-8 Rev 1, 04107/9S SkgEVISION E

(

1Z?.3 2-121

/

PCIVs 3.6.1.3 BWR/4 STS 3.6-9 r4 V.'

Rev 1, 04/07/95 REVISION E 4

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)A2 Isolation devices in

-'high radiation areas ILL t may be verified by use of administrative means.

Verify the affected Once per 31 days L-",

penetration flow path for isolation is isolated.

devices outside primary containment Prior to entering MODE 2 or 3 from

~, X~ ~j~ceS 4MDE 4p if primary

..t o.4,:

containment was S&,

4 W -e-.*e, de-inerted while

$secfCU-VAO-Y b-.

in MODE 4, if uVY-:-,

by "se or not performed within the

& 4L.WAe

V'tv*.1 **-

previous e92 days, for Isolation devices inside primary containment (continued) 1

'-I PCIVs 3.6.1.3 CONDITION REQUIRED ACTION COMPLETION TIME B -

- NOTE-.....

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with two PC tnoeralef*fxep*for*

purgZ'valv I:ea&ge J

C. ----

NOTE---

Only applicable to penetration flow paths with only one PCIV.

L rL41

'-I One or more penetration flow paths

-V with one PCIV moperabi B.1 Isolate the affected penetration flow path by use of at least one closed and de-acti vated automatic valve, closed manual valve, or blind flange.

9.

C.1 C.2 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

-NOTEGSýŽ.

Isolation devices in high radiation areas my be verified by use of administrative mans.

Verify the affected penetration flow path is isolated.

4 I

D.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months NOD~ b~

V, 4 v 10'-\\

Once per 31 days BWR/4 STS 3.6-:

ArT~l" a'~d /,-nani" 4

n~m]

'FL I-\\

-S~e-CA r4iLA3.May by CLB'e f

D.

d i

as kage rate o otyitt ith-limit.

cy VeCLSO-09 0,64-ev

-kk'4L'V% CqVkCL!t;G-MS

'Ib V"

10 OSt.*::*

t*

PCIVs 3.6.1.3 TIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One or more E.1 isolat he affected 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration ow paths penet tionflow path with one o re by e of at least containme purge o (closed and vaIves t within e-activated purge a

automatic valve, 11.1 lv.lek closed manual valve, "lm or blind flange].

E.2 NOTE -------

Isolation devices in high radiation area may be verified b use of admlnlstr ive.

means.

Verify the ffected Once per penetrat n flow path 31 days for is isol ed.

isolation devices outside containment Prior to entering E 2 or 3f MODE 4 if t perf "wi ilathe vious 2 days for isolation devices inside containment (continued BWR/4 STS 3.6-11 Rev 1, 04/07/95

E.

One or more penetration flow paths with LPCI System or CS System testable check valve leakage limit

-not met.

INSERT ACTION E E.1 Restore leakage rate to within limit.

Insert Page 3.6-11 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

PCIVs 3.6.1.3 (continued)

Rev 1, 04/07/95 BWR/4 STS rS.3.7, D.

CM 6]E,-7 3.6-12

PCIVs 3.6.1.3 ACTIONS (continued)

SCONDITION I

equired Action and associated,Compl etion Time ofL ndjttion A, B*

(P not met fo-PC (s) required to be OPERABLE during MODE 4 or 5 r

n peralonsith ac lpotet ial/for/

J

- L dra ing the *ea I

REQUIRED ACTION

/

COMPLETION TIME

? Ini~e ti'ate action to suspend mt

.2 initiate action to restore valve(s) to OPERABLE status.

J i

....rnrI I AUI

nrnht1orMrIrI

.JUIVC1LLL~ltRR6fL4UE~Iu SURVEILLANCE SR 3.6.1.3.1 NOTE d 3.

jVerify each [18] inch crimary contalument purge valve is sealed closed except for one purge valve in a netratlon flow path while in Condit on E of this LCO.

Immediately Immediately FREQUENCY 31 Lays]

(continued)

Rev 1, 04107/95 BWR/4 STS CM11 3.6-13 I

I FREQUENCY r

PCIVs 3.6.1.3

-,NOTES,

1.

Valves; and blind flanges in high radiation areas may be verified by use of administrative means.

Not required to be met for PCIVs are open under administrative controls.

Verify each primary containment isolation manual valve and blind flange that is located outside primary containment and is required to be closed during accident conditions is closed.

3.6-14 31 days (continued)

(continued)

Rev 1, 04/07/95 4

rMJ BWR/4 STS PJA.43 F. 0,M-D

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

T?

SURVEILLANCE FREQUENCY

-SR 3.6.1.3.

NOTES

1.

Valves and blind flanges~in high radiation areas may be verified by use of administrative means.

2.

Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual Prior to isolation valve and blind flange that is entering MODE 2

" 'located inside primary containment'and is or 3 from required to be closed during acciden MODE 4 if conditions is closed.

primary containment was while in or 0H NMODE 4, if not performed within the previous 92 days SR 3.6.1.3.1f*.Verify continuity of the traversing 31 days

)incore probe (TIP) shear isolation valve

"*/ explosive charge.

SR 3.6.1.3.0' Verify the isolation time of eachpower In dperateda c automatic PCIVI, except accordance for -IVs, s Ithin limits.

iith the Inservi ce Testing r

tm (continued)

BWR/4 STS 3.6-15 Rev 1, 04/07/95 4-D. 0,0-9

ý-T.

011.

PCIVs 3.6.1.3 URVEILLANCE REQUIRENENTS (continued SURVEILLANCE FREQUENCY SR 3.6.1.3.7 nly requi obe met in OES1L PSerfo leakage.rate testing or each 18i s

prS3 i

containt purge Val c ith tn re i

Lt seals.

/

i/

ce wthin, 2 days after opening the val ve k secnds nd !

secnds.with the L

43 Inservice SR 3.6.1.33R Verify each autotic PCIV actuates to i

1,nths the isolation position on an actual orE siultd isolation signal.

P__4v&

each~~

~

r,1 tw-o Mntunato te I

SR 3.6.1.3.1&

Verify eahrate ornsrmnainle EFCV actuate a a simulated instrume t SR 3.61-%3.

Remve and test the explosive squbfo otso each shear isolation valve of the TIP a **6ERtED Systm.

TEST BAIS x(/,

(continued) i BWR/4 STS 3.6-16 Rev 1, 04/07/95 L.

REVISION E

II PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.12 ---- ----------- NOTES ----------- --

[1.

nly required to be met in MOD 1,

2, and 3.]

2. Results shall be evaluated a ainst acceptance criteria of SR 3.

1.1.1 in accordance with 10 CFR 50, Appendix J, as modified by a proved exemptions.

--7----

Verify the combined leakage te for all

NO secondary containment bypas leakage SR 3.0.

paths is < [

L when pre urized to is not S[psig].

appli ble In ccordance wi 1 CFR 50, pendix J, s modified by approved exemptions SVerify leakage rate through each NSIV.is

-NOTE In accordance

-"~~

~

i

.L, by app v (continued)

BWR/4 STS 3.6-17 Rev 1, 04/07/95 F

I 4

PCIVs 3.5.1.3 SURVEILLANCE REQ*UIREMENTIS

(.oni*:nued)

SURVEILLANCE FREQUENCY SUV only, quired b to inMS 2

o,*,,.a.d 3*

sr*=*ms

neag T~r.U v,

aol

,Is)l_

t l~ug S

0.

Shydrosta ti lly testedl )nos that s o Spenetr atehe primary ontainmen i

lcb SR3..13.

Ony esltred 3-25 be e.1, and3.

purge~~la vavis leddoS valve app oped9 SVR451 3.6.135 18-e

, 407E RcIIO

Insert SR 3.6.1.3.11 each air operated testable check valve associated with the LPCI System and CS System vessel injection penetrations is < 10 gpm when hydrostatically tested at it 1035 psig or < 11 scfm when pneumatically tested at 2 45 psig, at ambient temperature.

Insert Page 3.6-18

/

4 AI

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1 4

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

RETENTION OF EXISTING REOUIRENENT (CLB)

CLB1 ITS 3.6.1.3 has been revised to reflect the current licensing requirements of JAFNPP, that no special vent and purge valve leakage limits, flow path exceptions, or Surveillance Requirements exist in the CTS 3/4.7.

The bracketed ISTS 3.6.1.3 Action E, SR 3.6.1.3.1, SR 3.1.6.3.7, and references to purge valve leakage limits are not applicable and have been deleted.

Subsequent ACTIONS and Surveillance Requirements have been renumbered as applicable.

CLB2 ISTS 3.6.1.3 ACTION G and ACTION H have been deleted to reflect the current licensing requirement of JAFNPP that no PCIVs are required to be OPERABLE during movement of irradiated fuel or during CORE ALTERATIONS.

Subsequent ACTIONS have been renumbered as applicable.

CLB3 Not Used.

CLB4 ITS SR 3.6.1.3.1 Note 2 has been revised to reflect the current licensing requirement of JAFNPP, CTS 3.7.B.4, that for periods when primary containment integrity is required, inerting and de-inerting be performed using the 27NOV-121 (low flow, 6 inch) valve, and the 27MOV 120 (full-flow, 12 inch) valve shall be closed.

CLB5 ITS SR 3.6.1.3.5 has been revised to reflect current licensing requirements at JAFNPP (CTS 4.7.D.l.a) that the Frequency for verifying isolation time of each automatic PCIV except for MSIVs is in accordance with the Inservice Testing Program.

CLB6 ITS SR 3.6.1.3.6 has been revised to reflect current licensing requirements at JAFNPP (CTS 4.7.D.1.d) that the isolation time of each MSIV is m 3 seconds and s 5 seconds in accordance with UFSAR Table 7.3 1, Primary Containment Isolation Valves, and-the Frequency for the Surveillance is in accordance with the Inservice Testing Program.

CLB7 Not Used.

CLBB ITS SR 3.6.1.3.8 has been revised to reflect current licensing requirements at JAFNPP, CTS 4.7.D.1.b. that the Frequency for verifying each reactor instrument line EFCV actuates to the isolation position on an actual or simulated (M2) isolation instrument line break is in accordance with the Inservice Testing Program.

In addition, the requirement to restrict flow to s 1 gph has been deleted since the JAFNPP analysis does not assume a specific leakage through the EFCVs.

The leakage will be controlled administratively and will be based on valve design leakage.

Page 1 of 5 J

Revision A JAFNPP

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

RETENTION OF EXISTING REQUIREMENT (CLB)

CLB9 ITS 3.6.1.3 has been revised to reflect the current licensing requirements of JAFNPP, that since no separate secondary containment bypass leakage is considered with respect to the primary containment leakage, no specific leakage rates or Surveillance Requirements exist in the CTS 3/4.7.

The bracketed ISTS 3.6.1.3 Action D reference to secondary containment bypass leakage and the bracket SR 3.6.1.3.12 to verify secondary containment bypass leakage path limits are not applicable and have been deleted.

Subsequent Surveillance Requirements have been renumbered as applicable.

CLB1O ITS SR 3.6.1.3.10 (ISTS SR 3.6.1.3.13) has been revised to reflect the current licensing requirements of JAFNPP, that the MSIV leakage rate testing Frequency is contained in the Primary Containment Leakage Rate Testing Program.

In addition, the Note to the ISTS SR 3.6.1.3.13 Frequency has been deleted since SR 3.0.2 does not apply to the Primary Containment Leakage Rate Testing Program as stated in the Bases of SR 3.0.2.

Therefore, it is not necessary to include this Note in the ITS.

CLB11 ITS SR 3.6.1.3.11 (ISTS SR 3.6.1.3.14) has been revised to reflect the current licensing requirement of JAFNPP. CTS 4.7.A.2.c, to determine the leakage rate of hydrostatically tested valves.

In addition, the Note to the ISTS SR 3.6.1.3.14 Frequency has been deleted since SR 3.0.2 does not apply to the Primary Containment Leakage Rate Testing Program as stated in the Bases of SR 3.0.2.

Therefore. it is not necessary to include this Note in the ITS.

CLB12 ITS SR 3.6.1.3.7 has been revised to reflect the requirements at JAFNPP that the Frequency for verifying each automatic PCIV actuates to the isolation position on an actual (Li) or simulated isolation signal is 24 months (A9) consistent with CTS Table 4.2-1. Primary Containment Isolation Instrumentation Test and Calibration Requirements.

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl The words "in MODES 1, 2. and 3" have been deleted from ITS 3.6.1.3 ACTIONS Note 4 since there are no PCIV leakage tests required in MODES other than MODES 1. 2, and 3 for JAFNPP (i.e., there are no PCIVs required to be OPERABLE in MODES other than MODES 1, 2, and 3 that have specific leakage limits).

In addition, ITS SR 3.6.1.3.1. Note 1 and SR3.6.1.3.11 Note 1. have been deleted for the same reason.

The subsequent Notes have been renumbered, as applicable.

PA2 Editorial changes have been made to enhance clarity.

Page 2 of 5 Revision E JAFNPP

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1

-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PA3 The plant specific terminology has been included.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 ITS 3.6.1.3 has been revised to reflect specific differences based on the JAFNPP design of the vent and purge system.

The vent and purge valves at JAFNPP are of two sizes, 20 inch and 24 inch.

DB2 Not used.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

TA1 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 45. Revision 2. have been incorporated into the revised Improved Technical Specifications.

TA2 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 46, Revision 1, have been incorporated into the revised Improved Technical Specifications.

TA3 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 30, Revision 3. have been r

incorporated into the revised Improved Technical Specification.

The allowance was included in accordance with L4.

TA4 The changes presented in Technical Specification Task Force (TSTF)

I Technical Specification Change Trave er Number 52, Revision 3, have been

. I incorporated into the revised Improved Technical Specifications.

TAS The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 207, Revision 5, have been incorporated into the revised Improved Technical Specifications.

TA6 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 269, Revision 2, have 4-s been incorporated into the revised Improved Technical Specification.

&-1; DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None jt Page 3 of 5 Revision E JAFNPP

.. 0 JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1

ý-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE MX)

X1 ISTS 3.6.1.3 ACTION D, for secondary containment bypass leakage rate not within limit, is being revised.

Since secondary containment bypass leakage is not accounted for in the DBA LOCA radiological analysis it is not addressed in JAFNPP CTS.

The CTS 4.7.2.b Surveillance Requirement for MSIV leakage is contained in ITS SR 3.6.1.3.10 (ISTS SR 3.6.1.3.13).

ITS 3.6.1.3 ACTION D, addresses the condition for one or more penetration flow paths with one or more MSIVs not within leakage rate limits, provides a Required Action to restore leakage rate to within limits, and establishes a Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (LM).

These requirements are consistent with those of NUREG-1433. Revision 1, except that the Completion Time is increased from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Since the secondary containment bypass leakage is not considered, the Completion Time was revised to be consistent with ISTS 3.6.1.3 ACTION A for an inoperable MSIV.

In addition, ACTIONS A and B have been revised by replacing the bracketed listing of valves with the phrase "for reasons other than Conditions D and E.

This change reflects TSTF-207, R5.

X2 The brackets have been removed and changes have been made to ITS 3.6.1.3 ACTION G (ISTS 3.6.1.3 ACTION I) to reflect the appropriate Required Action and associated Completion Times for MODE 4 and 5 operations.

X3 ITS SR 3.6.1.3.1 (ISTS 3.6.1.3.2) to verify each 20 and 24 inch (DB1) primary containment purge and vent (CLB3) valve is closed, has been included, based on CTS 4.7.8.4 requirement for 27MUV-120 to be verified closed (M7).

X4 Not used.

X5 ITS SR 3.6.1.3.8, to verify each reactor instrumentation line EFCV actuates on a simulated instrument line break, has been revised to include the words "to the isolation position" to describe the final position of the EFCVs, consistent with other NUREG-1433, Revision 1, Surveillances that test PCIVs (e.g., ITS SR 3.6.1.3.7).

t X6 ITS SR 3.6.1.3.9 Frequency of 24 months to remove and test the explosive squib from each shear isolation valve of the TIP System has been included (W4).

This Frequency is consistent with similar testing which is performed at the refueling cycle Frequency.

JAFNPP Page 4 of 5 Revision E

_A*

4

/

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1

`ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X7 ISTS SR 3.6.1.3.15, to verify each primary containment purge valve is blocked to restrict valve opening, has been deleted.

In accordance with the ISTS Bases SR 3.6.1.3.15rReviewers Note, this Surveillance is not required for valves which have blocking devices permanently installed.

JAFNPP blocking devices are permanently installed.

X8 ITS 3.6.1.3 ACTION E has been added to address the condition when leakage rate specified in SR 3.6.1.3.11 (CTS 4.7.A.2.c) is exceeded.

The addition of this Action is similar to ACTION D for other leakage V"

limits not within limits.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is adequate as described in L1O.

In addition, the bracketed exceptions of ITS 3.6.1.3 ACTION A and ACTION B. have been revised by replacing the bracketed valve listing with the phrase "for reasons other than Conditions D and E.0 The change reflects TSTF-207, R5.

Subsequent Conditions and Required Actions have also been renumbered to reflect addition of Condition E accordingly.

X9 ITS SR 3.6.1.3.11 (ISTS SR 3.6.1.3.14) Frequency has been revised to determine the leakage rate of hydrostatically tested valves in accordance with the Primary Containment Leakage Rate Testing Program (L.13).

Page 5 of 5 Revision E JAF'NPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

MARKUP OF NUREG-1433, REVISION 1, BASES Ir

PCIVs B 3.6.1.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

BASES BACKGROUND The function of the PCIVs, in combination with other 1

accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs) to within limits.

Primary containment isolation within the tim limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.

The OPERABILITY requirmnts for PCIVs help ensure that an adequate primary containment boundary is maintained during and after an accident by minimizing potential paths to the environment.

Therefore, the OPERABILITY requirements provide assurance that primary containment function assumed in the safety analyses will be maintained.

These isolation devices are either passive or active (automatic).

Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closus-tems are a.-Vid considered passive devices.

Check valves, Wother automatic valves designed to close without bperator aCtL following an accident, are considered active devices.

r barriers in series are provided for each penetration so thatta no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses.

One of these barriers may be a closed system.

The reactor building-to-suppression chamber vacuum breakers serve a dual function, one of which is primary containment isolation. However, since the other safety function of the vacuum breakers would not be available If the normal PCIV actions were taken, the PCIV OPERABILITY requirements are not applicable to the reactor building-to-suppression chamber vacuum breakers valves.

Similar surveillance requirements in the LCO for reactor building-to-suppression chamber vacuum breakers provide assurance that the isolation capability is available without conflicting with the vacuum relief function.

(continued)

BIR/4 STS B 3.6-14 Rev 1, 04/07/95 REVISION E

10"d

'T-'-*

iss'l~i ts p

'i around the dum.

"APPLICABLE The PCI.LCO was derived from the assumptions related to SAFETY ANALYSES minimizing the loss of reactor coolant inventory, and establishing the prinary containment boundary during major accidents.

As part of the primry containment boundary, I ft PCIV OPERABILITY supports leak tightness of primary containment.

Therefore, the safety analysis of any event requiring isolation of primary containment s

plicable to

-s The DBAs that result in a release of radioactive material WM.Vt namrv n

inme are a L and m

main stem lin by r

break (NSIJ).

in theanalysis for each of these accidents, it s assumed that PKIVs are either closed or close within oevent

,n0t4ati7n.

i nu thtptnilpaths to the a-nvtrwmnt throucs DrIVe 14ncludipp nLr11 containmentei-Ni ae vves tar.,

o the.z events an,,ze in Reeec 1~.

e HSLJB is the most limittng event due to radiological) cosqec t

o 4Kr Th closure tin of the main stem isolation valves (NSIVs) ro&

ifgm (a19ia se nt.

nvsd)o REVISION E

+

"I.

-d INSERT BKGD-1 suppression chamber and drywell vent and purge lines are 20 and 24 inches in diameter respectively, and INSERT BKGD-2 both the suppression chamber and drywell vent lines have 2 inch bypass lines around them for use during normal reactor operation or when it is not necessary to open the 20 and 24 inch valves.

The only primary containment vent path provided, by design, is from the common 30 inch suppression chamber and drywell vent line through two parallel lines with valves (one 6 inches in diameter, the other 12 inches in diameter) to the 24 inch Standby Gas Treatment (SGT) System suction line.

When in MODES 1, 2, and 3 only the low flow 6 inch line (with valve 27MOV-121) is allowed to be open whenever the 20 or 24 inch vent and purge valves are open.

The full-flow 12 inch line (with valve 27MOV-120) is required to be closed to INSERT Page B 3.6-15

"ýD --__

Fý&

Revi si on E

APPLICABLE containment is isolated such that release of fission SAFET ANAYSES products to the environmnt is controlled.

(continued) sms th within 60 seco/

of the c cdont, solation of the/

,arym cont Ime is comlet I

and le Orhge is terminat except for the imum allow le ccen, so atr of th prmy c ontim isoupe.

leaka rate, L..

The pmary contain..

isolation t al /

I ID -*he single failure _*Griterion required to be imposed in the re-conduct of6(

0 saoety analyses was considered in e

original design of the prim con nuse v

Two valves tn sertes on eachourge l ne proviw e assurance that boeth the supply and exhaust lies could be isolated even if a single failure occurred.

th PCI~

I satisf Criterion 3 fPed.

Lormia psrn of the primr tainmet*

valves TCo valfes usnrcestn relate*

d tn iniemilozingshe lssurs o reacto oolath inventorpy and exastablinshingldthe pimoaryed

.ee if a

~

sigl aiu e

, thured Trnleftlre<

con m

tainent b ay duinT a voIA prZ vdeg The po e p r ate au c

sol ti n v s

areu r qit r d to have isolation the prtwin a*

t andatuate orne

.he uare Val to is req atord otamnt s

pene tra tons, re r ooasnta lnit edtrbol the prevent full opegm a hile the ure iding-to-suppression chIaber

2.

(~ ~

~

w e//*-*

acu h Vraler V oa. oprimav onttn purenerv os t

exclnded fromthtS ecftcation.

otrols on their isolation function are adequately addressed in LC (continued)

BUR/4 STS B 3.6-15 Rev 1. 04/07/95 REVISION E

(

INSERT ASA-1 does not assume a specific closure time for primary cintainment isolation valves (PCIVs).

The analysis assumes that the leakage from the primary containment is 1.5 percent primary containment air weight per day (La) at pressure P* throughout the accident.

The bases for PCIV closure times, and the specifled valve closure times, are specified in UFSAR 7.3.3.1 and UFSAR Table 7.3-1 (Refs. 4 and 5), respectively.

K INSERT Page B 3.6-16 Revision E

°--TL..........*

,4 BASES LCO (continued) 3.6.1*, "Reactor Building-to-Suppression I Breakers."

The valves covered by this LCO

_e___ _rs__-_-_-_ _____e____

in Reference The normally closed PCIVs are considered OPERABLE when manual valves are closed or open in accordance with appropriate administrative controls, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed.systems are intact.

These passive isolation valves and devices are those listed in Reference k Y__

Ii

r.

RHIS valves musitmeet ai tional leakage rate requirements.

Other PCIV leakage rates are addressed by LCO 3.6.1.1, *Primary Containment,"

as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

LICABILITY In NODES 1, 2, and 3, a IBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these NODES.

Therefore, most PCIVs are not reuired to be OPERABLE and the primary containmantýpurgejvalves are not.

a velaro closed in MODES 4 and 5. Certain valves, however, a required to be OPERABLE to prevent Vinadvertent reactor vessel draindown.

These valves are those whose associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, 'Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instruintation.)

The ACTIONS are madifin b a Note allowing penetration flow path(s) y ra uvave t

o be mnisolated interitteently under adifiistrative controls.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous (continued)

B 3.6-17 Rev 1, 04/07/95 C.

APP ACTIONS BNR/4 STS

1

PC!Vs B 3.6.1.3 A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PIV.

Comlying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4.

Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve).

Note 4 ensures appropriate remedial actions are taken when the primary contaitnent leakage limits are exceeded.

Pursuant to LCO 3.0.6, these actions are not required even when the associated LCO is not met.

Therefore, Notes 3 and 4 are added to require the proper actions be taken.

A-1and A.2 AitbmnI rmO netrationn ffloow ths with one PCIV inoperabl eco or eakage not within limit#; the affected penetration ow paths must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that met this criterion are a closed and do-activated automatic valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured.

For a penetration isolated in accordance with Required Action A.1, (continued) 5 3.6-18 Rev 1, 04/07/95 REVISION E I

fyi WRI/4 STS Q!

-rwr-ýý vL

PCIVs 8 3.6.1.3 BASES ACTIONS A.1 and A.2 (continued) the device used to isolate the penetration should be the closest available valve to the primary containment.

The Required Action must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Tim of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the tim required to isolate the penetration and the relative importance of supporting primary containment OPERABILITY during HODES 1, 2, and 3.

For main stem lines, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed.

The Completion Tie of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the main steam lines allows a period of time to restore A;

the NSIVs to OPERABLE status given the fact that NSIV closure will result in isolation of the main stem line(s) and a potential for plant shutdown.

For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path(s) must be verified to be isolated on a periodic basis.

This is necessary to ensure that primary containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be in the isolation position should an event occur.

This Required Action does not require any testing or device manipulation.

Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position.

The Completion Tin of once per 31 days for isolation devices outside primary containment is appropriate because the devices are operated under administrative controls and the probablity of their misalignment is low. For the devices inside primary containment, the time period specified "prior to entering NODE 2 or 3 from NODE 4, if primary containment was de-inerted while in NODE 4, if not performed within the previous 92 days" is based on engineering Judgment and is considered reasonable in view of the inaccessibility of the devices and other administrative controls ensuring that device misalignment is an unlikely possibility.

Condition A is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two PCIVs.

For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions.

Required Action A.2 is modified by a I

_th applies to

-e l isolation devices located in high rads otn-

-areas, and Br G

.v(continued)

BUR/4 STS B 3.6-19 Rev 1. 04/07/95 REVISION E

PCIVs B 3.6.1.3 BASES ACTIONS A1ad A.

(continued) allows them to be verified by use of administrative means.

Allowing verification by administrative means is considered C

.J acceptabl since access to these areas is typically

/restrictedo., Therefore, the probability of misalignment d once they have been verified to be in the pr-per position, is low.

ciS5i3 rA With one or more penetration flow paths with two PCIVs nsopr either the inoperable PCIVs must be restored to H OPERABLE status or the affected penetration flow path must a-be isolated within I hour.

The method of isolation must include the use of at least one isolation barrier tha canno beadversely affcoted by a single active failure.

S~Isolationh barriers that meet this criterion are a closed and de-activated automatic valve, a closed mnual valve, and a blind flange.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two PCIVs.

For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions.

With'one or more penetration flow paths with one PCIV noper the inoperable valve must be restored torg OPERABLE status or the affected penetration flow path must be isolated.

The method of isolation must include the use p f at least one.isolation barrier that cannot be adversely cno affected by a single activevfailure.

Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange.

~A check valve may not be used to isolate the affected tration.

Required Action C.1 must be completed within th h

ofmpletion Tim.

The Comletion Tie o ConditiBurs is reasonable considering the relative stability is onl closed system (hence, reliability) to act as a For penetration isolation boundary and the relative importance pof supporting primary ontatnment OPERABILITY during (continued)

Rev 1, 04/07/95 J '-

8 3.6-20 BWR/4 STS 9tvij;6.-

F,

INSERT ACTIONS ASA-1 Note 2 applies to the isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verfied closed by administrative means.

Allowing verification by administrative means is consodered acceptable, since the function of locking, sealing, or securing of components is to ensure that these devices are not inadvertently repositioned.

I T%.

INSERT Page B 3.6-20

--Eý Revision E

ljcle.

4

/1v~

ACTIONS~~

LSn.. (cniud reasonabl e considering the instrument and the smal p pe dIamter of penetration (hence, reliability) to act as a I

S penetration isolation boundary and the small pipe diameter of the affected penetrations.

In the event the affected penetration flow path is isolated in accordance with o

Required Action C., the affected penetration must be TNuIZ.,

verified to be isolated on a periodic basis.

This is C..,

4 necessary to ensure that premry containment penetrations p..

'e.

required to be isolated following an accident are isolated.

Sj" The Campletion Time of once per 31 days for verifying each affected penetration ts isolated is appropriate because the valves are operated under t

adinistrative controls and the

/ " ' probability of their mISalignmnt is low.

.bI*-2*,

Condition C is modtfied by a Note indicating that this nCondition is only applicable to penetration flow paths with ronly one tIV.

For penetration lowin paths with two PCIVs,o SConditions A and B provide tere31 ap fo rvef ng e

Rfeq*ued Aeti*on C.2 is msod ted by a aup e valves and blind flanges located in high raiiation areas I " allows them to be verified by use of administrative means. ( t4 (i£T verification by administrative means is considered \\ *Qr*av.6 I

_ ~~acceptable, since aceusstthsars st*clv

-o restricted.

erefore, probability of iisalggnment 1

.. 1-1 Cthese valves, once they have been verified to be in thei proper position, is low.e t pa only on

___V Fo eerainfo ptswt toPI leakage rate not itn limoid umptions of the safety)pr

[

o analysis ynotbe

t.

Thref

. t eakae tbe I

resoured to within limit withinfrs.

straon can be 0

accomplished by isolating the penetration that caused the alimit to be e veeded by us e of'ne closed and de-activated m

I II automatic valve, closed manual valve, or blind flange.

When I

/

A pei n vetration is isolat, the leakage rate for the isolated penetration is assumed to be the actual path leakage II k

threugh the isolation device.

If two isolation devices are used to isolate the penetration, the leakage rate is assumed (continued) r oR/4 STS B 3.6-21 Rea 1, 04/07/c b REVISION E

INSERT C.1 and C.2 This Required Action does not require any testing or device manipulation.

Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position.

SINSERT Required Action C.2 Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means.

Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertantly repositioned.

INSERT Page B 3.6-21 Revision E N

'4:

4 t!!

4

£ e__._

PCIVs B 3.6.1.3 BASES ACTIONS Li (continued) to befthe lesser actual pathway leakage of the two devices.

The 9 hour1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months Completion Tim is reasonable considering the tim required store the leakageby isolating the penetratlo and t relative importance of 4arnMMr Sleakage to the overall containment

,\\ r'"( /

"r.I.

E-2. andE.

In the event o or more containment purge val v are not within the p 9e valve leakage limits, purg lve leakage must be ored to within limits or the fected 5 W"* j penetra n must be isolated.

The of isolation must be by e use of at least one is on barrier that cannot be versely affected by a si active failure.

Isolation issthtne hs r io-r a [closed nd..

- I de-activated automatic Vye closed manual valve, and blind flange]. If a purge ye with resilient seals is utilized SR 3.6.1.3.7 specified Completion Tim is reasonab consideri h

one containment purge valve remains sad so thatigllssolatd be n the iot sh ouldan eveth occuir.d Acisn REquire Actindesrtino requir.Te anyrtest c ve calv manipulation ath ersurt ihatconvolves erit onethatitons redtobe isola te ide contawinmeant potient wialyloge capable of beingmipstoe auoareinal th ort`

poiton For the isolation devicesn shoul ente NE ocr3. f N R ired wti theon d

onsidred reasonabei n

vlvew ofnipulath

. Raccess ity ivle eiiothttoeisolation devicesadoteaeiitt' cotoltsitha wreil ensurestin.Fo that isolation devicemslgmn s

a unlikely peao nal nve fteiacssibility.o h (continued)

BVR/4 STS 8 3.6-22 Rev 1, 04/07/95

.41 INSERT ACTION E E.1 With one or more penetration flow paths with LPCI System or CS System air operated testable check valve leakage rate not within limits, the assumptions of the safety analysis may not be met.

Therefore, the leakage must be restored to within limit within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, or closed manual valve.

When a penetration is assumed to be the actual pathway leakage through the isolation device.

If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable considering the time required to restore the leakage and the importance to maintain these penetrations availabe to perform the required function during a design basis accident.

INSERT Page B 3.6-22 Revision E

4. A

-i 0

0 f

I PCIVs

B 3.6.1.3 BASES ACTIONS F.I. E.2, and E.3 (c tinued)

/ IFor the containment. urge valve with resilient seal *hat is

\\

!ISR 3.6.1.3.7 must.6 performed at least once ever* [ ] days.

IIseal is detect dand confirms that the leakage

te of the I

IF~l

! Icontatnment pu je valve does not increase dunlQ the time I

I Ithe penetratioa is Isolated.

The normal Freq ncy. for SISR 3.6.1.3.7 *s184 days.

Since more relianc is placed on SIa single valv* while in this Condition, it I5 prudent to i

\\Iperform the *Rmore often.

Therefore, a Fre uency of once I

\\Iper [ ] day was chosen and has been shown t be acceptable If any Requtred Action and associated Completion Time cannot be met in NOSE 1, 2, or 3, the plant most be brought to a NOD0E in which the LCD does not apply.

To achieve this status, the plant must be brought to at least NODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to NODE 4 withtn 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without ch*_14t paant syst

(~~)

If any Required Action and associated Completion Tim cannot the*

be pla ctdin ondto mu tnb Ieiahthey intae d

s to suspn oertioswt oeta o

probabiity of tav el draindown a subsequnt potetia onp u

ase.Atos must contine utl spDeRls a spetde d

and vovirm es) a rt rt or l

-e to PeRABLE snitatu.

I suspendin agn th w

in plosing tf h conainmengthu raco valessoel(PRs

)

n t

ices drin e the tim resiual heat removal (RiR) shutdown cooling isolation valves, an a1ternative Required Action is provided to (continued)

Rev 1, 04/07/95 BWR/4 STS B 3.6-23 8 3.6.-23 BWR/4 STS

PCIVs 8 3.6.1.3 BASES (continued) itmediately initiate action to restoM the valve(s) to OPERABLE status.

This allows RHRftIremain in service while actions are being taken to restore the valve.

SURVEILLANCE REQUIREMENTS Each 118] inch pr ry containment purge valve is required to be verife aldcoe at3dyite al.TsS isdsind nur ha rosbrah fprmr cotinm sntcue a ndetn rsu u ro e seaiidled closed mshavemtiv r1 toy ithervalveThs opertor emovd. Tis an ea ihdb eeegn (R ef.g 4),urelae toa p marys containment purgemalveus giveanm (e fe tdistcaussdb nionadforNten1 of the ACIOs oeing o e ritmfe eair s ton t

hainet prevalve. Thisal ed opu vle to em o pnd itutrslignaf reo hisy ofth purge valve s

pro ide lhesaed ret r

ionsl are t

vav opne tl as neesay fo re tn rpas.Ec opnerovied onei reabi ins to close d

,r L if n iesay to Ic to ffle te r

oepi

s.

on iar thp ne atioprgnaleta The sRalid mlodifed bus N otie sttn tohat priarye cotaine t pourge of e

seti oe ar o nlyrqie tohe arseapledt cls in NOesul of2 and 3.

if atie Leerc Inside primar contolsto met he S duing he in (ecolvtisud BiR/4 STS 3 3.6-24 Rev 1, 04/07/95 ACTIONS i

cju-vý-W-'ý =C-101 V

V Rev 1, 04/07/95 8 3.6-24 BW/4 STS

i-i REVISION E

PCIVs B 3.6.1.3 SURVEILLANCE ILR.6.1.3Lf" ce

~

o-~tzJz eu'e REQUIREMENTS (continued)

This SRthat each primarycontainment isolation

""anual va-lve, an blind flanged that is located outside primary containmentran-Tis required to be clo inga accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

This SR does not require any t osttng or val v manipulation.

Rather, it involves verification that those outside primary containment, and capable of being mispositioned, are ISO in the correct osition.

Since verification of valve pos t on o outside primary containment is relatively e asy, the 31 day Frequency was chosen to provide added CI aassurrance W.Oat

TeZZ are in the correct positions.

Two Notes have been added to this SR.

The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls.

Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during NODES 1, 2, and 3 for ALARA reasons.

Therefore, the

.SO too~s;,

pro M, once they have

- *,h d~mA, 1 been verified to be in the proper position, is low. A 1

J e.'w second Note has been included to clarify that PCIVs that areý m,

-,a vo open under administrative controls are not required to meet A (,*A bi,$h, the SR during the time that the PCIVs are open.,

~~~qI ~

~

0 AV,

e1.J S

hi's SR16E

)that each primary contaiqnt manual

~~~~~~~

acci I~ei.

ec x,

isolation valve and blind flange.that tis located insi 41 f

3 primary containment.m is 'lrd 0 c a ur ng accident clndtions is closed.

The SR helps to ensure that

?'

pcost accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

inside primary containment, the Frequency defined as *prior to entering MODE 2 or 3 from MOME 4 if primary if.,,.e, 4

containment was de-inerted while in NODE 4, if not performed dtv' ty within the previous 92 days' is appropriate since these are operated under administrative controls and the probability of their misalignment is low.

(continued)

Rev 1, 04/07/95 BWR/4 STS 41 9A%

4P--Vt SJOLf"

)-ý5E B 3.6-26

INSERT SR 3.6.1.3.2 This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing or securing.

INSERT SR 3.6.1.3.3 This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing or securing.

bvi INSERT Page B 3.6-26

- -ATO Revi si on E

PCIVs B 3.6.1.3 RASES SURVEILLANCE REQUIREMENTS S....

k*

Verifying the isolation tin of each power operate c-,

automatic PCIV is within limits is required to demonstraete C(O)

OPERABILITY.

MSIVs may be excluded from this SR since NSIV full closure isolation tim is demonstrated by SR 3.6.1.3.ý The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

The QgtAgn9E1i Frequency of this

(*i/ L fin accordance with the requirements of the Inservice S'-

Testing Program kflY._3.

Rev 1, 04/07/95 BWR/4 STS BASES A -

LR3.6.L.L.I4L(ntinued)

Two Notes have been added to this SR.

The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls.

Allowing PAI verification by administrative controls is considered "A

acceptable since the primary containment is inerted and access to these areas is typically restricted during I

NODES 1, 2, and 3 for ALARA reasons.

T e.rer th V,

probability of misalignment of these a once they have been verified to be in their proper posittFon, is low.

A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to met the SR during the time that the PCIVs are open.

SR 3~.6.1.r.kig The traversing incore probe (TIP) shear isolation valves are actuated by explosive charges.

Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required.

Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed.

The 31 day Frequency is based on operating experience that has demonstrated the reliability of the explosive charge continuity.

7:

B 3.6-27

PCIVs B 3.6.1.3 BASESt Su RE (continued)

Rev 1, 04/07/95 IRVEILLANCE

'QUIREMENTS SR 3.6. 1.3.7 (continued)

OPERABILITY.

Operating Hence has demonstrated that this type of seal has t potential to degrade in a shorter tim period than do o er seal types.

Based on this observation and the Eportance of maintaining this penetration leak ght (due to the direct path between primary contaiT nt and the environment), a Frequency of 184 days was tablished.

Addition y, this SR must be performed once within 9days after o ning the valve.

The 92 day Frequency wa osen rec zing that cycling the valve could intr o1e ladd ional seal degradation (beyond that wh occurs to a v ve that has not been opened).

Thus,

reasing the nterval (from 184 days) is a prudent lasure after a valve has been opened.

The SR is modified by a Note st ieg that the primary containment purge valves are ly required to meet leakage rate testing requireet

/NODES 1, 2, and 3. If a LOCA inside primary coetainme occurs in these NODES, purge valve leakage must be mnized to ensure offsite Vrdiflogicg that e

i tsin timets. At otheratimi s when Theislaio tMere tes enue htteNVwl slt the purA aalyses a enures thcapable of clostng (eg. duigh(ngo raite fuel), pressurization Iconcerns arn pesn and the purge valves are not rquired to met any specific leakage criteria.

Sit 3.6.1.3.ifr Verifying that the isolation tin of each NSIV is within the specified limits is required to demonstrate OPERABILITY.

The isolation tin test ensures that the HSIV will isolate in a time period that does not exceed the tines assumed in the ODA~analyses.

This ensures that the calculated radiological consequences of these events remain within 10 CFR 100 limits. The Frequency of this SR is in accordance with the requirements of the InservicA Testing Program 8 3.6-2.8 BVR/4 S"TS

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6

'A (continued)

Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary contaitment following a DBA.

This SR ensures that each automatic PCIV will actuate to its isolation position

. 2 LcO c-1, n

r contaituent isolation signal.

The LOGIC SYSTEM t J *-FUN E

- TI 5overlaps this S to

-rovide complete testing o s

tFi-l'i

-function.

The 1m-nth

-37s 0 1 a VFrequency was developed considering its ruden th thisn..

tr."'

e _.

...io Surveillance be performed only during a age s nce isolation of penetrations would eliminate cooling water fow and disrupt the normal operation of many critical

"---q components.

Operating experience has shown that these Scomponnts usually pass this Surveillance when performed at

.ejj4Y-'-hi~

month Frequency.

Therefore, the Frequency was

(

--._c concc1ided to be acceptable from a reliability standpoint.

t b)e O

This SR requiresa dmnstration that each reactor

~ss~~ipoS,'*.oP instrumentation line excess flow check valve (EFCV) is 0

by verifying that the'valv8Lr9e CuitiiY P1 L%8-p-ov on a simulated instrIment aine

reaKj, MIs RK prov s assurance that the instrumentation line EFCVs will perform so that predicted radiological cons eel

.i I exceeded during the postula fts. unt line break i

- -"~4-

~

event evaluated hn Referencey LIs Xolue

.o Fbrequencyple frIm as r s

m this surve ance under te ToIPt sh that i during a plvent a act*at d

thby e./oiv

((---"itinentiu Jl for an ful ed transient is the.

osrveille wt

,re as*srmeda th the reactor at a

tr.

Opere nJ Ir.

-*",-7_

M (exper *nee he/shown that ths apnents usuall ypass this\\

S-r, I,I awn performoa 118] month Fc ontiue d) fR/A

'SF B.a reliability s 3

ad nt.

Of 444

_s-r V;

,\\&

_*The TIP shear isolatien valves are actated by explosive.

"-*~charges.

In, j lane functional test is not possible with

/'-*. %. -

this design.

The explosive squib is..emoved and. tested to S~provide assurance that the valves will actuat~e when (continued)

OWR/4 STS B 3.6-29 Rev 1, 04/07/95 REVISION E

PCIVS B 3.6.1.3 C LJA RArF*

SURVEILLANCE REQUIREMENTS SRB.LL(continued) required.

The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired 4.')

or from another batch that has been certified by having o*ar )

of the batch successfully fired.

The Frequency of to s

on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.._

This SR ensures that th ekg ate of secondary containment bypass I age paths is less than the specified leakage rate.

Th provides assurance that the assumptions in the radiol al evaluations of Reference 7 are met.

The leakage rate each bypass leakage path is assumed to be the maxi pathway leakage (leakage through the worse of the two olation valves) unless the penetration is isolated by u of one closed and de-activated automatic valve, cl manual valve, or blind flange. In this case, the akage rate of the isolated bypass leakage path is ass to-be the actual pathway leakage through the isolation device.

If both isolation valves in the penetratlo closed, the actual leakage rate Is the lesser le ge rate of the two valves.

This method of quantifyi imum pathway leakage is only to be used for thi (i.e.,.

Appendix, maximum pathway leakage limi are to be quantified in accordance with Appendo

).

The Frequency is required by 10 CFR 50, Appendix 3 s modified by approved exemptions (and therefore, the quency extensions of SR 3.0.2 smy not be applied), s cc the testing is an Appendix 3, Type C test. This SR ly imposes additional acceptance criteria.

e I is added to this SR which states that these va es are only required to met this leakage lmit in ES 1, 2, and 3.

In the other conditions, the actor Coolant System is not pressuriz and specific nmary containment leakage limits are Srequired.

[Bypas eakage is considered part of L viewer's Note:

Unl specifically exempted].]

(continued)

Rev 1, 04/07/95 BWP,/4 STS 8 3.6-30

PCIVs 8 3.6.1.3 BASES SURVEILLANCE e'

REQUIREMENTS (continued The analyses in Referenc are based on leakage that s

than the specife kage rate.

Leakage through each MSIV must be : (11.5 scfh when tested at A.

f m psigi. The MSIV eakage rate must be verflred to be in accordance with the leakage test requirements of til~

ves. a, 0 only re1 t

is l a g. m - n ES

, 2,

3.

In t other 1ond ions, the actor

.ol ft Systg is. not sui ze pcf m

TO

.a,

~,a This ensures w*

A, that NSIV leakage is properly accounted for in determining the overall primary containment leakage rate.

The Frequency

~ -~A~

r'I qu reo y1 0 AppendlVa mispo contaitnn i

reIied rs rooe ins ces, thee valve a reuie to cpabeo Tomati clMoin d

gthertan E 1 2 Sureilanc o,,I,

,,;o.

a r212t;*eprovides

.va W/ /b assurance that t.

g w

l areot W-nJ a' kagt 0Au jous Do.iota.

wih rg ale witthe rsliea l

gat rqec t)FtC ons; usS3..2whc I sFr Ivalvi are only equired to meet tnh cI).ined_,eav e-.rate din I MOES 1,

2, 3, since this boiwhen the eac sr Cootant Sy em is pressurized and prima contaient.

(tirequired.

I eBsI nst Ices, the valves-&

requiredvto ca p4/e of oma~tItCa11 closing during ES*

other than S 1, 2,

, vr.s c t e

,-,*l-*

nL these h~er MIES or coed~ttoýns.ý

ý:-

I A Nt: This SR Is on require for thos lat,-]

w-i vth irgev~alves with resili* seals allowed toe open:*

IIdurti

[14OE 1, 2, 3, or 4] S having blocking deces, thatI:

(cninued)

BMR/4 STS 8 3.6-31 Rey 1, 04/07/95

4i INSERT SR 3.6.1.3.11 each air operated testable check valve associated with the LPCI and CS System vessel injection penetrations.

D INSERT SR 3.6.1.3.11 FREQ The Frequency is required by the Primary Containment Leakage Testing Program.

INSERT Page B 3.6-31 Revision E

PCIVs B 3.6.1.3 BASES SURVEILLLANCE SR 3.6.1.3.15 continued)

Verifying ea inch primary containment urge valve is blocked to strict opening to:s [SO]% is quired to ensure REQUIREMENTS 1A that the V ves can close under DBA condit ons within the enh ai2 tins ass in the analysis of Referen s 2 and 6. [The s

R If bnist vV w

SR is modifi by a Note stati ng that s SR is only required to met in MODES 1, 20 and If a LOCA occurs, rg

1.

tW uei a

aatf0tSn I ci the purge va ves must close to maintai containment leakage tin on to b coai t uusi within the-,

ues assumed in the accide t analysis. At v0estg No dif ntai ed t0a e3 s

ot p other tin on purge valves are requi to be capable of ve Cs rg V&

3 de t analy.

I con S0 closing (.. during movement f irra ated fuel r

e"i f

assemblie pressurization conofernis" not present, thus e g d

"a ated ul the pu valves can be fully a 9 118] month va tstnisa a Frequen is appropriate becauseFt; blocking devices are y

t typica removed only during a re Wing outage.

a -13P REFERENCES I

FSA*-

.,r Y',

t/'KA C*T F.*

" "3.1 Rev 1, 04/07/95 B 3.6-32

/

IR/4 STS BAE i

//

(91 Rrtvýstdo-

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES I"-T

/

4s JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS-BASES: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

RETENTION OF EXISTING REQUIREMENT (CLB)

CLB1 ITS 3.6.1.3 has been revised to reflect the current licensing requirements of JAFNPP, that no special vent and purge valve leakage

-limits, flow path exceptions, or Surveillance Requirements exist in the CTS 3/4.7.

The bracketed, ISTS 3.6.1.3 Action E, SR 3.6.1.3.1. SR 3.6.1.3.7, and references to purge valve leakage limits are not applicable and have been deleted.

Subsequent Surveillance Requirements have been renumbered as applicable.

The Bases has been revised to reflect this change.

CLB2 ISTS 3.6.1.3 ACTION G and ACTION H have been deleted to reflect the current licensing requirement of JAFNPP, that no PCIVs are required to be OPERABLE during movement of irradiated fuel, or CORE ALTERATIONS.

Subsequent ACTIONS have been renumbered as applicable.

CLB3 Not Used.

CLB4 ISTS SR 3.6.1.3.2 Note 2 (ITS SR 3.6.1.3.1 Note 1) has been revised to reflect the current licensing requirement of JAFNPP. CTS 3.7.B.4, that for periods when primary containment integrity is required, inerting and de-inerting be performed using the 27MOV-121 (low-flow, 6 inch) valve, and the 27MOV-120 (full-flow, 12 inch) valve shall be closed.

The Bases Background and the discussion of SR 3.6.1.3.1 has been revised to reflect this current licensing requirement.

CLB5 ITS SR 3.6.1.3.5 has been revised to reflect current licensing requirements at JAFNPP, CTS 4.7.D.1.a. that the Frequency for verifying isolation time of each automatic PCIV except for MSIVs is in accordance with the Inservice Testing Program.

CLB6 ITS SR 3.6.1.3.6 has been revised to reflect current licensing requirements at JAFNPP, CTS 4.7.D.l.d, that the isolation time of each MSIV is a 3 seconds and s 5 seconds in accordance with UFSAR. Table 7.3

1. Primary Containment Isolation Valves, and the Frequency for the Surveillance is in accordance with the Inservice Testing Program.

CLB7 Not Used.

CLB8 ITS SR 3.6.1.3.8 has been revised to reflect current licensing requirements at JAFNPP, CTS 4.7.D.l.b, that the Frequency for verifying each reactor instrument line EFCV actuates to the isolation position on a simulated (142) instrument line break is in accordance with the Inservice Testing Program.

In addition, the requirement to restrict flow to s 1 gph has been deleted since the JAFNPP analysis does not assume a specific leakage through the EFCVs.

JAFNPP Page 1 of 6 Revision E

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433.

REVISION 1 ITS-BASES: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Editorial changes have been made for enhanced clarity or to correct a grammatical/typographical error.

PA2 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific system/structure/component nomenclature, equipment identification or description.

PA3 The information for ITS SR 3.6.1.3.1 Note 1, SR 3.6.1.3.10 Note 1. and SR 3.6.1.3.11 Note 1. has been deleted, since there are no PCIVs required to be OPERABLE in MODES other than MODES 1, 2, and 3 that have specific leakage limits for JAFNPP.

Subsequent Notes are renumbered as applicable.

PA4 The correct LCO number has been provided.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 ITS 3.6.1.3 has been revised to reflect specific differences based on the JAFNPP design of the vent and purge system.

The vent and purge valves at JAFNPP are of two sizes 20 inch and 24 inch.

DB2 ITS 3.6.1.3 APPLICABLE SAFETY ANALYSES has been revised to reflect specific differences based on the JAFNPP design of the vent and purge system.

The brackets have been removed and the information retained, since the JAFNPP two valve configuration for purge and vent lines is consistent with meeting the single failure criterion.

DB3 ITS 3.6.1.3 has been revised to reflect the specific JAFNPP reference requirements of UFSAR, Section 14.6. Analysis of Design Basis Accidents.

DB4 ITS 3.6.1.3 has been revised to reflect the specific JAFNPP reference requirements of UFSAR, Section 6.5.3.2. Steam Line Breaks.

0 DB5 ITS 3.6.1.3 has been revised to reflect the specific JAFNPP reference requirements of UFSAR, Section 14.5.2.3, Main Steam Line Isolation Valve fr Closure.

N DB6 Not used.

DB7 ITS 3.6.1.3 has been revised to reflect the specific JAFNPP reference requirements of UFSAR, Section 14.8.2.1.1, Loss of Coolant Accident.

JAFNPP Page 3 of 6 Revision E

';,1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB8 ITS 3.6.1.3 Applicable Safety Analyses has been revised to reflect the specific JAFNPP DBA analysis.

UFSAR, Section 14.8.2.1.1, does not assume a specific closure time for PCIVs.

The analysis assumes that the leakage from the containment is L. throughout the accident.

The bases for the valve closure times are specified in the UFSAR Section 7.3.3.1 and the actual times are specified in UFSAR, Table 7.3-1.

DB9 Not used.

DB1O The allowances of Technical Specification Task Force (TSTF) Technical Specification Change Travelor Number 30, Revision 3. was incorporated as documented in TA3.

The appropriate reference for a closed system has been incorporated.

DB11 ITS 3.6.1.3 has been revised to reflect the requirements of the control rod drop accident.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

'4' TA1

-The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 45, Revision 2. have been incorporated into the revised Improved Technical Specifications.

I TA2 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 46, Revision 1, have been incorporated into the revised Improved Technical Specifications.

TA3 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 30, Revision 3, have been 6 incorporated into the revised Improved Technical Specification.

The allowance was included in accordance with L4.

TM The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 52. Revision 3, have beenl~)I incorporated into the revised Improved Technical Specifications.

r I

TA5 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change. Traveler Number 207, Revision 5. have g

been incorporated into the revised Improved Technical Specifications.

c TA6 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 269, Revision 2. have been incorporated into the revised Improved Technical Specifications.

Page 4 of 6 Revision E 3.AFNPP

JUSTIFICATION-FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS-BASES: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA) tit TA7 The changes presented in Technical Specification Task Force (TSTF)

Technical Specification Change Traveler Number 323, Revision 0, have been incorporated into the revised Improved Technical Specifications.

1 DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X1 ISTS 3.6.1.3 ACTION D. for secondary containment leakage bypass (and MSIV) leakage rate not within limit, is being revised.

Since secondary containment bypass leakage is not accounted for in the DBA LOCA radiological analysis it is not addressed in JAFNPP CTS.

CTS 4.7.2.b Surveillance Requirement for MSIV leakage is contained in proposed ITS SR 3.6.1.3.10 (ISTS SR 3.6.1.3.13).

Proposed ITS 3.6.1.3 ACTION D, addresses the condition for one or more penetration flow paths with one or more MSIVs not within leakage rate limits, provides a Required Action to restore leakage rate to within limits, and establishes a Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (19).

These requirements are consistent with those of NUREG-1433, Revision 1, except that the Completion Time is increased from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Since the secondary containment bypass leakage is not considered, the Completion Time was revised to be consistent with ISTS 3.6.1.3 ACTION A for an inoperable MSIV.

As a result of these changes, the bracketed exceptions of ITS 3.6.1.3 ACTION A (L1O),

and ACTION B (L3) have been revised to exclude MSIV leakage limits as a factor for PCIV inoperability.

X2 The brackets have been removed and changes made to ITS 3.6.1.5 ACTION G (ISTS 3.6.1.3 ACTION I) to reflect the appropriate Required Action and associated Completion Times for MODE 4 and 5 operations.

In addition, the Bases has been modified to reflect this change.

X3 The brackets have been removed and the ITS SR 3.6.1.3.1 (ISTS SR 3.6.1.3.2) requirement to verify each 20 and 24 inch primary containment vent and purge valve is closed, has been included, based on CTS 4.7.B.4 requirement for 27MOV-120 to be verified closed (7).

The Bases Surveillance description has been modified as required to reflect the JAFNPP plant requirements.

X4 Not Used X5 Not used.

4k JAFNPP Page 5 of 6 Revision E

.0 /

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433. REVISION 1 ITS-BASES: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES (PCIVS)

DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

X6 ITS SR 3.6.1.3.9 Frequency of 24 months to remove and test the explosive squib from each shear isolation valve of the TIP System has been included (M4).

This Frequency is consistent with similar testing which is performed at the refueling cycle frequency.

X7 ISTS SR 3.6.1.3.15, to verify each primary containment purge valve is blocked to restrict valve opening, has been deleted.

In accordance with the ISTS Bases SR 3.6.1.3.15 Reviewers Note, this Surveillance is not required for valves which have blocking devices permanently installed.

JAFNPP blocking devices are permanently installed.

X8 NUREG-1433, Revision 1, Bases reference 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.

X9 This change to ITS 3.6.1.3 Bases A.1 and A.2 was approved to be made in NUREG-1433, Revision 1 per change package BWR-15, C.5, but apparently was not made.

X1O Not used.

Xl ITS 3.6.1.3 has been revised to include reference to the Technical Requirements Manual (TRM) and the Inservice Testing (IST) Program.

The TRg will include the PCIV listing while the Inservice Testing Program will include the valve stroke times.

X12 ITS 3.6.1.3 ACTION E has been added to address the condition when the leakage rate specified in SR 3.6.1.3.11 (CTS 4.7.A.2.c) is exceeded for LPCI or CS System testable check valves.

The addition of this Action is similar to ACTION D for other leakage limits not within limits (i.e.,

MSIVs).

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is adequate as described in L10.

The Bases have been revised to reflect this added Condition including modifications to the description for Required Actions A.1 and A.2, Required Actions 8.1 and B.2, and Required Actions C.1 and C.2.

X13 ITS SR 3.6.1.3.11 (ISTS SR 3.6.1.3.14) Frequentcy has been revised to l

determine the leakage rate of hydrostatically tested valves In accordance with the Primary Containment Leakage Rate Testing Program (L13).

JAFNPP Page 6 of 6 Revision E

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES "4

1 I.

PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 APPLICABILITY:

Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

MODES 1, 2, and 3, When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."

Amendment 3.6-7 JAFNPP

PCIVs 3.6.1.3 ACTIONS NOTES -----------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. --------- NOTE --------- A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except Only applicable to enetration flow path for main steam penetration flow paths by use of at least line with two PCIVs.

one closed and de-activated AND automatic valve, One or more closed manual valve, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main penetration flow paths blind flange, or steam line with one PCIV check valve with flow inoperable for reasons through the valve other than Conditions secured.

D and E.

AND (continued)

Amendment (Rev. E) 0:

"q al I

3.6-8 JAFNPP

PCIVs 3.6.1.3 B. --------- NOTE --------

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with two PCIVs inoperable for reasons other than Conditions D and E.

B.1 Isolate the affected gynetration flow path use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months At,* I J.UIIJ CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2----------NOTES........

1.

Isolation devices in high radiation areas may be verified by use of administrative means.

2.

Isolation devices Once per 31 days that are locked, for isolation sealed, or devices outside otherwise secured primary may be verified containment by use of administrative AND means.

S.....................

Prior to entering MODE 2 Verify the affected or 3 from penetration flow path MODE 4, if is isolated.

primary containment was de-inerted while in MODE 4, if not performed within the previous 2 days, for isolation devices inside primary containment II

I

______________I a

- hi (continued) v Amendment (Rev. E)

APfTTA'IIlC 3.6-9 JAFNPP T I i

II

PCIVs 3.6.1.3 1Tn,1 U I.1 4-.4J II. IlII

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

NOTE --------

Only applicable to penetration flow paths with only one PCIV.

One or more penetration flow paths with one PCIV inoperable for reasons other than Conditions D and E.

.1 C.1 AND C.2 Isolate the affected genetration flow path use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

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

1.

Isolation devices in high radiation areas may be verified by use of administrative means.

2.

Isolation devices that are locked.

sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Once per 31 days AI (continued)

Amendment (Rev. E)

ArTTAII(C 'Ii.,~vl-4 'n n-'*a'I JAFNPP 3.6-10

di' PCIVs 3.6.1.3 (Rev. E) 3.6-11 Amendment k,4I a *'1"t" #%LIe*

t 4,

A*I AtI I.UM3 KOI*LUCU

_)UJ CONDITION REQUIRED ACTION COMPLETION TIME D. One or more D.1 Restore leakage rate 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths to within limit.

with one or more MSIVs not within leakage rate limit.

E. One or more E.1 Restore leakage rate 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months penetration flow paths to within limit.

with LPCI or CS System testable check valve leakage limit not met.

F. Required Action and F.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A.

AND B. C, D, or E not met in MODE 1, 2, or 3.

F.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. Required Action and G.1 Initiate action to Immediately associated Completion suspend operations Time of Condition A or with a potential for B not met-for PCIV(s) draining the reactor required to be vessel.

OPERABLE during MODE 4 or 5.

OR G.2 Initiate action to Immediately restore valve(s) to OPERABLE status.

JAFNPP

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1

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

Not required to be met when the 20 and 24 inch primary containment vent and purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open as long as the full flow line to Standby Gas Treatment (SGT)

System is closed.

Verify each 20 and 24 inch primary 31 days containment vent and purge valve is closed.

SR 3.6.1.3.2

NOTES -----------------

1.

Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2.

Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation 31 days manual valve and blind flange that is located outside primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

3.6-12 Amendment onti nued)

(Rev. E) o JAFNPP

PCIVs 3.6.1.3 emIntIrTaI AMPr DIITDMNT

fv-nntinifl 3UIVLiLLJ¶IL J4UJIL.U5b.*'*..'

'--.....---.

I SURVEILLANCE SR 3.6.1.3.3 NOTES..................

1.

Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2.

Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation valve and blind flange that is located inside primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

FREQUENCY Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-i nerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing 31 days incore probe (TIP) shear isolation valve explosive charge.

SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated automatic PCIV, except for with the NSIVs. is within limits.

Inservice Testing Program (continued)

Amendment (Rev. E)

JAFNIPP TI I AUrC DCfM1TDrMCM1*C (r-nn+in"Pd) aurvu-I 3.6-13

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify the isolation time of each MSIV is In accordance S3 seconds and s 5 seconds.

with the Inservice Testing Program SR 3.6.1.3.7 Verify each automatic PCIV actuates to 24 months the isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.8 Verify each reactor instrumentation line In accordance EFCV actuates to the isolation position with the on a simulated instrument line break.

Inservice Testing Program SR 3.6.1.3.9 Remove and test the explosive squib from 24 months on a each shear isolation valve of the TIP STAGGERED TEST System.

BASIS SR 3.6.1.3.10 Verify leakage rate through each MSIV is In accordance within limits of the Primary Containment with the Leakage Rate Testing Program.

Primary Containment Leakage Rate Testing Program SR 3.6.1.3.11 Verify the leakage rate of each air In accordance operated testable check valve associated with the with the LPCI and CS System vessel Primary injection penetrations is < 10 gpm when Containment hydrostatically tested at t 1035 psig or Leakage Rate

< 11 scfm when pneumatically tested at Testing

45 psig, at ambient temperature.

Program.

Amendment (Rev. E)

()

I M

1 JAFNPP 3.6-14

PCIVs B 3.6.1.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

BASES BACKGROUND The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs) to within limits.

Primary containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.

The OPERABILITY requirements for PCIVs help ensure that an adequate primary containment boundary is maintained during and after an accident by minimizing potential paths to the environment.

Therefore. the OPERABILITY requirements provide assurance that primary containment function assumed in the safety analyses will be maintained.

These isolation devices are either passive or active (automatic).

Manual valves. de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges and closed systems are considered passive devices.

Check valves, and other automatic valves designed to close without operator action following an accident, are considered active devices.

At least two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses.

One of these barriers may be a closed system.

The reactor building-to-suppression chamber vacuum breakers serve a dual function, one of which is primary containment isolation.

However, since the other safety function of the vacuum breakers would not be available if the normal PCIV actions were taken, the PCIV OPERABILITY requirements are not applicable to the reactor building-to-suppression chamber vacuum breakers valves.

Similar surveillance requirements in the LCO for reactor building-to-suppression (continued)

Revision 0 (Rev. E)

JAFNPP B 3.6-14

I /

PCIVs B 3.6.1.3 BASES BACKGROUND (continued) chamber vacuum breakers provide assurance that the isolation capability is available without conflicting with the vacuum relief function.

The primary containment suppression chamber and drywell vent and purge lines are 20 and 24 inches in diameter respectively, and are normally maintained closed in MODES 1, 2, and 3 to ensure the primary containment boundary is maintained.

The isolation valves on both the suppression chamber and drywell vent lines have 2 inch bypass lines around them for use during normal reactor operation or when it is not necessary to open the 20 and 24 inch valves.

The only primary containment vent path provided, by design, is from he common 30 inch suppression chamber and drywell vent line through two parallel lines with valves (one 6 inches in diameter, the other 12 inches in diameter) to the 24 inch Standby Gas Treatment (SGT) System suction line.

When in MODES 1 2, and 3 only the low-flow 6 inch line (with valve 27MOV-121) is allowed to be open whenever the 20 or 24 inch vent and purge valves are open.

The full-flow 12 inch line (with valve 27MOV-120) is required to be closed to prevent high pressure from reaching the SGT System filter trains in the unlikely event of a loss of coolant accident (LOCA) during venting.

Closure of these valves will not prevent the SGT System from performing its design function (that is, to maintain a negative pressure in the secondary containment).

APPLICABLE The PCIV LCO was derived from the assumptions related to SAFETY ANALYSES minimizin9 the loss of reactor coolant inventory, and establishing the primary containment boundary during major accidents.

As part of the primary containment boundaryo PCIV OPERABILITY supports leak tightness of primary containment.

Therefbre, the safety analysis of any event requiring isolation of primary containment is applicable to this LCO.

The DBAs that result in a release of radioactive material for which the consequences are mitigated by PCIVs are a LOCA control rod drop accident, and a main steam line break (MSLA).

In the analysis for each of these accidents, it is assumed that PCIVs are either closed or close within the required isolation times following event initiation. This ensures that potential paths to the environment through PCIVs (including primary containment vent and purge valves)

(continued)

Revision 0 (Rev. E)

B 3.6-15 JAFNPP

PCIVs B 3.6.1.3 BASES APPLICABLE SAFETY ANALYSES (continued) are minimized.

Of the events analyzed in Reference 1 for which the consequences are mitigated by PCIVs, the MSLB is the most limiting event due to radiological consequences to control room personnel.

The closure time of the main steam isolation valves (NSIVs) is a significant variable from a radiological standpoint.

The MSIVs are required to close within 3 to 5 seconds, after signal generation, since the closure times are assumed in the analyses (Refs. 2 and 3).

Likewise, it is assumed that the primary containment is isolated such that release of fission products to the environment is controlled.

The DBA analysis does not assume a specific closure time for primary containment isolation valves (PCIVs).

The analysis assumes that the leakage from the primary containment is 1.5 percent primary containment air weight per day (L,) at pressure P° throughout the accident.

The bases for PCIV closure times, and the specified valve closure times, are specified in UFSAR 7.3.3.1 and UFSAR Table 7.3-1 (Refs. 4 and 5). respectively.

The single failure criterion required to be imposed in the conduct of plant safety analyses was considered in the original design of the primary containment vent and purge valves.

Two valves in series on each vent and purge line provide assurance that both the supply and exhaust lines could be isolated even if a single failure occurred.

PCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii)

(Ref. 6).

SPCIVs form a part of the primary containment boundary.

The PCIV safety function is related to minimizing the loss of reactor coolant inventory and establishing the primary containment boundary during a DBA.

The power operated. automatic isolation valves are required to have isolation times within limits and actuate on an automatic isolation signal.

The 20 and 24 inch vent and purge valves must be maintained closed or blocked to prevent full opening.

While the reactor building-to-suppression chamber vacuum breakers isolate primary contalm.ent penetrations, they are excluded from this Specification.

Controls on their isolation function are adequately addressed in LCO 3.6.1.6. Reactor Building-to-Suppression Chamber Vacuum Breakers.*

The valves covered by this LCO are listed in Reference 7.

The associated stroke time of each automatic PCIV is included in the Inservice Testing (IST) Program.

(continued)

Revision 0 (Rev. E)

LCO r

0 JAF'NPP B 3.6-16

PCIVs B 3.6.1.3 BASES LCO (continued)

APPLICABILITY ACTIONS The normally closed PCIVs are considered OPERABLE when manual valves are closed or open in accordance with appropriate administrative controls, automatic valves are de-activated and secured in their closed position, blind flanges are in place, and closed systems are intact.

These passive isolation valves and devices are those listed in eference 7.

MSIVs, Low Pressure Coolant Injection (LPCI) and Core S pray (CS) System air operated testable check valves must meet additional leakage rate requirements.

Other PCIV leakage rates are addressed by LCO 3.6.1.1, "Primary Containment,"

as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, most PCIVs are not required to be OPERABLE and the primary containment vent and purge valves are not required to be normally closed in MODES 4 and 5.

Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor vessel draindown.

These valves are those whose associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation." (This aoes not include the valves that isolate the associated instrumentation.)

The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO. separate Condition entry is allowed for each penetration flow path.

This is acceptable, (continued)

Revision 0 (Rev. E)

JAFNPP B 3.6-17

PCIVs B 3.6.1.3 BASES ACTIONS since the Required Actions for each Condition provide (continued) appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4.

Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System 0

subsystem is inoperable due to a failed open test return valve).

Note 4 ensures appropriate remedial actions are taken when the primary containment leakage limits are exceeded.

Pursuant to LCO 3.0.6. these actions are not required even when the associated LCO is not met.

Therefore, Notes 3 and 4 are added to require the proper actions be taken.

A.1 and A.2 With one or more penetration flow paths with one PCIV inoperable except for inoperabilities due to MSIV, LPCI or CS System air operated testable check valve leakage not within limit, the affected penetration flow paths must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured.

For a penetration isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available valve to the primary containment.

The Required Action must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam lines).

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the time required to isolate the penetration and the relative importance of supporting primary containment OPERABILITY during MODES 1, 2, and 3.

For main steam lines, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed.

The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months o

for the main steam lines allows a period of time to restore the MSIVs to OPERABLE status given the fact that HSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown.

(continued)

Revision 0 (Rev. E) j JAFNPP B 3.6-18

PCIVs B 3.6.1.3 BASES ACTIONS A.1 and A.2 (continued)

For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path(s) must be verified to be isolated on a periodic basis.

This is necessary to ensure that primary containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be in the isolation position should an event occur.

This Required Action does not require any testing or device manipulation.

Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position.

The Completion Time of *once per 31 days for isolation devices outside primary containment" is appropriate because the devices are operated under administrative controls and the probability of their misalignment is low.

For the devices inside primary containment, the time period specified "prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days" is based on engineering judgm*nt and is considered reasonable in view of the inaccessibility of the devices and other administrative controls ensuring that device misalignment is an unlikely possibility.

Condition A is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two PCIVs.

For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions.

Required Action A.2 is modified by two notes.

Note 1 applies to isolation devices located in high radiation areas, and allows them to be verified by use of administrative means.

Allowing verification by administrative means is considered acceptable, since access N

to these areas is typically restricted.

Note 2 applies to the isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by administrative means.

Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing of conents is to ensure that these devices are not inadvertently repositioned.

Therefore, the probability of mi sa iggnment, once they have been verified to be in the proper position, is low.

(continued)

JAFNPP B 3.6-19 Revision 0 (Rev. E)

PCIVs B 3.6.1.3 BASES ACTIONS (continued)

B.1 With one or more penetration flow paths with two PCIVs inoperable except for inoperabilities due to MSIV, LPCI or CS system air operated testable check valve leakage not within limits, either the inoperable PCIVs must be restored to OPERABLE status or the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active component failure.

Isolation barriers that =t this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two PCIVs.

For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions.

C.1 and C.2 With one or more penetration flow paths with one PCIV inoperable, the inoperable valve must be restored to OPERABLE status or the affected penetration flow path must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected bg a single active component failure.

Isolation barriers tnat meet this criterion are a closed and de-activated automatic valve, a closed manual valve and a blind flange.

A check valve may not be used to isolate the affected penetration.

Required Action C.1 must be completed \\,

within the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time.

The Completion Time of_

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable considering the relative stability of the closed system (hence, reliability) to act as a f

penetration isolation boundary and the relative importance M

of supprting primary, containment OPERABILITY during MODES 1, 2 and 3.

The closed system must meet the requirements of Reference 8.

The Completion Time of 72 M

hours for EFCVs is also reasonable considering the instrument and the small pipe diameter of penetration (hence, reliability) to act as a penetration isolation C

-w boundary and the small pipe diameter of the affected penetrations.

In the event the affected penetration flow path is isolated in accordance with Required Action C.1, the affected penetration must be verified to be isolated on a periodic basis.

This is necessary to ensure that primary containment penetrations required to be isolated following an accident are isolated. This Required Action does not (continued)

Revision 0 (Rev. E)

B 3.6-20 JAFNPP

PCIVs B 3.6.1.3 BASES ACTIONS C.1 and C.2 (continued) require any testing or device manipulation.

Rather, it involves verification, that those devices outside containment and capable of potentially being mispositioned are in the correct position.

The Completion Time of once per 31 days for verif ing each affected penetration is isolated is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low.

Condition C is modified by a Note indicating that this Condition is only applicable to penetration flow paths with

-T only one PCIV.

For penetration flow paths with two PCIVs, f

Conditions A and B provide the appropriate Required Actions.

This Note is necessary since this Condition is written specifically to address those penetrations with a single Required Action C.2 is modified by two Notes.

Note 1

=l applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative means.

Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted.

Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means.

Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these valves are not i

inadvertently repositioned.

Therefore, the probability of misalignment, once they have been verified to be in the proper position, is low.

D.1 With any MSIV leakage rate not within limit, the assumptions of the safety analysis may not be met.

Therefore, the leakage must be restored to within limit within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange.

When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual patlhway leakage through the isolation device.

If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway (continued)

Revision 0 (Rev. E)

JAFNPP B 3.6-21

PCIVs B 3.6.1.3 BASES ACTIONS D.1 (continued) leakage of the two devices. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable considering the time required to restore the leakage by isolating the penetration, the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown, and the relative importance of MSIV leakage to the overall containment function.

E.1 With the one or more penetration flow paths with LPCI or CS ste testable check valve leakage rate not within limit, te assumptions of the safety analysis may not be met.

Therefore, the leakage must be restored to within limit within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Restoration can be accomplished by isolating the penetration that caused the limit to exceeded by use of one closed and de-activated automatic valve, or closed manual valve.

When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device.

If two isolation devices are used to isolate the penetration. the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable considering the time required to restore the leakage and the importance to maintain these penetrations available to perform the required function during a design basis accident.

F.I and F.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3. the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to NODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

(continued)

JAFNPP B 3.6-22 Revision 0 (Rev. E) 0'.

/

/s PCIVs B 3.6.1.3 BASES ACTIONS (continued)

G.1 and G.2 If any Required Action and associated Completion Time cannot be met for PCIV(s) required to OPERABLE during MODE 4 or 5, the plant must be placed in a condition in which the LCO does not apply. Action must be immediately initiated to suspend operations with a potential for draining the reactor vessel (OPDRVs) to minimize the probability of a vessel draindown and subsequent potential for fission product release.

Actions must continue until OPDRVs are suspended and valve(s) are restored to OPERABLE status.

If suspending an OPDRV would result in closing the residual heat removal (RHR) shutdown cooling isolation valves, an alternative Required Action is provided to immediately initiate action to restore the valve(s) to OPERABLE status.

This allows RHR shutdown cooling to remain in service while actions are being taken to restore the valve.

SURVEILLANCE REQUIREMENTS SR 3.6.1.3.1 This SR ensures that the primary containment vent and purge valves are closed as required or, if open, open for an allowable reason.

If a purge valve is open in violation of this SR. the valve is considered inoperable.

The SR is modified by a Note stating that the SR is not required to be met when the vent and purge valves are open for the stated reasons.

The Note states that these valves may be opened for inerting, de-inerting, pressure control. ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided that full-flow line (with valve 27MOV-120) to the SGT System is closed.

This will ensure there is no damage to the filters if a LOCA were to occur with the vent and purge valves open since excessive differential pressure is not expected with the full-flow line closed.

The 20 and 24 inch vent and purge valves are capable of closing against the dynamic effects of a LOCA.

Therefore. these valves are allowed to be open for limited periods of time.

The 31 day Frequency is consistent with other PCIV requirements discussed in SR 3.6.1.3.2.

SR 3.6.1.3.2 This SR ensures that each primary containment isolation manual valve and blind flange that is located outside (continued)

Revision 0 (Rev. E)

'1

.3 to II

B 3.6-23 JAFNPP

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.2 (continued)

REQUIREMENTS primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

This SR does not require any testing or valve manipulation.

Rather, it involves verification that those PCIVs outside primary containment, and capable of being mispositioned, are in the correct position.

Since verification of valve position for PCIVs outside primary containment is relatively easy, the 31 day Frequency was chosen to provide added assurance that the PCIVs are in the correct positions.

Two Notes have been added to this SR.

The first Note allows valves, blind flanges or equivalent isolation methods located in high radiation areas to be verified by use of administrative controls.

Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons.

Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in the proper position, is low.

A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

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

SR 3,6.1.3.3 This SR ensures that each primary containment manual isolation valve and blind flange that is located inside primary containment and not locked, sealed or otherwise (continued)

JAFNPP B 3.6-24 Revision 0 (Rev. E)

/

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.3 (continued)

REQUIREMENTS secured and is required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

For PCIVs inside primary containment, the Frequency defined as "prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the-previous 92 days" is appropriate since these PCIVs are operated under administrative controls and the probability of their misalignment is low.

This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to M

be in the correct position upon locking, sealing, or securing.

Two Notes have been added to this SR.

The first Note allows valves, blind flanges and equivalent isolation methods located in high radiation areas to be verified by use of administrative controls.

Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons.

Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in their proper position, is low.

A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room.

In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

SR 3.6.1.3.4 The traversing incore probe (TIP) shear isolation valves are actuated by explosive charges.

Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required.

Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed.

The 31 day Frequency is based on (continued)

Revision 0 (Rev. E)

JAFNPP B 3.6-25

.4'.

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.4 (continued)

REQUIREMENTS operating experience that has demonstrated the reliability of the explosive charge continuity.

SR 3.6.1.3.5 Verifying the isolation time of each power operated automatic PCIV is within limits is required to demonstrate OPERABILITY.

MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.6.

The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.6 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses.

This ensures that the calculated radiological consequences of these events remain within 10 CFR 100 limits. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.7 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA.

This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal.

The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.1. "Primary Containment Isolation Instrumentation." overlaps this SR to provide complete testing of the safety function.

The 24 month Frequency was developed considering it is prudent that this Surveillance be performed only during a plant outage since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components.

Operating experience has shown that these (continued)

JAFNPP B 3.6-26 Revision 0

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.7 (continued)

REQUIREMENTS components usually pass this Surveillance when performed at the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.1.3.8 This SR requires a demonstration that each reactor instrumentation line excess flow check valve (EFCV) is OPERABLE by verifying that the valve actuates to the isolation position on a simulated instrument line break.

This SR provides assurance that the instrumentation line EFCVs will perform so that predicted radiological consequences will not be exceeded during the postulated instrument line break event evaluated in Reference 9.

The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.9 The TIP shear isolation valves are actuated by explosive charges.

An in-place functional test is not possible with this design.

The explosive squib is removed and tested to provide assurance that the valves will actuate when required.

The replacement charge for the explosive squib shall be from the same manufactured batch as the one ired or from another batch that has been certified by having one of the batch successfully fired.

The Frequency of 24 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4).

SR 3.6.1.3.10 The analyses in Reference 8 are based on leakage that is more than the specified leakage rate.

Leakage through each MSIV must be s 11.5 scfh when tested at t 25 psig.

The MSIV leakage rate must be verified to be in accordance with the leakage test requirements of the Primary Containment Leakage Rate Testing Program.

This ensures that MSIV leakage is properly accounted for in determining the overall primary (continued)

Revision 0 (Rev. E)

B 3.6-27 JAFINPP

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.10 (continued)

REQUIREMENTS containment leakage rate.

The Frequency is in accordance with the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.11 Surveillance of each air operated testable check valve associated with the LPCI and CS System vessel injection penetrations provides assurance that the resulting radiatior dose that would result if the reactor coolant were released to the reactor building at the specified limit will be small (Ref. 11).

The Frequency is required by the Primary Containment Leakage Rate Testing Program.

REFERENCES

1.

UFSAR, Section 14.6.

2.

UFSAR, Section 6.5.3.2.

3.

UFSAR, Section 14.5.2.3.

4.

UFSAR, Section 7.3.3.1

5.

UFSAR. Table 7.3-1

6.

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

7.

Technical Requirements Manual.

8.

UFSAR, Section 16.3.2.5.

9.

UFSAR, Section 5.2.3.5.

10.

UFSAR, Section 14.8.2.1.1.

11.

NRC Letter to NYPA, November 9.,

1978 NRC Safety.

Evaluation Supporting Amendment 40 to the Facility Operating License No. DPR-59.

Revision 0 (Rev. E)

JAFN1PP B 3.6-28

7 JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure 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

-4 4r".

I:

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS) y

Insert Nei Specification 3.6.1.4 Insert new Specification 3.6.1.4, "Drywell Pressure," as shown in the JAFNPP Improved Technical Specifications.

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure DISCUSSION OF CHANGES (DOCs) TO THE CTS

-I DISCUSSION OF CHANGES ITS: 3.6.1.4 - DRYWELL PRESSURE ADMINISTRATIVE CHANGES None TECHNICAL CHANGES - MORE RESTRICTIVE M1 A new Specification requiring drywell pressure to be less than or equal to 1.95 psig is proposed to be added.

This is required because the accident analyses of UFSAR, Section 14.6.1.3.3 and the power uprate analysis, assume this pressure as an initial condition.

Appropriate ACTIONS and a Surveillance Requirement are also proposed to be added.

The addition of this new Specification constitutes a more restrictive change necessary to ensure the accident analysis is met.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

None TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

None TECHNICAL CHANGES - RELOCATIONS None Page 1 of 1 Revision A JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

I NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS: 3.6.1.4 - DRYWELL PRESSURE TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

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

Page 1 of 1 Revision A

1 JAFNPP

I JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION

Drywell Pressure 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywell Pressure tCO 3.6.1.4 Drywell pressure shall be P:5 APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TINE A. Drywell pressure not A.1 Restore drywell 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within limit.

pressure to within limit.

B. Required Action and B.1 Be in NODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND 8.2 Be in NODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.4.1 Verify drywell pressure is within limit.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Rev 1. 04/07/95 BWR/4 STS 3.6-19

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433.

REVISION 1 ITS: 3.6.1.4 - DRYWELL PRESSURE RETENTION OF EXISTING REQUIREMENT (CLB)

None PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

None PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 The brackets have been removed and the proper plant specific value has been provided.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

None flT rrDECMrr aAvrn Alt A IIRMTT1Tfl AlIT PrmnTNT TRAVF[ER (TP)

UI Ir loc*EnIlJ-n*l i*-l "lltTI. s

.i I I m

None DIFFERENCE FOR ANY REASON OTHER THAN THE ABOVE (X)

None Page 1 of 1 Revision A JAFNPP I I

w I B

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure MARKUP OF NUREG-1433, REVISION 1, BASES

/4/

ell Pressure B 3.6.1.4 B 3.6 CONTAINMENT SYSTEMS B 3.6A1.4 Drywell Pressure BASES BACKGROUE The drywe1l pressure is limited during normal operations to preserve the initial conditions assumed in the accident analysis for a Design Basis Accident (DBA) or loss of 191 coolant accident (LOCA).

a.s APPLICABLE SAFETY ANALYSES Primary containment performance is evaluated or the entire spectrum of break sizes for postulated LOCAs (Ref. 1).

Among the inputs to the DBA is the in ti primar containment internal pressure 0Re a yses assume an initial drywell pressure of si g.

This limitation ensures that the safety analysis remains valid by maintaining the expected initial conditions and ensures that the peak LOCA drywel1 internal pressure does not exceed the The maximum ca culated drywell pressure occurs during the reactor blowdown phase of the DIA, which assumes an instantaneous recirculation line break.

The calculated peak drywell pressure f r this limiting event is JY p Tg (Ref.

K7 A

Drywell pressure satisfies Criterion 2 f

&..~

0,

=:)

LCO,'

In he vent of a DBA, with an initial drywell pressure psi the resultant peak drywell accident pressure

-I Ivtl'

~ll main ained below thefdrIywe11 <-*,

pressure.

~~~~

a, klw*-

APPLICABILITY BklR/4 STS In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

In NODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these NODES.

Therefore, maintaining drywell pressure within limits is not required in NODE 4 or S.

B 3.6-33 (continued)

Rev 1, 04/07/95

-4.

-A I

Drywell Pressure B 3.6.1.4 BASES (continued)

ACTIONS AJ1 With drywell pressure not within the limit of the LCO, drywell pressure must be restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The Required Action is necessary to return operation to within the bounds of the primary containment analysis.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, "Primary Containment," which requires that primary containment be restored to OPERABLE status.within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

L.1and B.

If drywell pressure cannot be restored to within limit within the required Completion Time, the plant must be brought to a NODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least NODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to NODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

SURVEILLANCE SR 3.6.1.4.14 REQUIREPENTS Verifying that drywell pressure is within limit ensures that 4*M operation remains within the limit assumed in the primary containmet analysis.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed, based on operating experience related to trending of drywell pressure variations during the applicable NODES.

Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal drywell pressure condition.

REFERENCES crn FS ecio R,

Rev 1. 04/07/95 8 3.6-34 BWR/4 STS

Insert REF

2.

NEDO-24578, Revision 0, Mark I Containment Program Plant Unique Load Definition, James A. FitzPatrick Nuclear Power Plant, March 1979.

3.

GE-NE-187-45-1191, FitzPatrickPower Uprate Impact Study Engineering Report: Section 4.1 Containment Systems Evaluation For The James A FitzPatrick Nuclear Power Plant, November 1991.

-4.

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

Insert Page B 3.6-34

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.4 - DRYWELL PRESSURE RETENTION OF EXISTING REQUIREMENT (CLB)

None PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Changes have been made to be consistent with other portions of the Bases.

PA2 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the plant specific nomencl ature.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 The proper plant specific references have been provided.

DB2 The brackets have been removed and the proper plant specific value has been provided.

DB3 The brackets have been removed and the proper plant specific provided.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

None DIFFERENCE BASED ON A SUBMITTED. BUT PENDING TRAVELER (TP) reference None DIFFERENCE FOR ANY REASON OTHER THAN THE 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 1 of 1 Revision A JAFNPP

j JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.4 Drywell Pressure RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

Drywell Pressure 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywell Pressure LCO 3.6.1.4 APPLICABILITY:

Drywell pressure shall be -s 1.95 psig.

MODES 1. 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell pressure not A.1 Restore drywell 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within limit.

ressure to within lmit.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.4.1 Verify drywell pressure is within limit.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months JAFNPP 3.6-15 Amendment 4!

Drywell Pressure B 3.6.1.4 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.4 Drywell Pressure BASES BACKGROUND APPLICABLE SAFETY ANALYSES LCO The drywell pressure is limited during normal operations to preserve the initial conditions assumed in the accident analysis for a Design Basis Accident (DBA) or loss of coolant accident (LOCA).

Primary containment performance is evaluated for the entire spectrum of break sizes for postulated LOCAs (Ref. 1).

Among the inputs to the DBA is the initial primary containment internal-pressure (Refs. 1. 2 and 3).

Analyses assume an initial drywell pressure of 1.95 psig.

This limitation ensures that the safety analysis remains valid by maintaining the expected initial conditions and ensures that the peak LOCA drywell internal pressure does not exceed the drywell design pressure of 56 psig.

The maximum calculated drywell pressure occurs during the reactor blowdown phase of the DBA, which assumes an instantaneous recirculation line break.

The calculated peak drywell pressure for this limiting event is 41.2 psig (Ref. 3).

Drywell pressure satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 4).

In the event of a DBA. with an initial drywell pressure S 1.95 psig, the resultant peak drywell accident pressure will be maintained below the maximum allowable drywell pressure.

APPLICABILITY In MODES 1. 2. and 3, a DBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, maintaining drywell pressure within limits is not required in MODE 4 or 5.

(continued)

B 3.6-29 Revision 0 JAFNPP

Drywell Pressure B 3.6.1.4 BASES (continued)

ACTIONS A.1 With drywell pressure not within the limit of the LCO, drywell pressure must be restored within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The Required Action is necessary to return operation to within the bounds of the primary containment analysis.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, "Primary Containment," which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

B.1 and B.2 If drywell pressure cannot be restored to within limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status. the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

SURVEILLANCE SR 3.6.1.4.1 REQUIREMENTS Verifying that drywell pressure is within limit ensures that plant operation remains within the limit assumed in the primary containment analysis.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed, based on operating experience related to trending of drywell pressure variations during the applicable MODES.

Furthermore, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal drywell pressure condition.

REFERENCES

1.

UFSAR, Section 14.6.1.3.3.

2.

NEDO-24578, Revision 0, Mark I Containment Program Plant Unique Load Definition, James A. FitzPatrick Nuclear Power Plant, March 1979.

(continued)

JAFNPP B 3.6-30 Revision 0

Drywell Pressure B 3.6.1.4 BASES REFERENCES

3.

GE-NE-187-45-1191. FitzPatrick Power Uprate Impact (continued)

Study Engineering Report: Section 4.1 Containment Systems Evaluation For The James A. FitzPatrick Nuclear Power Plant, November 1991.

4.

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

Revision 0 JAFNPP B 3.6-31

.1 /

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature 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: 3.6.1.5 Drywell Air Temperature MARKUP OF CURRENT TECHNICAL SPECIFICATIONS (CTS) 2

if, Insert Neý Specification 3.6.1.5 Insert new Specification 3.6.1.5. "Drywell Air Temperature," as shown in the JAFNPP Improved Technical Specifications.

SI

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature DISCUSSION OF CHANGES (DOCs) TO THE CTS

DISCUSSION OF CHANGES ITS: 3.6.1.5 - DRYWELL AIR TEMPERATURE ADMINISTRATIVE CHANGES None TECHNICAL CHANGES MORE RESTRICTIVE M1 A new Specification is proposed to be added requiring drywell air temperature to be s 1350F. This is required because accident analyses of UFSAR, Section 14.6.1.3.3 and the power uprate analysis assume this temperature as an initial condition.

Appropriate ACTIONS and a Surveillance Requirement are also proposed to be added.

The addition of this new Specification constitutes a more restrictive change necessary to ensure the accident analyses can be met.

TECHNICAL CHANGES - LESS RESTRICTIVE (GENERIC)

None TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

None TECHNICAL CHANGES - RELOCATIONS None Revision A Page 1 of 1 JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC) FOR LESS RESTRICTIVE CHANGES

NO SIGNIFICANT HAZARDS CONSIDERATIONS "ITS: 3.6.1.5 - DRYWELL AIR TEMPERATURE TECHNICAL CHANGES - LESS RESTRICTIVE (SPECIFIC)

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

Page 1 of 1 Revision A JAFNPP 1'

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature MARKUP OF NUREG-1433, REVISION 1 SPECIFICATION

I, Drywel 1 Al r Temperature 3.6.1.5 3.6 CONTAINMENT SYSTEMS 3.6.1.5 Drywell Air Temperature LCO 3.6.1.5 Drywell average air temperature shall be

01354F.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Drywell average air A.1 Restore drywell 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within average air limit.

temperature to within limit.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.5.1 Verify drywell average air temperature is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months within limit.

Rev 1, 04/07/95 BWR/4 STS 0X(

3.6-20

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS: 3.6.1.5 - DRYWELL AIR TEMPERATURE RETENTION OF EXISTING REQUIREMENT (CLB)

None PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

None PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 The brackets have been removed and the proper plant specific value has been provided.

flT FFFRENCF BASED ON AN APPROVED TRAVELER (TA)

None DIFFERENCE BASED ON A SUBMITTED.

BUT PENDING TRAVELER (TP)

None nlT IFl:DflJCF~l tFT'R ANY RFPA~fl"N OTHER THAN THE ABOVE (X)

None I

Page 1 of 1 J.AFNPP DIFFERENCE DIFFERENCE wrrrrmr Pn Amlyl~I~.

PrI rilI qn.mliJ, Revision A

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature MARKUP OF NUREG-1433, REVISION 1, BASES

Drywell Air Temperature B 3.6.1.5 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.5 Drywall Air Temperature BASES BACKGROUND The drywell contains the reactor vessel and piping, which add heat to the airspace.

Drywell coolers remove heat and maintain a suitable environment.

The average airspace temperature affects the calculated response to postulated Design Basis Accidents (OBAs).

The limitation on the drywell average air temerature was developed as reasonable, based on operating experience.

The limitation on drywell air temperature is used in the Reference 1 safety analyses.

APPLICABLE Primary containment performance is evaluated for a SAFETY ANALYSES spectrum of break sizes for postulated loss of coolant accidents (LOCAs)

(Ref. 1).

Among the inputs to the design analyss the initial drywell average air

-Wil uemperaturf Analyses assume an intia-.

a e drywell air tamera ure of f135*F. Thisiit tion ensures that the safety analysis remains valid by maintaining the a t onitions and ensures that the peak LOCA a

oO not exceed the dg a

T-1 D

i IJ (Ref ýkt.

Exed h h

a pc may result in th;e doegiradion of the priry Cow,"

containment structure under accident loads.

Equipment d *i inside primary containment required to mitigate the effects 3.v**F Iof a DBA is designed to operate and be capable of operating I under environmental conditions expected for the J

'S.

(continued)

Rev 1, 04/07/9S BVR/4 STS B 3.6-35

Drywell Air Temperature B 3.6.1.5 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these NODES.

Therefore, maintaining drywell average air temperature within the limit is not required in MODE 4 or 5.

ACTIONS With drywell average air temperature not within the limit of the LCO, drywell average air temperature must be restored within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Required Action is necessary to return operation to within the bounds of the primary containment analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Tim is acceptable, considering the sensitivity of the analysis to variations in this parameter, and provides sufficient time to correct minor problems.

If the drywall average air temperature cannot be restored to ithn-limit~within the required Completion Tim, the plant

must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least VOOE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to NODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

SURVEILLANCE REQUIREMENTS Verifyin that the drywell average air temperature is within the LCO11imit ensures that operation remains within the

)

limits assumed for the primary containment analyses.

Drywell air temperature is monitored in AIM n&

at various elevations (referenced to man sea level).

Due to the shape of the drywael, a volumetric average is used to determine an accurate representation of the actual average temperature.

.(continued)

Rev 1, 04/07/95 BWR/4 STS BS 3.6-.36

Drywell Air Temperature 8 3.6.1.5 BASES SURVEILLANCE REQUIREMENT BVR/4 STS SR 3.6.1.5.1 (continued)

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of the SR was developed based on operating experience related to drywell average air temperature variations and temperature instrument drift during the applicable MODES and the low probability of a DBA occurring between surveillances.

Furthermore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal drywel1 air temperature condition, 8 3.6-37 Rev 1, 04/07/95

Insert REF

2.

GE-NE-187-45-1191. FitzPatrick Power Uprate Impact Study Engineering Report: Section 4.1 Containment Systems Evaluation For The James A. FitzPatrick Nuclear Power Plant, November 1991.

3.

GE-NE-T23-00725-01, James A. FitzPatrick Nuclear Power Plant LOCA Drywell Temperature Analysis at Power Uprate Conditions, March 1995.

4.

GE-NE-T23-00737-01, James A. FitzPatrick Nuclear Power Plant Higher RHR Service Water Temperatures Analysis, August 1996.

Insert Page B 3.6-37

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature JUSTIFICATION FOR DIFFERENCES (JFDs)

FROM NUREG-1433, REVISION 1, BASES

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.5 - DRYWELL AIR TEMPERATURE RETENTION OF EXISTING REQUIREMENT (CLB)

None PLANT-SPECIFIC WORDING PREFERENCE OR MINOR EDITORIAL IMPROVEMENT (PA)

PAl Changes have been made to be consistent with other places in the Bases.

PA2 Typographical/grammatical error corrected.

PA3 Changes have been made (additions, deletions, and/or changes to the NUREG) to reflect the pl ant specific nomenclature.

PA4 ISTS 3.6.1.5 Reference 3 is deleted since it is not referenced within the associated Bases.

PLANT-SPECIFIC DIFFERENCE IN THE DESIGN (DB)

DB1 The peak drywell temperature exceeds the primary containment design temperature of 309OF during a design bases loss of coolant accident (LOCA) as well as during small steam line breaks.

However, as documented in UFSAR Section 16.7.3.2.3 this limit is only applicable coincident with the primary containment design pressure in accordance with the ASME Code allowance.

Since the peak drywell pressure is far below the drywell design pressure of 56 psig in all postulated accidents, the primary containment response is considered to be within the design limits.

The ITS 3.6.1.5 Bases has been revised to reflect the plant specific references.

DB2 The brackets have been removed and the proper plant specific value has been provided.

DB3 The brackets have been removed and the proper plant specific reference included.

DIFFERENCE BASED ON AN APPROVED TRAVELER (TA)

None DIFFERENCE BASED ON A SUBMITTED, BUT PENDING TRAVELER (TP)

None JAFNPP Page 1 of 2 Revision A

JUSTIFICATION FOR DIFFERENCES FROM NUREG-1433, REVISION 1 ITS BASES: 3.6.1.5 - DRYWELL AIR TEMPERATURE DIFFERENCE FOR ANY REASON OTHER THAN THE 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 2 of 2 Revision A JAFNPP

JAFNPP IMPROVED STANDARD TECHNICAL SPECIFICATIONS (ISTS) CONVERSION ITS: 3.6.1.5 Drywell Air Temperature RETYPED PROPOSED IMPROVED TECHNICAL SPECIFICATIONS (ITS) AND BASES

,1

Drywell Air Temperature 3.6.1.5 3.6 CONTAINMENT SYSTEMS 3.6.1.5 Drywell Air Temperature LCO 3.6.1.5 Drywell average air temperature shall be -< 135°F.

APPLICABILITY:

MODES 1, 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell average air A.1 Restore drywell 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within average air

limit, temperature to within limit.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.5.1 Verify drywell average air temperature is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months within limit.

Amendment 3.6-16 JAFNPP

Drywell Air Temperature B 3.6.1.5 B 3.6 CONTAINMENT SYSTEMS B 3.6.1.5 Drywell Air Temperature BASES BACKGROUND APPLICABLE SAFETY ANALYSES The drywell contains the reactor vessel and piping, which add heat to the airspace.

Drywell coolers remove heat and maintain a suitable environment.

The average airspace temperature affects the calculated response to postulated Design Basis Accidents (DBAs).

The limitation on the drywell average air temperature was developed as reasonable, based on operating experience.

The limitation on drywell air temperature is used in the Reference 1 safety analyses.

Primary containment performance is evaluated for a spectrum of break sizes for postulated loss of coolant accidents (LOCAs)

(Ref. 1).

Among the inputs to the design basis analysis is the initial drywell average air temperature (Refs. 1, 2, 3 and 4).

Analyses assume an initial average drywell air temperature of 135 0 F. This limitation ensures that the safety analysis remains valid by maintaining the expected initial conditions and ensures that the peak LOCA drywell temperature and pressuure do not exceed the drywell design pressure of 56 psig coincident with a design temperature of 309°F (Ref. 5).

Exceeding these design limitations may result in the degradation of the primary containment structure under accident loads.

Equipment inside primary containment required to mitigate the effects of a BA is designed to operate and be capable of operating under environmental conditions expected for the spectrum of break sizes.

Drywell air temperature satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 6).

LCO In the event of a DBA. with an initial drywell average air temperature less than or equal to the LCO temperature limit, the resultant peak accident temperature and pressure are maintained within the drywell design.limits and within the environmental qualification envelope of the equipment in the drywell.

As a result, the ability of primary containment to perform its design function it ensured.

(continued)

Revision 0 B 3.6-32 JAFNPP

-j Drywel 1 Air Temperature B 3.6.1.5 BASES (continued)

APPLICABILITY ACTIONS SURVEILLANCE REQUIREMENTS In MODES 1, 2. and 3, a DBA could cause a release of radioactive material to primary containment.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, maintaining drywell average air temperature within the limit is not required in MODE 4 or 5.

A.1 With drywell average air temperature not within the limit of the LCO. drywell average air temperature must be restored within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Required Action is necessary to return operation to within the bounds of the primary containment analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable, considering the sensitivity of the analysis to variations in this parameter. and provides sufficient time to correct minor problems.

B.1 and B.2 If the drywell average air temperature cannot be restored to within the limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable.

based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.6.1.5.1 Verifying that the drywell average air temperature is within the LCO limit ensures that operation remains within the limits assumed for the primary containment analyses.

Drywell air temperature is monitored in five zones and at various elevations (referenced to mean sea level).

Due to the shape of the drywell. a volumetric average is used to determine an accurate representation of the actual average temperature.

(continued)

Revision 0 B 3.6-33 JAFNPP

Drywel 1 Air Temperature B 3.6.1.5 BASES SURVEILLANCE REQUIREMENT SR 3.6.1.5.1 (continued)

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of the SR was developed based on operating experience related to drywell average air temperature variations and temperature instrument drift during the applicable MODES and the low probability of a DBA occurring between surveillances.

Furthermore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal drywell air temperature condition.

REFERENCES

1. UFSAR, Section 14.6.1.3.3.

2.

GE-NE-187-45-1191, FitzPatrick Power Uprate Impact Study Engineering Report: Section 4.1 Containment Systems Evaluation For The James A. FitzPatrick Nuclear Power Plant, November 1991.

3.

GE-NE-T23-00725-01, James A. FitzPatrick Nuclear Power Plant LOCA Drywell Temperature Analysis at Power Uprate Conditions, March 1995.

4.

GE-NE-T23-00737-01, James A. FitzPatrick Nuclear Power Plant Higher RHR Service Water Temperature Analysis, August 1996.

5.

UFSAR, 16.7.3.2.3.

6.

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

Revision 0 B 3.6-34 JAFNPP

ML011630394

Text

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