Text

Part 2 of 2, Prairie Island Nuclear Generating Plant, Supplement to License Amendment Request Dated December 11, 2000, Conversion to Improved Technical Specifications (Its), Part D Package 3.7
	ML020800670
Person / Time
Site:	Prairie Island
Issue date:	03/06/2002
From:	Nazar M; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML020800670 (159)
	v • d • e

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 A

002 CTS 3.4.A, 3.4.B, 3.4.C, 3.4.D, 3.3.C, 3.3.D, 3.6.E and 3.6.F.

The CTS contain prose descriptions of the conditions for which the specification is applicable. This description has been replaced with the equivalent MODES of applicability for the ITS. Since the plant conditions to which this specification apply have not changed, this is an administrative change.

L 003 CTS 3.4.A.2.a. A new Condition and associated Required Action and Completion Time are included to allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the inoperable MSSV to operable status or begin preparations to shut the plant down. PI CTS does not address the condition when a MSSV is inoperable. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable to assess the inoperability and perform minor repairs. The probability of an event or transient occurring during this 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period which requires any given MSSV to be operable is extremely low. In the remote case an event did occur during this time the plant would rely upon other systems (i.e. PORVs) to shut the plant down in a safe manner.

PI is not proposing to continue plant operation for extended periods at reduced power with less than all ten MSSVs operable; therefore an allowed outage time is required to restore an inoperable valve and make preparations to shut down. This change is less restrictive since CTS would require entry into CTS 3.0.C which would allow the plant to continue to operate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months while corrective actions are pursued.

Prairie Island Units 1 and 2 2

2/2/02

Package 3.7 Discussion Of Change NSHD category L

Prairie Island Units 1 and 2 2/2/02 Part D 007 CTS 3.4.A.2.a. This change will allow one SG PORV to be inoperable for 7 days and two SG PORVs inoperable for I hour. It is acceptable to have one SG PORV inoperable for this length of time because the other SG PORV is still operable and there are other comparable means of heat removal such as the Steam Dump and Main Steam Safety Valves. It is acceptable to have two SG PORVs inoperable for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months because there is a low probability of a SG Tube Rupture coincident with a loss of offsite power. Also there are other means of removing heat such as the Steam Dump and Main Steam Safety Valves. Since these changes extend the time the plant can operate with equipment out of service, these changes are less restrictive.

Change number 3.7-4

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 M

008 CTS 3.4.B.1.a and 3.4.B.2. In conformance with the guidance of NUREG-1431, the more general term "train" is used instead of only requiring AFW pumps to be operable.

Since the requirement for a "train" to be operable may require more equipment, this change is more restrictive.

Also the specifications have been simplified in that the AFW requirements for a single unit operating are specified. If two units are operating, then the same requirements apply to each unit individually. CTS 3.4.B.2 also contained a statement that if the OPERABILITY of the AFW pump is not restored to OPERABILITY within the specified time, place the affected unit (or either unit in the case of the motor driven AFW pump inoperability) or initiate a shutdown track.

PI design is that a motor driven AFW pump can be cross tied and aligned to provide feedwater to the SGs to the other unit. In this case, one unit must be in a shutdown condition and the other unit motor driven AFW pump inoperable. PI is deleting this CTS flexibility and therefore, making this a more restrictive change. Eliminating this flexibility is acceptable since the ITS provides specific Conditions and Required Actions for individual unit equipment inoperabilities.

009 CTS 3.4.B.1.b. The AFW requirements for two units operating have been included in the ITS LCO such that the requirements are the same for each operating unit; thus a separate statement for two unit operation is not required. Since these requirements have been incorporated into the ITS, this is an administrative change.

010 Not used.

Prairie Island Units 1 and 2 5

2/2/02

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

011 CTS 3.4.B.1.c. This statement has been replaced with a LCO Note which specifies that AFW is considered operable during alignment and operation for SG level control if capable of being manually realigned to the AFW mode of operation. Since the note is broader in scope than this specification, this change is considered less restrictive. This change incorporates the conditions of NRC letter from Beth Wetzel to Roger Anderson, dated October 17, 1997.

M 012 A new SR, 3.7.5.1, is included which requires that AFW valves that are not locked, sealed or otherwise secured in position, are in the correct position. Since this SR requires additional plant activities, it is more restrictive. This more restrictive change is included to make the PI ITS complete. This change is consistent with the guidance of NUREG-1431.

M 013 A new specification, 3.7.2, is included which requires two MSIVs to be operable. PI CTS require surveillance of the MSIVs but does not include any limiting conditions for operations. Since this new specification places additional restrictions on the plant, this change is more restrictive. This change is included to make the P1 ITS consistent with the guidance of NUREG-1431. This change is acceptable because the MSIVs are currently administratively required to be operable by the plant.

Prairie Island Units 1 and 2 6

12/11/00

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 M

014 A new specification, 3.7.3, is included which requires two MFRVs and associated bypass valves to be operable. Since this new specification places additional restrictions on the plant, this change is more restrictive. This change is included to make the PI ITS consistent with the guidance of NUREG-1431. This change is acceptable because the MFRVs and associated bypass valves are currently administratively required to be operable by the plant.

M 015 Two new SRs, 3.7.3.1 and 3.7.3.2 are included which require verification of the isolation time for the MFRV and MFRV bypass valves on an actual or simulated signal. Since these new specifications place additional restrictions on the plant, these changes are more restrictive. These changes are included to make the PI ITS consistent with the guidance of NUREG-1431. These changes are acceptable because the MFRVs and MFRV bypass valves are currently administratively required to be operable by the plant.

M 016 CTS 3.4.B.1.d. The CTS requirement for 100,000 gallons of water in the CTSs is clarified to require 100,000 gallons per unit. Since this requires more water than is currently required, this is a more restrictive requirement. This change is acceptable because the plant currently maintain 100,000 gallons per unit in accordance with current plant procedures.

Prairie Island Units I and 2 7

12/11/00

PartD Package 3.7 Discussion Of Change NSHD category LR LR Prairie Island Units 1 and 2 12/11/00 Change number 3.7-017 CTS 3.4.B.1.d. The details of the OPERABILITY requirements for the condensate storage tank, including backup water supply requirements have been relocated to the Bases. These specification details are unnecessary since the Specification requirement that the CST is OPERABLE envelopes these requirements. This change is consistent with the guidance of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

018 CTS 3.4.B.1.e, f and g. The details of the OPERABILITY requirements for AFW system motor operated and manual valves, and condensate cross connect valve to the AFW system have been relocated to the TRM. These specification details are unnecessary in the TS since the Specification requirement that the AFW system is OPERABLE envelopes these requirements. This change is consistent with the guidance of NUREG-1431. Since the TRM is licensee controlled, this change is less restrictive. This change is acceptable since the TRM is under the regulatory controls of 10 CFR 50.59.

Package 3.7 Part D 8

NSHD Change category number Discussion Of Change 3.7 LR 019 CTS 3.4.B.2.a. CTS and ITS allow startup to proceed without demonstration of AFW pump and associated valve operability.

CTS details on the conditions of inoperability have been relocated to the Bases. This change is consistent with the guidance of NUREG-1431 as modified by approved travellers.

This change is acceptable because the turbine driven AFW pumps will continue to be maintained and tested as they are under the CTS requirements. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

A 020 CTS 3.4.B.2. CTS states that. "any one of the following conditions of inoperability may exist..." This requirement prevents two or more of the listed conditions from existing at the same time. The limitation that only one condition of inoperability may exist is not explicitly stated in ITS. In ITS, these conditions may be in more than one specification.

However, in the NUREG-1431 format, the SFDP exists to provide a mechanism to assure that entry into multiple TS Conditions will not result in loss of safety function. Thus the SFDP limits these conditions from simultaneous existence when there is a loss of safety function. The Maintenance Rule will also assure that multiple equipment inoperabilities are evaluated for reduction of plant safety. Since the ITS includes provisions to address this clause, there is no net change in plant safety and this is an administrative change.

Prairie Island Units 1 and 2 9

12/11/00 Part D Package 3.7

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 A

021 CTS 3.4.B.2.a. The CTS requirements for completion of turbine driven AFW pump testing have been reworded to be consistent with the NUREG-1431 format. Since there are no substantive changes, this is an administrative change.

L 022 CTS 3.4.B.2. A new Condition is included which allows one steam supply to the turbine driven AFW pump to be inoperable for 7 days and 10 days from discovery of failure to meet the LCO. This is less restrictive since the CTS allow a TDAFW pump, valve or piping to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, the TDAFW pump is NOT inoperable when one steam supply is inoperable. Seven days and 10 days from discovery of failure to meet the LCO are acceptable since there is a redundant steam supply to the pump; there is also a redundant motor driven pump and there is a low probability of an event which requires the inoperable steam supply to the TDAFW pump. This change is consistent with the guidance of NUREG-1431.

M 023 CTS 3.4.B.2.a. The CTS requirement that specifies equipment that may be inoperable is generalized to allow an AFW train to be inoperable. Since more equipment under this specification may make the AFW train inoperable, this change is considered more restrictive. Since a "train" of equipment is more inclusive, this change may enhance plant safety. This change is consistent with the guidance of NUREG-1431.

Prairie Island Units 1 and 2 10 2/2/02

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 LR 024 CTS 3.4 B.2.b. Since the ITS specifies that a whole train may be inoperable, the definition of equipment that may be inoperable is unnecessary in the TS and therefore relocated to the Bases. This change is consistent with the guidance of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

L 025 CTS 3.4.B.2.c. This change will allow the CSTs to be inoperable for 7 days. This is acceptable due to the availability of the backup supply of water from the cooling water system and the low probability of an event during this time which will require the CSTs. Also, inoperable CSTs does not necessarily mean total loss of function, such as the circumstances when the CST level is low. This change is consistent with the guidance of NUREG-1431. Since plant equipment may be inoperable for additional time beyond that allowed in the CTS, this change is less restrictive.

M 026 CTS 3.4.B.2.c. The ITS requires verification of cooling water supply availability within four hours and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This additional verification provides that the plant will be maintained in a safe condition during the extended time the CSTs are allowed to be inoperable. Since a specific time for verification is provided, this is a more restrictive change.

Verification within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter does not place the plant at risk and may improve plant safety. This change is consistent with the guidance of NUREG-1431.

Prairie Island Units 1 and 2 11 12/11/00

Package 3.7 Discussion Of Change NSHD category M

LR Prairie Island Units 1 and 2 12/11/00 Part D Change number 3.7-027 A new SR, 3.7.6.1, is included which requires verification of the CST inventory every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Currently plant procedures require verification of CST inventory; however, since this SR makes this verification a TS requirement, this change is considered more restrictive. This more restrictive change is included to make the PI ITS complete. This change is consistent with the guidance of NUREG-1431.

028 CTS 3.4.B.2.d. The details of inoperability conditions for the AFW backup supply of water from the cooling water system have been relocated to the Bases for the AFW system. AFW system OPERABILITY will require the availability of the backup water supply. Therefore, these specification details are unnecessary since the Specification requirement for AFW system OPERABILITY and associated ACTIONS envelope these requirements. This change is consistent with the guidance of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

12

NSHD Change category number Discussion Of Change 3.7 LR 029 CTS 3.4.B.2.e. The details of inoperability conditions for AFW system valves have been relocated to the TRM. These specification details are unnecessary since the Specification requirement for AFW system OPERABILITY and associated ACTIONS envelopes these requirements. This change is consistent with the guidance of NUREG-1431. Since the TRM is licensee controlled, this change is less restrictive.

This change is acceptable since the TRM is under the regulatory controls of 10 CFR 50.59.

This CTS requirement does not meet 10CFR50.36(c )(2)(ii) criteria for inclusion into the ITS as follows:

Criterion 1: Installed instrumentation that is used to detect and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

This Specification only applies to valve position lights for AFW system motor operated valves MV32242 and MV32243 (unit 2 MV32248 and MV32249). These lights show AFW valve position and do not provide any function for detection of an abnormal degradation of the reactor coolant system.

Therefore, they do not meet criteria 1.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission barrier:

This Specification only provides valve position indication which is not an operating restriction nor assumed as initial conditions for a design basis accident or transient analysis.

These lights do not control any equipment nor are they controlled by plant operators to mitigate any accident or event. Therefore, they do not meet criteria 2.

Prairie Island Units 1 and 2 13 2/2/02 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 LR 29 (continued)

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier:

These lights are not a structure, system, or component that are a primary success path or actuates to mitigate a design basis accident. These lights only provide a visual aid for the control room operators to monitor AFW valve position.

Therefore, they do not meet criteria 3.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Again, these lights only provide a valve status of open or closed. The do not have any initiating signals nor generate any to actuate valve position or throttling. There has not been any operating experience or probabilistic risk assessment issues at PI for these lights. Therefore, they do not meet criteria 4.

Based on the above, these lights can be relocated to a Licensee Controlled Document.

Prairie Island Units I and 2 14 2/2/02 Part D Package 3.7

Package 3.7 NSHD Change category number 3.7-M Discussion Of Change 030 CTS 3.4.D. CTS requires the plant to meet secondary coolant radiochemistry requirements while in MODES 1, 2, and 3.

When these limits are not met the plant is required to go to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . These requirements have been conformed to the more restrictive requirements of NUREG 1431 by applying the radiochemistry limits in MODE 4 and requiring the plant to go to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This change is acceptable since it will not cause any unsafe plant operations and is consistent with current plant operating practices when radiochemistry limits are not met in MODE 4.

031 Not used.

Prairie Island Units 1 and 2 2/2/02 Part D 15

NSHD Change category number Discussion Of Change 3.7 R

032 CTS 3.4 C and 4.8.C. This specification provides requirements for the plant Steam Exclusion System. The Steam Exclusion System LCO and SR requirements have been relocated to the TRM since the system does not meet the criteria of 10 CFR 50.36 for inclusion in the Technical Specifications.

This system is an installed system for preventing steam from high energy line breaks from reaching safeguards equipment; thus it does not meet 10 CFR 50.36 (c)(2)(ii) Criterion 1 or 2.

The Steam Exclusion System is an installed system. However, it does not mitigate accidents and thus is not a primary success path for mitigating accidents. Therefore, the Steam Exclusion System does not meet 10 CFR 50.36 (c)(2)(ii) Criterion 3.

The Steam Exclusion System is not considered in the plant IPE and it is not a system which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Therefore this system does not meet 10 CFR 50.36 (c)(2)(ii) Criterion 4.

L 033 CTS Table 3.5-2B, Functional Unit 5a and Table 4.1-1 B, Functional Unit 5a. CTS requires operability of the main steam line isolation valves manual switches at all times when in MODE 2. In the ITS, MODE 2 applicability is modified by a condition which does not require these switches to be operable when both MSIVs are closed. Since this change limits the applicability for these switches, this is a less restrictive change.

This change is acceptable since the steam line isolation function is met passively without these switches operable when both MSIVs are closed. This change conforms to the guidance of NUREG-1431.

Prairie Island Units 1 and 2 16 12/11/00 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 A

034 CTS Table 3.5-2B, Note c and Table 4.1-1B, Note 23. The format of this note has been revised to conform to the guidance of NUREG-1431. The note has been restated but has the same meaning; therefore this is an administrative change.

M 035 CTS 3.4.D. For consistency with NUREG-1431, 3.7.18 action statements, the one hour to initiate actions necessary to place the unit in MODE 3 has been deleted. Since this change may require the plant to shutdown sooner, it is a more restrictive change. This change does not cause the plant to be operated in an unsafe manner.

A 036 CTS3.3.C.1. The CTS has separate specifications for single unit or two unit operations. The ITS is written such that the requirements are the same for single or two unit operation. Any differences are addressed in the Bases.

M 037 CTS 3.3.C.1.a.l. For consistency with the format guidance of NUREG-1431, the requirement for two CC pumps to be OPERABLE has been generalized to require two trains of CC to be operable. Since this may require more equipment to be operable, this is a more restrictive requirement. This change is acceptable since the requirement for two trains may increase plant safety.

Prairie Island Units 1 and 2 17 12/11/00 Package 3.7 Part D

Package 3.7 Discussion Of Change NSHD category LR M

Prairie Island Units 1 and 2 12/11/00 Part D Change number 3.7-038 CTS 3.3.C.1.a.2. Since the ITS specifies that a whole train is required to be OPERABLE, the definition of specific components required to be OPERABLE is unnecessary in the TS and therefore relocated to the Bases. This change is consistent with the guidance of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

039 A new SR, 3.7.7.1, is included which requires that CC valves in flow paths to safety related equipment that are not locked, sealed, or otherwise secured in position, are in the correct position. Since this SR may require additional plant activities, it is more restrictive. This more restrictive change is included to make the PI ITS complete. This change is consistent with the guidance of NUREG-1431. This change is acceptable since it may increase plant safety.

18

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 M

040 CTS Table 3.5-2B, Action 27. The CTS requirements for the main steam line isolation valve (MSIV) manual switches are included in the ITS LCO 3.7.2 requirements because: 1) LCO 3.7.2 is a new specification for PI which should include all applicable design features of the MSIVs; and 2) these switches directly operate the MSIV without any intervening logic circuitry.

CTS requires an inoperable MSIV manual switch to be restored to operability within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS LCO 3.7.2 requires the MSIVs (including switches) to be restored to operability within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in MODE 2 within 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months , close the valve within 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months and verify the valve to be closed once per 7 days.

Since this will require the plant to shut down much sooner, this is a more restrictive change. This change is acceptable since it places the plant in a safer condition sooner and does not introduce any unsafe plant operations or tests.

LR 041 CTS3.3.C.2. The new format of the PI ITS requires that each unit has two trains OPERABLE. The details of equipment required to define two OPERABLE trains is contained in the Bases. Therefore, these details are unnecessary in the TS and are relocated to the Bases. This change is consistent with the guidance of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

Prairie Island Units 1 and 2 19 12/11/00

NSHD Change category number Discussion Of Change 3.7 M

042 CTS3.3.D.1. For consistency with the format guidance of NUREG-1431, the detailed listing of equipment required to be OPERABLE has been generalized to require two trains of Cooling Water (CL) to be operable. Since this may require more equipment to be operable, this is a more restrictive requirement. This change is acceptable since the requirement for two trains may increase plant safety.

LR 043 CTS 3.3.D.1.a., b., and c..The new format of the PI ITS requires that each unit has two trains OPERABLE. The details of equipment required to define two OPERABLE trains is contained in the Bases and TRM. This change is consistent with the guidance of NUREG-1431.

This change also relocates the CTS requirements for non safeguards CL pumps to the TRM. The non-safeguards pumps do not detect RCS leakage, they are not an initial condition of a DBA, they are not components that are part of the primary success path for mitigation of a DBA and they are not significant to public health and safety; thus these pumps do not meet the Screening Criteria for inclusion in the ITS.

Relocating CTS requirements to the TRM or Licensee Controlled Document is less restrictive.

Prairie Island Units 1 and 2 20 2/2/02 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 A

044 CTS3.3.D.1.a. For clarity and consistency with the format requirements of NUREG-1431, the CTS requirements for safeguards CL pump inoperability have been restated as "No safeguards pumps OPERABLE for one train..." Since this statement is substantively the same as the CTS requirements and does not change any requirements for plant operation, this is an administrative change.

A 045 CTS 3.3.D.2.a.(1) and (2). CTS provides specific actions to be taken if two CL safeguards pumps are inoperable. These actions include cross train checks, verify support and supported relationships, and to ensure that there is not a loss of function in the CL system. Under the guidance and format of NUREG-1431, these specific actions are incorporated and verified under the Safety Function Determination Program (SFDP) as required by LCO 3.0.6 and 5.5.13, Safety Function Determination Program. This change is acceptable since the actions required to assure the plant is operated safely without loss of safety function is provided by the required Safety Function Determination Program. This change is consistent with the guidance of NUREG-1431. This is an Administrative change since the CTS requirements are consistent with those in the ITS.

Prairie Island Units 1 and 2 21 2/2/02 Package 3.7 Part D

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 M

046 CTS3.3.D.2.b.(1) and (2). CTS allow one CL header to be inoperable provided the vertical motor-driven CL is operable, but no time frame is defined within which this action is required to be completed. In the format of the ITS, some COMPLETION TIME is required to be defined for REQUIRED ACTIONS.

Under the requirements of ITS LCO 3.0.6, the other train will be verified to be operable, including the OPERABILITY of the diesel driven cooling water pump on the operable header. The vertical motor driven CL pump provides added assurance that there is a safeguards pump to supply the operable header.

Thus 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is provided as the required time-frame in which the vertical motor driven CL pump must be verified to be operable. Since a specific time is specified, this change is more restrictive.

A 047 CTS 3.3.D.2.b.(1) and (2). CTS allow one CL header to be inoperable provided the horizontal CL pump is verified to be operable. These CTS actions include cross train checks, verifying support and supported relationships, and ensuring that there is not a loss of function in the CL system. Under the format and guidance of NUREG-1431, the horizontal pump will be relocated to the TRM as discussed in DOC LR3.7-43. In addition, the CTS requirements for verifying diesel generator operability and verifying the diesel driven pump operability are incorporated in LCO 3.7.8, Condition B.

This change is acceptable since the CTS required actions continue to be performed. This change is consistent with the guidance of NUREG-1431. This is an Administrative change since the CTS requirements are consistent with those in the ITS.

Prairie Island Units 1 and 2 22 2/2/02

NSHD Change category number Discussion Of Change 3.7 M

048 A new SR, 3.7.8.1, is included which requires that CL valves in flow paths to safety related equipment that are not locked, sealed, or otherwise secured in position, are in the correct position. This SR is modified by a Note that clarifies that the CL system is not inoperable if the flow path to an individual component is isolated. The operability of each TS system affected by an isolated component would have to be evaluated under the TS definition of OPERABILITY. Since this SR may require additional plant activities, it is more restrictive. This more restrictive change is included to make the PI ITS complete. This change is consistent with the guidance of NUREG-1431. This change is acceptable since it may increase plant safety.

M 049 CTS3.3.D.2.c. CTS allow one Safeguards Traveling Screen to be inoperable provided a sluice gate is open but no time frame is defined within which this action is required to be completed.

In the format of the ITS, some COMPLETION TIME is required to be defined for REQUIRED ACTIONS. Since there is a redundant Safeguards Traveling Screen and an inoperable Safeguards Traveling Screen may not have an immediate loss of function, four hours was selected as a reasonable time to complete this action. Since a specific time is specified, this change is more restrictive. This change is included to make the ITS complete and will maintain the plant in a safe condition.

Prairie Island Units l and 2 23 12/11/00 Package 3.7 Part D

PartD Package 3.7 Change number 3.7-Discussion Of Change NSHID category L

Prairie Island Units 1 and 2 2/2/02 Part D 050 CTS3.3.D.I.d. NUREG-1431 allows the safeguards diesel generators to have their fuel oil supply below the required limits for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 9 days from discovery of the failure to meet the LCO with an appropriate track for declaring them inoperable. Since NUREG-1431 assumes that all CL pumps are motor driven, similar provision is not given for the CL pumps. Consistent with the intent of NUREG-1431 for the diesel generators, the ITS allows the diesel CL pump fuel oil supply to be below limits for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 9 days from discovery of the failure to meet the LCO with an appropriate track for declaring them inoperable. This is operational flexibility which is not provided by the CTS; thus this is a less restrictive change. Overall, these changes are considered a less restrictive change. These changes are consistent with the intent of NUREG-1431.

Package 3.7 24

Package 3.7 Discussion Of Change NSHD category M

Prairie Island Units 1 and 2 12/11/00 Part D 051 CTS3.3.D.2.d. CTS allow both Safeguards Traveling Screens to be inoperable provided a sluice gate is open but no time frame is defined within which this action is required to be completed. In the format of the ITS, some COMPLETION TIME is required to be defined for REQUIRED ACTIONS. It is unlikely that both Safeguards Traveling Screens would become inoperable simultaneously; therefore when the first Safeguards Traveling Screen became inoperable the action to open the sluice gate would already have been taken and this CONDITION would likely only require administrative verification that a sluice gate had previously been opened. If both Safeguards Traveling Screens are inoperable, expeditious action is required to remedy the situation; thus one hour was selected as a reasonable time to complete this action. One hour is consistent with the time allowed in CTS 3.0.C to take action prior to shutdown when the plant is in conditions not addressed by TS. Since a specific time is specified, this change is more restrictive. This change is included to make the ITS complete and will maintain the plant in a safe condition.

Change number 3.7-25

Part DPakg3.

Discussion Of Change NSHD category M

M Prairie Island Units I and 2 12/11/00 Change number 3.7-052 CTS3.3.D.2.3. CTS allow the Emergency CL line to be inoperable provided a sluice gate connecting the emergency bay and the circulating water bay is open, but no time frame is defined within which this action is required to be completed. In the format of the ITS, some COMPLETION TIME is required to be defined for REQUIRED ACTIONS. Under the provisions of CTS 3.0.C, if this action was not completed, the plant would have 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate actions to shut the plant down.

Therefore, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months has been allowed to perform these verifications and take actions to assure these required pumps are operable. Since a specific time is specified, this change is more restrictive. This change is included to make the ITS complete and will maintain the plant in a safe condition.

053 A new SR, 3.7.9.1, is included which requires verification that the safeguards travelling screens are operable. This verifications is currently performed under plant procedures. For completeness and consistency with the guidance of NUREG 1431, this verification is included as a formal SR. This SR will assure the plant is maintained in a safe condition.

Package 3.7 Part D 26

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

054 CTS 3.13.A.1. The requirement for CRSVS operability has been revised to include MODES 1, 2, 3 and 4 and during movement of irradiated fuel.. When neither unit is in one of these modes or conditions, the CRSVS is not required to perform a safety function. Design basis accidents with radiological releases are not analyzed for MODES 5 and 6.

CRSVS operability during CORE ALTERATIONS is not required because:1) borated water prevents a problem with inadvertent rod withdrawal; 2) operators have sufficient time to identify and terminate a dilution accident; and 3) while shutdown, the borated water will maintain any misloaded assembly in a safe condition. The applicability would not require the CRSVS to be operable during handling of new fuel.

This is acceptable since new fuel does not contain any fission gas inventory. This change is consistent with TSTF-51. Since this change allows CRSVS inoperability during some modes, this change is less restrictive.

M 055 CTS 3.13.A.1. For consistency with NUREG-1431, the one hour to initiate actions to shut down has been deleted. This is acceptable since the Required Actions already allow time to take actions and prepare for shutdown if required.

Prairie Island Units 1 and 2 27 2/2/02

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

056 CTS 3.13.A.1 and 2. CRSVS operability during CORE ALTERATIONS is not required because:1) borated water prevents a problem with inadvertent rod withdrawal; 2) operators have sufficient time to identify and terminate a dilution accident; and 3) while shutdown, the borated water will maintain any misloaded assembly in a safe condition. This change is consistent with TSTF-51. Since this change allows CRSVS inoperability during CORE ALTERATIONS, this change is less restrictive.

A 057 CTS 3.13.A.1 and 2. NUREG-1431 provides separate action statements for CRSVS during plant operation (MODES 1, 2, 3, and 4) and irradiated fuel handling operations. For clarity a new statement is included to show the changes in the CTS markup.

Since this statement by itself does not change any CTS requirements, it is an administrative change.

M 058 CTS 3.13.A.1. CTS provisions which allow two hours to take actions with respect to fuel handling have been deleted since NUREG-1431 requires immediate termination of irradiated fuel handling activities. If only one train of CRSVS is inoperable, the option of placing the operable CRSVS train in service is included. Immediate termination of irradiated fuel handling and placement of the operable CRSVS train in service are acceptable since they maintain the plant in a safe condition.

These changes are more restrictive since required actions are required to occur sooner.

Prairie Island Units 1 and 2 28 12/11/00

NSHD Change category number Discussion Of Change 3.7 M

059 A new specification, 3.7.11, is included which requires two safeguards chilled water trains to be operable. Since this new specification places additional TS requirements on the plant, this change is more restrictive. This change is acceptable because the plant currently operates this system as a support system to the CRSVS.

M 060 New SR 3.7.8.3 requires monthly verification that the CL diesel fuel oil supply meets the required limits. CTS does not explicitly require verification of the diesel CL pump fuel oil supply; therefore, this is a more restrictive change. This change is acceptable since the plant currently checks the fuel oil supply and this will not introduce any unsafe plant operations or tests. This change is consistent with the intent of NUREG-1431 as applied to diesel generators.

M 061 Two new SRs, 3.7.11.1 and 3.7.11.2, are included which requires verification each SCWS train actuates on an actual or simulated actuation signal and OPERABILITY of SCWS components in accordance with the ITS program. Currently the plant performs these tests. However, these SRs will make these verifications TS requirements; thus, these changes are considered more restrictive. These more restrictive changes are included to make the PI ITS complete.

Prairie Island Units 1 and 2 29 12/11/00 Package 3.7 Part D

PartD Package 3.7 Change number 3.7-Discussion Of Change NSHD category A

LR Prairie Island Units 1 and 2 12/11/00 062 CTS 3.6.E. The CTS requirements for Auxiliary Building Special Ventilation Zone Integrity have been included in the ITS 3.7.12 requirements for the ABSVS; thus the title of this section is revised. Since all of the specification requirements are retained in the ITS, this is an administrative change.

063 CTS 3.6.E.2 and 3. The details of inoperability conditions and controls for the ABSVS have been relocated to the TRM and Bases. These specification details are unnecessary since the Specification requirement for ABSVS OPERABILITY in PI ITS 3.7.12 and associated ACTIONS envelopes these requirements. A general discussion of these requirements are included in the Bases for completeness. The specific requirements are included in the TRM to assure that they are readily accessible to the operators. This change is consistent with the format and philosophy of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) and the TRM are licensee controlled, this change is less restrictive. This change is acceptable since both of these documents are under the regulatory controls of 10 CFR 50.59.

Part D Package 3.7 30

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 LR 064 CTS 3.6.F.1. The details of supporting equipment for operability of ABSVS have been relocated to the TRM and Bases. These specification details are unnecessary since the Specification requirement for ABSVS OPERABILITY in PI ITS 3.7.12 and associated ACTIONS envelopes these requirements. A general discussion of these requirements is included in the Bases for completeness. The specific requirements are included in the TRM to assure that they are readily accessible to the operators. This change is consistent with the format and philosophy of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) and the TRM are licensee controlled, this change is less restrictive. This change is acceptable since both of these documents are under the regulatory controls of 10 CFR 50.59.

M 065 CTS 3.6.F.2. A new action statement, consistent with the guidance of NUREG-1431, is included which addresses the situation when the allowed outage time is not met. Since the CTS does not specify an action, CTS LCO 3.0.C is applicable.

This change is more restrictive since the proposed ITS action statement requires shutdown sooner than CTS LCO 3.0.C.

This change does not cause the plant to be operated in an unsafe manner.

Prairie Island Units 1 and 2 31 12/11/00

NSHD Change category number Discussion Of Change 3.7 A

066 CTS 3.8.B.1.c The ITS, consistent with CTS 3.8.E.2.a, requires the boron concentration to be maintained at 1800 ppm at all times when spent fuel is stored in the spent fuel pool.

Therefore the applicability is expanded beyond involving a spent fuel cask containing fuel. Since the applicability for this requirement is consistent with CTS 3.8.E.2.a, this is an administrative change. This change is consistent with other CTS requirements and does not cause the plant to operate in an unsafe manner.

LR 067 CTS 3.8.B.1.a. The CTS requirement to continuously monitor radiation levels in the SFP area during fuel handling was not included in the PI ITS. No screening criteria apply for this requirement because the process variable of the LCO is not an initial condition of a DBA or transient analysis. The SFP radiation levels only provide a secondary indication of a SFP area problem. Other ITS LCOs, such as SFP level and boron concentration, provide adequate assurance that all accident analysis assumptions are met. Since this Specification only applies during fuel handling, if an accident were to occur, the personnel stationed in the SFP area would be immediately aware of the problem. Therefore, this'specification does not satisfy any of the NRC Final Policy Statement TS screening criteria and is relocated to the TRM. This change is consistent with the guidance of NUREG-1431.

Prairie Island Units 1 and 2 32 12/11/00 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 LR 068 CTS 3.8.B.1.b. The requirement to test fuel handling cranes prior to fuel handling is not included in the PI ITS. No screening criteria applies for this requirement because the fuel handling crane limit switches, interlocks and alarms are not installed instrumentation that is used to detect and indicate in the control room, a significant abnormal degradation of the RCS. The crane testing requirements are not related to an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The equipment which is the subject of this specification requirement is not a part of the primary success path for mitigation of a DBA or Transient. If a fuel handling accident occurs, other plant features such as the SFP water and SFPSVS are the primary success paths. Therefore, this specification does not satisfy any of the NRC TS screening criteria and is relocated to the TRM. This change is consistent with WCAP-1 1618 and the guidance of NUREG-1431.

R 069 CTS 3.8.C. The CTS requirement to limit the number of recently discharged fuel assemblies stored in the small pool (Pool 1) is not included in the PI ITS. This specification does not contain requirements for installed instrumentation. This specification does not address an operating restriction that is an initial condition of a DBA or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This operating restriction on fuel storage is not a structure, system or component. Therefore, this specification does not satisfy any of the NRC Final Policy Statement TS screening criteria and is relocated to the TRM.

Prairie Island Units 1 and 2

33.

12/11/00 Part D Package 3.7

Package 3.7 NSHD Change category number 3.7-Discussion Of Change 070 Not used.

071 Not used.

L 072 CTS 3.8.D.2. This proposed change will delete the requirement to demonstrate operability of the redundant SFPSVS train when one train is inoperable. This change is acceptable because there is a low probability of a fuel handling accident in the 7 days that fuel movements are allowed to continue and the redundant train is required by ITS to be tested on a 31 day schedule. Further testing when one train fails is not necessary.

In addition, the ITS requires in Action B that if the Required Actions and associated Completion Time of Condition A is not met then place the OPERABLE SFPSVS train in operation immediately and to also immediately suspend movement of irradiated fuel assemblies in the spent fuel pool enclosure.

This change is consistent with the guidance of NUREG-1431.

Since this change may require less testing, it is a less restrictive change.

Prairie Island Units 1 and 2 2/2/02 Part D 34

PartD Package 3.7 Change number 3.7-Discussion Of Change NSHD category M

A M

Prairie Island Units 1 and 2 12/11/00 073 CTS 3.8.D.3. The CTS requirement to suspend movement of irradiated fuel is modified to require suspension "immediately".

No time frame is specified in the CTS. Since a time frame is specified in the ITS, this change is more restrictive. This change is acceptable since under the CTS requirements, fuel movement would be stopped as soon as practical, which is equivalent to this new required time frame. This change is consistent with the guidance of NUREG-1431.

074 CTS 3.8.D.4. and 3.8.E.1.c. CTS LCO 3.0.C is equivalent to ITS LCO 3.0.3 which is referenced for clarity. Since no substantive changes are involved, this is an administrative change.

075 A new specification, 3.7.15, is included which requires the fuel storage pool water level to exceed 23 feet over the top of irradiated fuel seated in the storage racks during irradiated fuel movement. This change is consistent with the guidance of NUREG-1431. This new specification is acceptable since the pool level is normally kept at or above this required level during fuel movement. Since this is a formal TS requirement this change is considered more restrictive.

Part D Package 3.7 35

Package 3.7 Discussion Of Change NSHD category M

A A

Prairie Island Units 1 and 2 12/11/00 Part D Change number 3.7-076 A new SR, 3.7.15.1, is included which requires verification of the fuel pool level during movement of irradiated fuel. Since this is a new formal TS requirement, this change is considered more restrictive. This more restrictive change is included to make the PI ITS complete. This change is consistent with the guidance of NUREG-1431. This change is acceptable since more frequent verification of the specified level as a formal requirement may increase plant safety.

077 CTS 3.8.E.1. The title of this specification has been changed to be consistent with the title of ITS 3.7.17. Since no substantive changes are involved, this is an administrative change.

078 CTS 3.8.E.2. The title and terminology within this specification are revised to be consistent with the title and terminology in ITS 3.7.16. Since no substantive changes are involved, this is an administrative change.

36

Package 3.7 Discussion Of Change NSHD category R

Prairie Island Units 1 and 2 12/11/00 Part D 079 CTS 3.12, 4.13 and Table 4.13-1. The snubber requirements in CTS 3.12 and 4.13 are relocated to the TRM. The CTS inspection and testing requirements do demonstrate the snubbers are OPERABLE. However, the ISI program, required by 10CFR50.55a, provides requirements for testing of snubbers. Prairie Island is required to comply with the provisions of 10CFR50.55a and therefore has an ISI program.

This ISI program is reviewed, approved and inspected by the NRC. These controls are adequate to the required inspection and testing to demonstrate snubber operability. Therefore, PI programs and NRC regulations contain adequate requirements for snubbers without repeating them in the TS. Since the snubber requirements will be relocated to the TRM, changes will be under the controls of 1 OCFR50.59. This change is consistent with the guidance of NUREG-1 431.

080 Not used.

Change number 3.7-37

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 R

081 CTS Table 4.1-2A, Function 11. CTS requires periodic testing of the turbine stop valves, governor valves and intercept valves. These valve testing requirements have been relocated to the TRM. These valves are not leak detection equipment, they are not process variables, they are not a part of the primary success path for mitigation of an accident and these valves have not been found to be significant to the public health and safety. Therefore these valves do not meet the criteria of 10 CFR 50.36 for inclusion in the TS. Thus the SR for testing these valves has been relocated to the TRM. This change is consistent with the guidance of NUREG-1431. However, this change is acceptable since the TRM is under the regulatory controls of 10 CFR 50.59.

LR 082 CTS Table 4.1-1 B, Functional Unit 5a and 4.7. Specific requirements for the surveillance interval for this test have been relocated to the Inservice Testing Program in accordance with the requirements of ITS Section 5.5, Inservice Testing Program. Since this test program is required by the TS, these requirements remain under regulatory controls. This change is consistent with the options given in NUREG-1431. Since this change removes specific requirements from the TS, it is a less restrictive change.

Prairie Island Units 1 and 2 38 2/2/02

Package 3.7 Discussion Of Change NSHD category A

LR Prairie Island Units I and 2 12/11/00 Part D Change number 3.7-083 CTS 4.7. CTS requirements for testing MSIV closure time upon receipt of an actuation signal is divided into two ITS SRs as discussed in the Justification for Differences for ITS 3.7.2.

Therefore another statement for this SR is included here.

Since the same test is still performed that is currently required, this is an administrative change.

084 CTS 4.8.A.1. In accordance with approved TSTF-101, the schedule for performing the AFW pump test is relocated to the IST program. Since the schedule is not in the TS, this is change is less restrictive. This change is acceptable since the IST program is reviewed and approved by the NRC and a test schedule which assures the operability of the AFW pumps will be specified.

39

NSHD Change category number Discussion Of Change 3.7 L

085 CTS 4.8.A.1. The CTS requirement to demonstrate full flow to the SG each refueling shutdown is not included in the ITS. This change is acceptable because the other AFW system SRs assure that full flow will reach the SGs. ITS SRs which implement CTS requirements include verification that each AFW pump develops the required head at the test flow point, verification that automatic valves actuate to the correct position on an actual or simulated signal, and verification of the flow path from the CSTs to each SG after each shutdown extending beyond 30 days. Also a new SR is included, SR 3.7.5.1, which requires verification that each valve in the AFW flow path that is not locked, sealed, or otherwise secured in position, is in the correct position. The combination of these SRs provide the necessary assurances that full AFW flow will reach the SGs.

Furthermore this system is used as an operational system to feed the SGs during plant startup until the main feedwater pumps can be started (approximately 2% power); thus if AFW flow was not provided to the SGs, plant startup would not be able to proceed. Therefore this requirement is not included in the ITS. This change is consistent with the guidance of NUREG-1431.

Prairie Island Units 1 and 2 40 12/11/00 Part D Package 3.7

Package 3.7 Discussion Of Change NSHD category LR LR Prairie Island Units 1 and 2 12/11/00 Part D Change number 3.7-086 CTS 4.8.A.3 and 4. The detailed Specification that the AFW system valves will be tested in accordance with CTS 4.2 (IST program) has not been included. ITS Section 5.5, Programs and Manuals, requires that plant components be tested in accordance with an IST program. Thus these requirements have been relocated to the IST program. This change is acceptable since the IST program is reviewed and approved by the NRC. Since these CTS requirements are not explicitly stated in the ITS, this change is less restrictive. This change is consistent with the guidance of NUREG-1431.

087 CTS 4.8.A.5. The details of SR performance have been relocated to the Bases. Since the ITS requires system operability and performance of tests to demonstrate operability, the details of how the test is performed are unnecessary in the TS. This change is consistent with the format and philosophy of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

41

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

088 CTS 4.8.A.6. The CTS requirement to verify the position of valves which are locked in position is not included. Some valves in the AFW system are locked, sealed, or otherwise secured in position under administrative controls to assure that AFW flow will not be obstructed or altogether stopped. Since these locks, seals or other secure means are under administrative control, it is unnecessary to verify these valves are secured in the proper position on a regular monthly schedule. Therefore this requirement is not included. Since this change places less requirements on plant operations, it is a less restrictive change. This change is consistent with the guidance of NUREG-1431.

L 089 CTS 4.8.A.7. The CTS requirement to verify the normal AFW flow path to the SGs after each cold shutdown is not included in the PI ITS. At PI the AFW system is used for each normal unit startup and shutdown. Therefore, further documented verification is not necessary. This change is consistent with the guidance of NUREG-1431 which states, "This SR is not required by those units that use AFW for normal startup and shutdown." Since this change requires less plant testing, it is a less restrictive change.

090 Not used.

Prairie Island Units 1 and 2 42 12/11/00

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

091 CTS 4.8.A.8. The surveillance interval for verification of AFW system automatic actuation is increased from 18 months to 24 months to accommodate extended refueling cycles. In accordance with SR 3.0.2 this surveillance interval is fixed at this maximum and is not allowed to be extended beyond 24 months. A review of the six year period from January 1990 to the end of 1995 showed that no problems were encountered during the performance of these tests.

Therefore extension of this interval up to 24 months is acceptable. This change is consistent with the guidance of GL-91-04. Since this change will allow less frequent performance of this test, this change is less restrictive. This change is consistent with the guidance of NUREG-1431.

L 092 CTS 4.8.A.8, 4.5.A.4 and 4.5.A.5. The phrase "that is not locked, sealed, or otherwise secured in position" is included to make this SR consistent with the guidance of NUREG-1431.

This is acceptable, since valves that are physically and administratively secured in position will very likely be in the correct position when system performance is required. Since this may require less verification of plant equipment, this change is less restrictive.

Prairie Island Units 1 and 2 43 2/2/02

Package 3.7 Discussion Of Change NSHD category L

A Prairie Island Units 1 and 2 12/11/00 Part D Change number 3.7-093 CTS 4.7, 4.8.A.8, 4.5.A.4, 4.5.A.5, 4.14.A.2, 4.4.B.3.c, 4.4.E and 4.15.A.2. The CTS requirement to perform this SR using a test signal has been broadened to include use of an actual signal. If the system starts due to receipt of an actual signal, this is adequate verification of system operability. Further testing within that test interval should not be required using a test signal. Therefore this change is acceptable. This change is consistent with the guidance of NUREG-1431. Since this change may require less testing, it is a less restrictive change.

The CTS requirements have also been split into two SRs for clarity. Currently, the check damper operability is verified monthly under the provisions of the CTS. Since this verification does not involve an actuation signal, this test is specified as a separate SR.

094 CTS 4.8.A.1, Footnote. CTS states that test shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entering power operation.

POWER OPERATION in this context has been defined as MODE 1 in accordance with the CTS and ITS definitions. Since no substantive changes are involved, this is an administrative change.

44

Part 0 Package 3.7 NSHD Change category number 3.7-L Discussion Of Change 095 CTS 4.8.B. The CTS Frequency for testing the SG PORVs is monthly. ITS SR 3.7.4.1 requires this SR test and Frequency to be in accordance with the IST program, which tests these valves quarterly in accordance with ASME Section XI. This is acceptable since plant experience has shown that these valves usually pass their surveillance when performed in accordance with the CTS. Thus extension of the test interval to IST requirements is justified.

The testing interval for these valves remains under NRC control through NRC review and approval of the IST program. Since this change will require less testing, it is a less restrictive change.

096 Not used.

A 097 CTS 4.5.A.4. This change includes an explicit requirement to verify that each pump starts. While this can be inferred from the CTS requirements, it is included for clarity. Since no substantive changes are involved, this is an administrative change.

Prairie Island Units 1 and 2 2/2/02 Part D Package 3.7 45

NSHD Change category number Discussion Of Change 3.7 LR 098 CTS 4.5.A.4.b, 4.5.A.5.a, 4.5.B.1.b, 4.5.B.1.c, 4.5.B.3.e, 4.4.B.2 and 4.4.B.3.c. The details of SR performance have been relocated to the Bases. Since the ITS requires system operability and performance of tests to demonstrate operability, the details of how the test is performed are unnecessary in the TS. This change is consistent with the format and philosophy of NUREG-1431. Since the ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) are licensee controlled, this change is less restrictive.

LR 099 CTS 4.5.A.5.b. The requirements for diesel engine inspections will be relocated to the TRM and have not been included in the PI ITS. ITS 3.7.8 requires the necessary CL trains, which includes applicable pumps, to be OPERABLE. The ITS definition of OPERABILITY states, "A system, subsystem, train, component, or device shall be OPERABLE... when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system...

to perform its specified safety function(s) are also capable of performing their related support functions(s)." The definition of OPERABILITY and the requirements of ITS LCO 3.7.8 are adequate for ensuring the diesel driven CL (DDCL) pump is OPERABLE. Therefore the LCO requirement for the DDCL pump to be OPERABLE mandates performance of inspections to the extent that they are required to assure operability of the pump. Thus, these requirements are relocated to the TRM.

Relocating these requirements to the TRM maintains consistency with NUREG-1431.

Prairie Island Units 1 and 2 46 12/11/00 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 LR 100 CTS 4.4.B.3.c. CTS requires verification that the ABSVS actuates on a high radiation signal in addition to an SI signal.

Following an accident, the ABSV system will be actuated by an SI signal, and therefore, actuation by the high radiation signal is not required for accident mitigation. The high radiation signal is not part of RCS leakage detection instrumentation; it is not a variable, design feature or operating restriction that is an initial condition of an accident; it is not a system, structure or component that is part of the primary success path for mitigating an accident; and it is not a structure, system or component which has been shown to be significant to the public health and safety. Thus this signal does not meet the TS Selection Criteria of 10CFR50.36 and is not included in the ITS. This requirement is relocated to the Offsite Dose Calculation Manual (ODCM). Since the ODCM is under licensee control this is a less restrictive requirement. However, this change is acceptable because the ODCM is a program required by ITS Section 5.5 and is under the regulatory controls of 10CFR50.59.

L 101 CTS 4.14.A and 4.15.A. The CTS requirement to test automatic initiation of this system at least every 18 months is not included. The ITS will require this system test every 24 months which will allow extension of the PI refueling outage cycle. A review of past test results for this system test showed that no problems were encountered during the performance of the test. Therefore, extension of the test to the refueling shutdown interval (up to 24 months) is acceptable.

Prairie Island Units 1 and 2 47 12/11/00 Part D Package 3.7

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 LR 102 CTS 4.14.A.1, 4.14.B, 4.4.B.3, 4.4.B.4, 4.4.B.5, 4.15.A.1, 4.15.B.1, 4.15.B.2 and 4.15.B.3. Specific details for conduct of ventilation filter tests have been relocated to the Ventilation Filter Test Program in accordance with the requirements of PI ITS Section 5.5, Ventilation Filter Test Program. Since this test program is required by the TS, these requirements remain under regulatory controls. This change is consistent with the guidance of NUREG-1431. Since this change removes specific requirements from the TS, it is a less restrictive change.

L 103 CTS 4.14.B.1.c and 4.15.B.1.c. The test interval for verification of fan performance has been extended to once per operating cycle on a STAGGERED TEST BASIS (STB). Past experience has shown that this system usually passes the fan flow test.

Fan performance usually changes slowly over long periods of time which would allow prediction of unacceptable performance before a test is actually failed. Other system tests verify that the fans move air. This test verifies that the air movement is within the specified limits. If the fan fails the test, it may still move air and continue to perform most of its safety function. Therefore, extension of the interval to 24 months on an STB is acceptable.

The change to 24 months is consistent with the guidance of Generic Letter 91-04. The change to an STB is consistent with the guidance of NUREG-1431. Since this change will require less testing, it is less restrictive.

Prairie Island Units 1 and 2 48 12/11/00

Package 3.7 Change number 3.7-Discussion Of Change NSHD category M

A Prairie Island Units 1 and 2 12/11/00 Part D 104 CTS 4.14.B.4, 4.4.B.4.d and 4.15.B.4. "Circuit" has been replaced with "train" to be consistent with the terminology used in the ISTS. Since a train may include more equipment than a circuit, this is considered a more restrictive requirement. This change is consistent with the guidance of NUREG-1431. This change is incorporated to conform the PI ITS to the philosophy of the ISTS and make it complete.

105 CTS 4.4.E. The CTS requirement to test the auxiliary building normal ventilation system isolation valves is included in the requirements of SR 3.7.12.4. Since no substantive changes have been made in this clarification, this is an administrative change.

49

NSHD Change category number Discussion Of Change 3.7 R

106 CTS 4.19. The requirements to inspect AB crane lifting devices prior to handling heavy loads is not included in the PI ITS. No screening criteria apply for this requirement because the AB crane lifting devices are not installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the RCS. The AB crane lifting device inspection requirements are not related to an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The equipment which is the subject of this specification requirement does not in any way mitigate the consequences of an accident and therefore is not a part of the primary success path for mitigation of a DBA or Transient.

Therefore, this specification does not satisfy any of the NRC Final Policy Statement TS screening criteria and is relocated to the USAR (TRM). This change is consistent with WCAP-1 1618 and the guidance of NUREG-1431.

M 107 CTS 4.20. A new SR, 3.7.17.1 is included to require verification of each assembly prior to moving the assembly. This change is acceptable because this verification is currently performed in accordance with plant procedures. Since this is a new TS requirement, it is a more restrictive change. This change is consistent with the guidance of NUREG-1431.

Prairie Island Units I and 2 50 12/11/00 Package 3.7 Part D

PartD Package 3.7 Discussion Of Change NSHD category M

M Prairie Island Units 1 and 2 2/2/02 Change number 3.7-108 CTS Table 4.1-2B, Item 15 and Note 5. CTS allows this surveillance to be performed every six months when the activity level is less than 10% of the limit. This change will conform this SR to NUREG-1431 SR 3.7.18.1 requirements which require the surveillance to be performed every 31 days regardless of activity level. This change is acceptable since it will not cause any unsafe plant operations or tests and the plant currently performs this testing within a 31 day frequency.

109 CTS 3.4.B.2.a. The CTS requirement that allows Auxiliary Feed Water equipment to be out of service for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is modified by the addition of "and 10 days from discovery of failure to meet the LCO" to be consistent with the guidance of NUREG-1431. Since this change could limit the time that AFW equipment is allowed out of service, this is a more restrictive change. This change is acceptable since it does not introduce any unsafe plant conditions.

Package 3.7 Part D 51

PartD Package 3.7 NSHD Change category number 3.7-M Discussion Of Change 110 CTS3.3.D.2.a and 3.3.D.2.b. The CTS requirements that allow a Cooling Water (CL) pump out of service for 7 days or a CL header to be out of service for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are modified by the addition of "and 10 days from discovery of failure to meet the LCO" to be consistent with the guidance of NUREG 1431. Since this change could limit the time that CL equipment is allowed out of service, this is a more restrictive change. This change is acceptable since it does not introduce any unsafe plant conditions.

111 Not used.

Prairie Island Units 1 and 2 2/2/02 Package 3.7 Part D 52

NSHD Change category number Discussion Of Change 3.7 LR 112 CTS Table 4.1-2B, Items 14, 16 and Note 6. CTS requirements to sample the Secondary coolant gross Beta Gamma activity (Item 14) and Secondary coolant chemistry (Item 16) have been relocated to the TRM. These sampling tests are not leak detection equipment, they are not process variables, they are not a part of the primary success path for mitigation of an accident and these tests have not been found to be significant to the public health and safety. Therefore these sampling tests do not meet the criteria of 10 CFR 50.36 for inclusion in the TS. Item 14 is not the subject of a TS in NUREG-1431, and since it does not meet the criteria of 10 CFR 50.36 (c)(2)(ii) it is not included in the ITS. Item 16 is related to the Secondary Water Chemistry Program in NUREG 1431 Section 5.5 and thus is not the subject of a TS in NUREG-1431. In accordance with the PI LAR dated December 14, 1995 (LA 141/132), PI does not propose to include a Secondary Water Chemistry Program in the ITS.

Thus, Item 16 has been relocated to the TRM. Since the SR for these tests are not in ITS, this is a less restrictive change.

However, this change is acceptable since the TRM is under the regulatory controls of 10 CFR 50.59.

Prairie Island Units 1 and 2 53 12/11/00 Package 3.7 Part D

NSHD Change category number Discussion Of Change 3.7 A

113 CTS 4.5.A.4.a, 4.5.A.5.a, 4.5.B.3.e, 4.5.A.B.3.f. The CTS has been revised to change phrase "refueling outage" or "refueling shutdown" to 24 months. As a result, DOC A3.4 113 was generated to justify this change. Throughout the ITS submittal, all SRs which are intended to be performed during refueling shutdown or refueling outage interval performance have a required Frequency of 24 months. The intent of the ITS is to allow PI operating cycles to extend up to 24 months. CTS 4.0.A.2 states that SRs with a "refueling shutdown" Frequency may not be performed at an interval exceeding to 24 months. ITS SR 3.0.2 retains CTS flexibility by allowing SR testing interval to be adjusted by 25%. CTS restrictions on this flexibility have also been retained in that ITS SR 3.0.2 states, "... the specified Frequency for each SR is met, except for SRs with a specified Frequency of 24 months, if the Surveillance is performed within 0.75 to 1.25 times the interval specified...." ITS SR 3.0.2 further reinforces this limitation by later stating, "The specified Frequency is met for each SR with a specified Frequency of 24 months if the Surveillance is performed within 24 months

." The proposed ITS does not intend for any SRs with 24 month Frequency to exceed 24 months and thus default PI operating cycles are limited to 24 months. Since the intent of the CTS Frequencies of "refueling outage" or Refueling Shutdown" are the same as the ITS, discussed above, this is considered to be an Administrative change.

I Prairie Island Units 1 and 2 54 2/2/02 Package 3.7 Part D

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

114 CTS Table 3.5-2B, Action 27. New Note added allowing separate Condition entry for each MS IV. CTS would require entry into LCO 3.0.C when two MSIVs were inoperable at the same time. This change will allow continued plant operation with inoperabilities of both MSIVs, providing the Required Actions are met. This change is acceptable since the Required Actions assure that the safety function of the MSIVs are maintained.

M 115 CTS 3.3.D.1.d. The CTS has been revised changing the volume of fuel oil supply required for the CL diesel from 19,000 to 19,500 gallons. Recent calculations have determined that 19,500 gallons are required to meet the design basis for the diesel driven CL pumps. This is a more restrictive change since the ITS divides the CTS diesel fuel oil volume into two separate Specifications. One Specification for the CL diesel fuel oil supply (3.7.8) and another for the diesel generator fuel oil supply (3.8.3). This change is acceptable since it envelopes the CTS fuel oil volume requirements The two separate fuel oil volume requirements ensure there is an adequate supply of fuel oil in order for the diesel driven CL pumps to perform their intended function and at the same time not consume fuel oil required to meet the EDGs needs.

Prairie Island Units 1 and 2 55 2/2/02

NSHD Change category number Discussion Of Change 3.7 M

116 CTS 4.8.B. A new SR has been added to manually cycle the SG PORV block valves every 24 months. The purpose of the SR is to manually cycle both PORV block valves closed and open to demonstrate their capability to perform this function. This change is considered to be a more restrictive since the CTS does not require an SR for manually cycling these block valves on a specific frequency. Adding this SR is acceptable since it ensures that the block valves will perform their intended function when required. This change is consistent with NUREG-1 431.

L 117 CTS 3.3.C.1.b. CTS states that. "any one of the following conditions of inoperability may exist..." This requirement prevents two or more of the listed conditions from existing at the same time to assure that there is no loss of safety function. The limitation that only one condition of inoperability may exist is not explicitly stated in ITS. In ITS, the system is treated as "trains" rather than individual components. The ITS assures there is no loss of safety function by requiring one train to be operable at all times.

Multiple components within a train may be inoperable since the whole train is considered inoperable when one component is not operable. Since the ITS would allow a train, instead of individual components as in the CTS, this change is considered to be a less restrictive change.

Prairie Island Units 1 and 2 56 2/2/02 Package 3.7 Part D

Part D Package 3.7 NSHD Change category number Discussion Of Change 3.7 L

118 Add new Condition and LCO Note. The LCO note allows the control room boundary to be open intermittently under administrative control. This.is acceptable since the ability to restore the boundary in the event of a DBA is always available in this condition. In addition, Condition B requires that with two CRSVS trains to be inoperable due to control room boundary in Modes 1, 2, 3, and 4, restore the control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Although less restrictive than the CTS, this change is applicable to PI since requiring the plant to enter LCO 3.0.3 when the ventilation envelope is not intact is excessive and not appropriate. The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is also acceptable since it is a reasonable time for routine repairs and due to the low probability of a DBA occurring during this time.

M 119 CTS Table 3.5-2B. CTS Table 3.5-2B, Action 27 requires that if the inoperable MSIV cannot be restored to OPERABLE status within a specific time, place the unit in at least HOT SHUTDOWN and close the associated valve. There is no specific time required to close the inoperable MSIV. ITS LCO 3.7.2, Condition D has been added. This Condition requires that if the inoperable MSIV cannot be closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , then be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Since the CTS only requires that the inoperable MSIV be closed and does not require any shutdown track, this is considered to be a More Restrictive change.

Prairie Island Units 1 and 2 57 2/2/02

MSIVs 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 TwoEFoti1 MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when both&--} MSIVs are closed--a-d

[de aetivated+/-.

A3.7-114-1 PA3.7-114 CL3.7-115I

[ i7~

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One MSIV inoperable in A.1 Restore MSIV to f8+/- hours MODE 1.

OPERABLE status.

B.

Required Action and B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not met.

C. ---------- NOTE------

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 AND C.2 Close MSIV.

Verify MSIV is closed.

f8l hours Once per 7 days r - -

1 I R-11 1 I

I L -

I Markup for PI ITS Part E WOG STS, Rev 1 04/07/95 3.7.2-1

SG PORVsADEVs 3.7.4 3.7 PLANT SYSTEMS I CL3.7-124 1 3.7.4 Steam Generator (SG)

Power Operated Relief Valves (PORVs)Atmospheric Dump Valves (ADVs)

LCO

3.7.4 APPLICABILITY

Two SG PORVs[Threl] ADV lines shall be OPERABLE.

MODES 1, 2, and 3T-CL3.7-124 CL3.7-125 I'IVL) ~

~

,ý%Ag t-""jýl-l

- !E*.I I111I I~l.~

U-LI e,.oI I-.5

!re.l/l l.l le.dl remova Wl.f ta eca~ i wu

~

irna ACTIONS CONDITION JREQUIRED ACTION J

COMPLETION TIME A. One SG PORVreq*i-red ADg line inoperable.

B.

Two SG PORVso -moire required ADV lines inoperable.

A.1 B.1 NOTE-------

LCO 3.0.4 is not applicable.

Restore SG PORV required ADV line to OPERABLE status.

Restore one SG PORVADV--I-ine to OPERABLE status.

ICL3.7-1241 7 days I PA3.7-353

-241 hours cL3"7-124- -

R-11 Markup for PI ITS Part E

-- I JL___

1 --" -- J r

I WOG STS, Rev 1 04/07/95 3.7.4-1

SG PORVsA)V-s 17 a

CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and associated Completion Time not met.

C.1 AND C.2 Be in MODE 3.

Be in MODE 4-w-itho-ut relianceeuo ta gcncatorFor heat r~emoveal.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ICL3.7-125 12{-I hou rs SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.4.1

-SR 3.7.4.2 Verify one complete cycle of each SG PORVAD÷.

Verify one complete manual cycle of each SG PORV ADV*-block valve.

FREQUENCY In accordance with the Inservice Testing Program{-l-81 mofr46 m18t24 months

+

IX3.7-137 I

+r Markup for PI ITS Part E ICL3.*7-124 X3.7-130 I

I R-1 WOG STS, Rev 1 04/07/95 3.7.4-2

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW)

System LCO

3.7.5 APPLICABILITY

TwoE-hree] AFW trains shall be OPERABLE.

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

A AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation. Only one AFW train, which includes a moltor driven pump,!

is required to b OPERABLE in MODE 4.

7-127J[

7-136 R-11 I

I L-I S...---------------

I +

CL.-129 MODES 1, 2, and 37 MODE 4 when steam gc neratc r is relied upon for heat remIl oval.

ACTIONS Markup for PI ITS Part E WOG STS, Rev 1 04/07/95 3.7.5-1 IPA3.

AFW System 3.7.5 CONDITION REQUIRED ACTION COMPLETION TIME One steam supply to turbine driven AFW pump inoperable.

OR NOTE --------

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

Restore affected equi pmentsteam-sttppl-y to OPERABLE status.

I

¶ B.

One AFW train inoperable in MODE* 1, 2 or -3Efor reasons other than Condition Al.

Restore AFW train to OPERABLE status.

7 days AND 10 days from discovery of failure to meet the LCO R-11 TA3.7-150 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

-AND da ys from

+

--discovery of

-failure to

-meet the LCO R-11 L-Markup for PI ITS Part E

-A.

A.1 B.1 WOG STS, Rev 1 04/07/95 3.7.5-2

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.7.5.4

-NOTES-F-1.

Not required to be performed for the turbine driven AFW pump until prior to exceeding 10% RTP or within 4

+

- 724 hour0.00838 days 0.201 hours 0.0012 weeks 2.75482e-4 months s+ after RCS temperature >

350OF t E1000] psi@ in thelsteam-l generateor.

2.

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation. Not appliable in,,D[ 4 when s generator is relied upon for heat removal..

Verify each AFW pump starts automatically on an actual or simulated actuation signal.

I-SR 3.7.5.5 Verify proper alignment of the required AFW flow paths by verifying flow fromi the condensate storage tank to eaeh steam

..,.M t,,,,

FREQUENCY CL3.7-134]

A3.7-136-I r

i I

I I R-11 I

I L- --

t X3.7-1371 24-E6l--months PA3.7-139 Markup for PI ITS Part E i

I WOG STS, Rev 1 04/07/95 3.7.5-6

CSTs 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tanks (CSTs)

LCO

3.7.6 APPLICABILITY

The CSTs l-eve-l--shall be OPERABLEt r110,-000 gll.

MODES 1, 2, and 3-;

i'.lfl A.

.....n i-rm Fen,*ra,,r is re i ai

,i n for 6....

CL3.7-141 TA3"7-142 CL3.7-143

-reffeval.

ACTIONS i

COMPLETION L_

CONDITION REQUIRED ACTION TIME TIME A.

CSTs inoperableleve-l not within limit.

Verify by administrative OPERABILITY of water supply.

means backup Restore CSTs lvel-lto OPERABLE status wi hi

_,i-'*

1-t 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 7 days R-11 I

TA3.7-142 Markup for PI ITS Part E A.1 AND A.2 WOG STS, Rev 1 04/07/95 3.7.6-1 I

CSTs 3.7.6 COMPLETION CONDITION REQUIRED ACTION TIME TIME B.

Required Action and associated Completion Time not met.

B.1 AND B.2 Be in MODE 3.

Be in MODE 4, without relianee on steam generator for heat removal.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12{-+18 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.6.1 Verify t-he-CSTs useable contents lel is

Ž

-[10+/-0,000 gall per operating unit.

FREQUENCY i

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ICL3.7-141 Markup for PI ITS Part E IR-11I WOG STS, Rev 1 04/07/95 3.7.6-2

CL SystemS-S 3.7.8 3.7 PLANT SYSTEMS 3.7.8 CoolingServiee Water (CL)

System-(-SWS--

I PA3.7-146]

LCO

3.7.8 APPLICABILITY

ACTIONS Two CLSW-S trains shall be OPERABLE.

MODES 1, 2, 3,

and 4.

COMP LElTION CONDITION REQUIRED ACTION TIME TIME A.

No safeguards CL pumps OPERABLE for one train.

NOTES ------

1.

Unit 1 enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-MODES 1, 2, 3, and 4," for emergency diesel generator made inoperable by CL System.

2.

Both units enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by CL System.

L __________________________________________

I r

R-11 L -------

CL3.7-1471 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 3.7.8-1

CL SystemSW-S 3.7.8 COMPLETION CONDITION REQUIRED ACTION TIME TIME

3.

This Condition may not exist > 7 days in any consecutive 30 day period.

Restore one safeguards CL pump to OPERABLE status.

I CL3.7-147 7 days AND I PA3.7-348 I 10 days from discovery of failure to meet the LCO R-11 1 I

I L----------I Markup for PI ITS Part E A.l WOG STS Rev 1, 04/07/95 3.7.8-2

CL SystemSWS 3.7.8 COMPLETION CONDITION REQUIRED ACTION TIME TIME One CL supply headerSWS train inoperable.

A.!

NOTES-----

1. Unit 1 eEnter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-MODES 1, 2, 3, and 4 Operating,"

for emergency diesel generator made inoperable by CL SystemSWS.

2.

Both units elnter applicable Conditions and Required Actions of LCO 3.4.6,"RCS Loops-MODE 4," for residual heat removal loops made inoperable by CL SystemSWS.

I CL3.7-1481 Markup for PI ITS Part E BA.

WOG STS Rev 1, 04/07/95 3.7.8-3

CL SystemnW-S 3.7.8 COMPLETION CONDITION REQUIRED ACTION TIME TIME B.1 AND B.2 AND B.3 Verify vertical motor driven CL pump OPERABLE.

Verify opposite train diesel driven CL pump OPERABLE.

Restore CL supply headerSWS -tran to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ICL3.7-148 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months PA3.7-146 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 I PA3.7-3481 days from discovery of failure to meet the LCO CB.

Required Action CB.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time-e-f AND Cld-i-i-n-A not met.

CB.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Markup for PI ITS Part E r

I R-11 I L-WOG STS Rev 1, 04/07/95 3.7.8-4

CL SystemSW%

3./.b I

COMPLETION CONDITION REQUIRED ACTION TIME TIME ACTIONS (continued D. Diesel driven CL pumps stored fuel oil supply

< 19,500 gal and >

17,000 gal.

E.

Diesel driven CL pumps stored fuel oil supply

< 17,000 gal.

OR Required Action and associated Completion Time of Condition D not met.

D.

1 E.1 Restore fuel oil supply to within limits.

Declare diesel driven CL pumps inoperable.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months I PA3.7-159 AND 9 days IPA3.7-348 from di scov ery of failure to meet the LCO r --. -.-.-.- l I R-11 I

I L----------I PA3.7-159 Immediately Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 3.7.8-5

CL SystemnW-S 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.8.1

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

Isolation of CLSW-S flow to individual components does not render the CL SystemSWS inoperable.

Verify each CLSystemSW-S manual, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

FREQUENCY I PA3.7-146 31 days SR 3.7.8.2 Verify each diesel driven CL pump starts CL3.7-151 and assumes load within one minute.

31 days I PA3.7-159 SR 3.7.8.3 Verify stored diesel driven CL pumps fuel oil supply > 19,500 gal.

31 days CL c,.7-151 SR 3.7.8.4 Verify OPERABILITY of vertical motor driven CL pump.

92 days Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 3.7.8-6

CL SystenfW-S 3.7.8 SURVEILLANCE SR 3.7.8.5Z Verify each CL SystemSW-& automatic valve required to mitigate accidents in the fl-ow pa-t that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

FREQUENCY 24{-l18} months CL3.7-146 CL3.7-152 CL3.7-116I SR 3.7.8.63 Verify efteI the diesel driven and vertical motor driven CL-SWS pumps starts automatically on an actual or simulated actuation signal.

24-+81-months R-2 1 I..----

I PA3.7-146 CL3.7-153 CL3.7-116 Markup for PI ITS Part E I

I R-2 I I

I L..

.I WOG STS Rev 1, 04/07/95 3.7.8-7 I

Emergency CL SupplybUS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Emergency Cooling Water (CL)

SupplyUltimate "eat Sink (""I' LCO 3.7.9 The Emergency CL SupplybUS shall be OPERABLE.

CL3.7-154 CL3.7-156I CL3.7-154 APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS R-11 CONDITION A. One safeguards traveling screen inoperable.

REQUIRED ACTION

1*

A. I AND A.2

--NOTE.-------

Not applicable during periods of testing for < 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Verify one emergency bay sluice gate open..

Restore safeguards traveling screen to OPERABLE status.

COMPLETION TIME I CL3.7-156 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L-7I R-11 I

L I

90 days Markup for PI ITS Part E WOG STS, Rev 1 04/07/95 3.7.9-1

CRSVE-FS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Special VentilationEmergency Filtration System (CRSVEFS)

LCO 3.7.10 APPLICABILITY:

IPA3.7-162 Two CRSVE-FS trains shall be OPERABLE.

IPA3.7-162 N

-NOTE The control room boundary may be opened intermittently under administrative control.

TA3.7-354 I

I II R-11 I

MODES 1, 2, 3, and 4, [5,-a and ICL3"7164TI During movement of irradiated fuel assemblies-ACTIONS I

CONDITION I

REQUIRED ACTION COMPLETION TIME A.

One CRSVEFS train inoperable.

A.1 Restore CRSVEFS train to OPERABLE status.

7 days IPA3.7-162 I

B.

Two CRSVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control status.

room boundary in MODES ITA3.7-354 1, 2, 3, or 4.

r R-1 1 Markup for PI ITS Part E

' R-11 L---------

Lu~ul I'd

%.VI\\L-

/'1I..I L.I\\PI L.UI1-.Jj.

WOG STS, Rev 1 04/07/95 3.7.10-1 I I L

CRSVEFS 3.7.10 ACTIONS CONDITION R

REQUIRED ACTION COMPLETION TIME Required Action and associated Completion Time of Condition A not met in MODE 1, 2, 3, or 4.

4 Required Action and associated Completion Time of Condition A not met ti-,MODE5 or 6, or] during movement of irradiated fuel assemblies Er duri~nghCORE ALTERATIONlSI.

BC.1 Be in MODE 3.

AND BC.2 Be in MODE 5.

GD. 1 NOTE-n.1aee inH taxic eYa5

-prateetion made if aurctomatic-ý t ra n sfer, to toxie gas preteetion mode is i noperabl e.

Place OPERABLE CRSVEFS train in emergency mode.

OR A.2. uspend COR[P ALTERATIONS.

GD. 2-.

32]

-Suspend movement of irradiated fuel assemblies.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours CL3.7-166 CL3.7-164 r

i I

I I R-11 I

I I

L

.I PA3.7 -162 TA3.7-165 Immediately ITA3"7-165 Immediately I

IR-11 I

I I

L

.I Markup for PI ITS Part E 8C.

GD.

______________________________________ a ______________________________________

WOG STS, Rev 1 04/07/95 3.7.10-2

CRSVE-FS 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Two CRSVE-FS trains inoperable [in MODE*5 6, or] during movement of irradiated fuel assembl i e s--or-o during GORE ALTERAT+/-GHS1.

r%

I1*J D1 Suspend CORE ALTERATION~S.

9E.1{2]- Suspend movement of irradiated fuel assemblies.

I t

Two CRSVEFS trains inoperable in MODE 2,

3, or 4 for reasons other than Condition B.

EF.1 Enter LCO 3.0.3.

I I

I I r

.4.4 I

II i

I I

1I Immediately Immediately PA3.7-162 CL3.7-167

TA3.7'354

PA3.7-162 SR-1 r

'1 I

I L-IR-11 I - -

SURVEILLANCE REQUIREMENTS SURVEILLANCE

+

SR 3.7.10.1 Operate each CRSVE-FS train for

[Ž 10 --ntinuous hours with the heaters AA- -A A I I I

I A

l-d

Afi WILhn~t Ih Irlq I4b l

Ž15 minutes].

FREQUENCY 31 days PA3.7-162 TA3.7-165 SR 3.7.10.2 Perform required CRSVE-FS filter testing in In accordance accordance with the fVentilation Filter with EVFTP Testing Program (VFTP)+.

Markup for PI ITS Part E DE.

EF.

1, j

Immfndi a

,te-^,

J WOG STS, Rev 1 04/07/95 3.7.10-3

CRSV-FS 3.7.10 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.7.10.3 SR 3.7.10.4 Verify each CRSVE-FS train actuates on an actual or simulated actuation signal.

Verify theoet CRSVEFS fan in each train delivers 3600 to 4400 cfmcan naintai, a pomitiv I

pressure of t! 0o.125] inLhes wate gauge, relativc to the adjaeent [turbine building] during the pressurization

d. ^ of operation at a mfakeup flow rate-o-f t E3000] -fem.

FREQUENCY 24{-8+/-

months PA3.7-162 X3.7-137 24f-118 months on a STAGGERED TEST BASIS CL3.7-168 X3.7-137 Markup for PI ITS Part E I

WOG STS, Rev 1 04/07/95 3.7.10-4

Safeguards Chilled Water SystemCREATC-S 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Safeguards Chilled Water System (SCWS)GantroRe Temperature Control System (CR[ATCS)

A" PA3.7-169 LCO 3.7.11 APPLICABILITY:

Two SCWSGREATGC loopst-rai-ns shall. be OPERABLE.

MODES 1, 2, 3, and 4, E5, and 6-1 During movement of irradiated fuel assemblies rn.--

r('nr Al TrnATTrIc1 PA3.7-169 PA3.7-171 TA3.7-165 ACTIONS L

CONDITION REQUIRED ACTION COMPLETION IPA TIME A. One SCWSnREATGS loop-raIin inoperable.

B.

Required Action and associated Completion Time of Condition A not met in MODE 1, 2, 3, or 4.

A.1 B.I AND B.2 Restore SCWSGREATIG loopt-ra-in to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

R-11iI 3.7-1711 30 days IPA3.7-169 I 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Markup for PI ITS Part E LL.ý I IId-l

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WOG STS Rev 1, 04/07/95 3.7.11-1

ABSVSECGC PRERAC 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Auxiliary Building Special VentilationEmergen, y Care Cooling System

([CGS) rump Room Exhaust Air CleanupSystem (ABSVSPREAGS)

IPA3.7-172 LCO 3.7.12 APPLICABILITY:

Two ABSVSECCS PREAC& trains shall be OPERABLE.

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

The ABSV boundary may be opened under adlministrative control -

IPA3.7-172 I CL3.7-174 MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ABSVSEGGS* PREACS A.1 Restore ABSVSE-CC 7 days train inoperable.

P-REACS train to OPERABLE status.

B.

Two ABSVS trains inoperable due to inoperable ABSVS boundary.

B.1 Restore ABSVS boundary to OPERABLE status.

PA3.7-172 cL3"7-174 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C.B Required Action and CB.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND CB.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Markup for PI ITS Part E I

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WOG STS Rev 1, 04/07/95 3.7.12-1

ABSVSECC

,,P*AG&

3.7.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each ABSVSEGGS PREAeS train for 31 days ft 1i0 eentinuoui y hours with the heaters operating or (for systems without heaters 15 F inll.7-17 SR 3.7.12.2 SR 3.7.12.43 SR 3.7.12.34 1 0 7 1 ) r Perform required ABSVS CS-P-REACS filter testing in accordance with the IVentilation Filter Testing Program (VFTP)+/-.

Verify each ABSVSECGSP-REAG train actuates on an actual or simulated actuation signal.

Verify eachne ABSVSEC*S PREACS train can producemairntair, a negative pressure within 6 minutes after initiation_

[-0.125] in"hes water gauge relative to atm-spheri V '.

S I J

I I flL.I IV.J..)

I I I

kJJ JL'..J.J In accorda nce with the EVFTPI 4-244-81 months I CL3.7-177 PA3. 7-172 CL3.7-175 PA3"7-1721 4-92 days-El PA3.7-172 8]-men X3.7-137

++hs-on LJ a

BASIS IPA3.7-172I j47CL3.7-176 Markup for PI ITS Part E L-i operation at a flevo rate of _< E3000] efi..,

xi-*

-C-L, rPr1C nnr A PC C.* 1 4---

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i -

udiil l el l idf fl iki WOG STS Rev 1, 04/07/95 3.7.12-2 l

MSSVs B 3.7.1 IPA3.7-2O1]

BASES ACTI{ONS (eoft1*T e1td eonditions of the valve at nominal operating temperature and LCO This LCO provides assurance that the MSSVs will perform (continued) their designed safety functions to mitigate the consequences of accidents that could result in a ITA3.7-202 challenge to the RCPB or Main Steam System integrity.

APPLICABILITY ACTIONS In MODES 1, 2, and 3 above 40% RTP, the numbe-202 effive MSSVs per steam generator are required to be OPERABLE to prevent Main Steam System overpressurization.

m,4ust be according to Table 3.7.1 1 in the a..ompanying LCO.

Below 40%ý RT-P in MODES 1, 2, and 3, only two MSSVs per steam generator are r-euied to be nnERA-LE.

In MODES 4, ai-d-5, and 6, there are no credible transients requiring the MSSVs.

JPA3.7-207 The energy content in the steam generators is sufficiently low are not normally used for heat remova, in MODES 5 and 6-,

,nd thus that they cannot be overpressurized; there is no requirement for the MSSVs to be OPERABLE-in these MODES.

The ACTIONS table is moadified by a Note indicating that separate Condition entry is allowed for each MSVT.

-112 A.1 With one eor-lore MSSVWs inoperable, redtee-e powerrestore OPERABILITY of the inoperable MSSV within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is a reasonable time due to the low I

probability of an event or transient occuring during this time requiring MSSV operation.

so that the available MSSV r_,

relieving,apaity m,,cets Referene 2 requirem""ents for the 'I R-1 1 E*iALI-PI I

LT....... t Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.1-4

MSIVs B 3.7.2 BASES on operating experience, to reach MODE 2 and to close the 4$-Vs-in an orderly manner-a-nd without challenging unit systems.

C.1 and C.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

r......

I I

Since the MSIVs are required to be OPERABLE in MODES 2 LR-I i

and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

ACTIONS G.1 and C.2 (eontinue-d)

The -8+ hour Completion Time is consistent with that allowed in Condition A for one MSlV inoperable.

For an inoperable MSIVW& that cannot be restored to OPERABLE status within the specified Completion Time, but isa-re closed, the inoperable MSIVs must be verified on a periodic basis to be closed.

This is necessary to ensure that the assumptions in the safety analysis remain valid.

The 7 day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure that these valves are in the closed position.

D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status or are not closed within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply.

To achieve this status, the unit must be placed at least in (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.2-7

PA3.7-201 SG PORVsADVs B 3.7.4 APPLICABILITY In MODES 1, 2, and 3, and i"n MODE 4, whn* a I__________

steam generator is being relied upon for heat CL3.7-125 removal, the SG PORVsAB-s are required to be OPERABLE.

In MODE 4, a steam generator and the SG PORV are not relied upon for heat removal.

In MODE 5 or 6, an SGTR is not a credible event.

ACTIONS A.1 With one required SG PORVADV---inre inoperable, action must be taken to restore OPERABLE status within 7 days.

The 7 day Completion Time allows for the redundant capability afforded by the remaining OPERABLE SG PORVABV lines, a nonsafety grade bakup in the Steam DumpBypass System, and MSSVs.

Required Action A.1 is modified by a Note indicating that LCO 3.0.4 does not apply.

B.1 With two or-mfoie-SG PORVsA9V lines inoperable, action must be taken to restoreall but one SG PORVAD1V*l-i-ne to OPERABLE status.

Since the block valve can be closed to isolate aft SG

PORVADV, some repairs may be possible with the unit at power.

The -241 hour Completion Time allows time to PA3.7-353 plan an orderly shutdown of the unit and is reasonable to repair inoperable ADV lines, based on the availability of the Steam Dump Bypass System 1R-111 and MSSVs, and the low probability of an event occurring L-during this period that would require the SG PORVABV- -lines.

B 3.7.4-4 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95

IPA3.7-201 SG PORVsADVs B 3.7.4 SR 3.7.4.2 I X3.7-137 I The function of the block valve is to isolate a failed open ADVSG PORV.

Manually Ccycling the block valve both closed and open demonstrates its capability to perform this function.

Performance of inservice testing or use of the block valve during unit cooldown may satisfy this requirement.

Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month requ*eney. The Frequency is acceptable from a reliability standpoint.

REFERENCES

1.

UFSAR, Section 11.4EI0.3+/-.

2.

USAR, Section 14.

Markup for PI ITS Part E r...

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B 3.7.4-6 l

WOG STS Rev 1, 04/07/95

AFW System PA3.7-201 B 3.7.5 BASES Two{-T-ree]- independent AFW pumps in two{+-lee+

diverse trains are required to be OPERABLE to CL3.7-251 ensure the availability of decay heat removalRl-R capability for all events accompanied by a loss of *offsite power main feedwater and a single failure.

This is accomplished by powering two of the pum.ps from independent emergency buses.

The third AFW pump is powereýd by a different mflans,a steamf driven turbine supplied with, steam, fromn a source that is n isolated by elesure of the MS!Vs.

The AFW System is configured into [three] trains.

The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.

This requires that the onetwe motor driven AFW pumps-be OPERABLE and capable of i-n

[tw,] diverse paths, ea*h supplying AFW to both separate steam generators.

The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of ftwo-main steam lines upstream of the MSIVs, and shall be capable of supplying AFW to bothan-o-f-- the-steam generators.

The piping, valves, instrumentation, and controls in the required flow paths, required for the system to perform the safety related function, also are required to be OPERABLE.

The normal (Condensate Storage Tanks (CSTs))

and backup (Cooling Water PA3.7-255 System) water supplies to the AFW pumps must also be OPERABLE.

OPERABILITY requirements for the CSTs are specified in LCO 3.7.6, "Condensate Storage Tanks (CSTs)."

The LCO is modified by a Note indicating that enean AFW train, which includes a motor driven pumfp, is required to may be considered OPERABLE TA37136 I

i IR-11 1 L-------

B 3.7.5-6 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95

AFW System IPA37-201 B 3.7.5 BASES

a.

For the inoperability of a steam supply to the TATTT5 1 turbine driven AFW pump, tThe 7 day Completion i

Time is reasonable since there is a redundant OPERABLE steam supply line for-to the turbine driven AFW pump;

b.

For the inoperability of a turbine driven AFW TA3.7-150 pump while in MODE 3 immediately subsequent to a refueling outage, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situationThe availability of redundant OPERABLE motor driven AFW pumpq3s; and

c.

For both the inoperability of a steam supply IT3.-150O line to the turbine driven pump and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of the redundant OPERABLE motor driven AFW pump, and due to tihe low probability of an event accurrning that requiringe-s the use ofinperabi' steam supply to the turbine driven AFW pump.

ACTIONS-A.!

(eantinued)

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently.

The AND connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

R-11 L

I B 3.7.5-8 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95

AFW System B 3.7.5 I PA3.7-201 BASES Condition A is. modified by a Note which limits the applicability of the Condition when the TA3.7-150 unit has not entered MODE 2 following a refueling.

Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B.

This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

B.1 R-11 L

With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 [for cL3"7-129 reasons other than Condition Al, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This Condition includes the loss of two steam supply lines to the turbine driven AFW pump.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on redundant capabilities afforded by the AFW System, time needed for repairs, and the low probability of a DBA occurring during this time period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently.

The AND connector between 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

I R-11 L -

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l WOG STS Rev 1, 04/07/95

I PA3.7-201 I

AFW System B 3.7.5 BASES (continued)

control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable.

This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable.

Since AFW may be used during MODES 2, 3 and 4 operations for steam generator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY (i.e., the intended safety function) continues to be maintainedthe SR is-no required in MODE 4. in MODE 4, the required AFW train is already aligned and operating.

SR 3.7.5.4 This SR verifies that the AFW pumps will start in the eve**t of any accident or transient that generates an ESFASwhen required by demonstrating that each AFW pump starts automatically on an actual or simulated AFW pump start "aetta-i signal in MODES 1, 2, and 3.

in MODE 4, the required putmp is already operating and the autostart function is not required. Since this PA3.7 test is performed during unit shutdown, the turbine driven AFW pump is not actually started, but the components necessary to assure it starts on an actual or simulated AFW pump start signal are demonstrated to be OPERABLE.

This test is considered satisfactory if control board indication and subsequent visual observation of the equipment demonstrate that all components have operated properly.

The 24 f1-] month Frequency is x3.7 based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

This SR is modified by -al-]two-Note-si.

fNote CL3.7-134 R-11 I

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WOG STS Rev 1, 04/07/95

-255 I 137 I Markup for PI ITS Part E B 3.7.5-14

AFW System B 3.7.5 I PA3.7-201 1 indicates that the SR be deferred until CL3.7-134 suitable test conditions are established.

This deferral is required because there is CL3.7-138 insufficient steam pressure to perform the test.]

ET"he Note 2-2]-states that one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable.

This exception allows the system to be out of its normal standby alignment and SURVEILLANCE

-REQUIREMENTS

]

1R-11 1

I I

TA3.7-136 I

temporarily incapable of automatic initiation without declaring the train(s) inoperable.

Since AFW may be used during MODES 2, 3 and 4 operations for steam generator level

control, and these manual operations are an accepted function of the AFW system, OPERABILITY (i.e., the intended safety function) continues to be maintainedthe SR is "required in MODE 4. [in MODE 4, the required pump is already operating and the autestart funetion isnt required.]

[In MODE 4, the heat removal requirements wIuld be less providing moere timfe for operator aetion to manually start the required ArW pump.]-I SR 3.7.5.4 (continued)

Reviewer's Note:

Some plants may not routinely use the AFW for heat removal in MODE 4. The second justification is provided for plants that use a startup feedwater pum.p rath than AFW for startup and shutdown.

This SR verifies that the AW is properly aligned by verifying the flow paths from the P3.7-139 CST to each steam generator prior to entering MODE 2 after more than 30 days in MODE 5 or 6.

OPERAILIT o

,f AW fl,,w

,,,ths mutbvrfed before sufficient core heat is generated that would require the operation of the Markup for PI ITS Part E BASES WOG STS Rev 1, 04/07/95 B 3.7.5-15

CSTs B 3.7.6 B 3.7 PLANT SYSTEMS B 3.7.6 Condensate Storage Tanks (CSTs)

PA3.7-201 CL3.7-141 BASES BACKGROUND Three 150,000 gallon CSTs (total) are shared via a common header between the 2 units. Unit 1 has 1 tank (11) and Unit 2 has 2 tanks (21 and 22).

The CSTs provides a nonsafety grade source of water to the steam generators for removing decay and sensible heat from the Reactor Coolant System (RCS).

A backup safety grade source of water is provided by the safety-related portion of the Cooling Water (CL)

System (LCO 3.7.8) via either the Emergency Cooling Water Line or the emergency bay sluice gates.

Since water supplied from the CL System is of lower ICL3.7-254 purity, its use is considered less desirable under normal conditions than the higher purity condensate water from the CSTs.

However, if needed, the operator can lineup the Cooling Water supply by opening the associated CL supply motor operated valve (MOV) and closing the associated CST supply MOV for each auxiliary feedwater pump.

The CSTs provides a passive flow of water, by gravity, to the Auxiliary Feedwater (AFW)

PA3.7-247 System (LCO 3.7.5).

The steam produced is released to the atmosphere by the main steam safety valves, ei-the steam generator power operated relief valves or the atmospheric dump valves.

EachT-he AFW pumps operates with a continuous recirculation to at-he CST.

When the main steam isolation valves are open, the preferred means of heat removal is to discharge steam to the condenser by the nonsafety grade path of the steam dumpbypass valves.

The condensed steam '-smay be returned to the CSTs by the (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.6-1

CST PA3.7-201 B 3.7.6 cL3141 BASES (requiring additional steam to drive the remnaining AFW pump turbine); anrd

b. Failure of the steamn driven AFW pump (requiring a longer time for cooldown using only 0n"mtr rie These are not usually the limniting failures in terms of consequenees for these events.

A nonlimiting event eonsidered in CST inventory determinations is a break in either the main feedwater or AFW line near where the two join.

This break has the potential for dumping condensate until terminated by operator action, since the Emergency Feedwater Actuation System would not detect a differenee in pressure between the steam generators for this break location.

This loss of eondensate inventory is partially eompcnsated for by the retention of steam generator inventory.

The 100,000 gallon CSTs useable volume requirement for each unit in MODE 1, 2, or 3 is sufficient to:

I L.-256

a. Remove the decay heat generated by one reactor in the first 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after shutdown;

b. Ensure sufficient water is available-to cool down a reactor from 547 0F to 350OF using natural circulation at 250F/hour; or C. Ensure sufficient water is available to hold the unit in Mode 3 for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , followed by a cooldown to RHR entry conditions within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

These calculations take into account the decay heat and reactor coolant system stored energy. (Ref. 1)

The CST satisfies Criteria"n 2 and 3 of 10 IR-11 CFR 50.36 (c)

(2) (ii)the NRC Policy Statcent

.7142L---

(conti nued)

WOG STS Rev 1, 04/07/95 B 3.7.6-3 Markup for PI ITS Part E

CST B 3.7.6 PA3.7-201 IcL3"7-141 To satisfy aecident analysis assumptions, the CST must eontain sufficient cooling water to remoe decay heat for [30 minutes] following a reactor trip from 102%ý RTP, and then to cool down the RCS to RIIR ent-ry eanditions, assuming a coinciddent loss of offsite power and the most adverse single failure. in doing this, it must retain sufficient water to ensure adequate net positive suction head for the AFW pumps during cooldown, as well account for any losses from the steam driven AFW pump turbine, or before isolating AFW to a broken line.

The CS~s are considered OPERABLE when the CSTs' contents have at least 100,000 gallons useable per operating unit (MODES 1, 2, or 3).

The GST level required is equivalent to a usable volume of t! E110,000 gallons], which is based on holding the unit in MOD[ 3 for [2] hours, followed by a ecooldown to entry conditions at [75]VF/hour.

This basis is establis in Reference 24 and exceeds the volume required by the accident analysis.

LCO (continued)

The OPERABILITY of the CSTs is determined by maintaining the tank level at or above the minimum required level.

APPLICABILITY In MODES 1, 2, and 3, and in MODE 4, when steam (conti nued)

Markup for PI ITS Part E BASES LCO CL3.7-257

__L I R-11 I

~I4I 1 1 I

hed I CL3.7-143 1 as WOG STS Rev 1, 04/07/95 B 3.7.6-4

CST B 3.7.6 PA3.7-2011 ICL3.7-14 BASES being relid upon for heat rema*l the CSTs are +a required to be OPERABLE.

In MODES 4, 5 or 6, the CSTs are +s--not required because the AFW System is not required.

ACTIONS A.1 and A.2 I

I I R-11 I L -

J If the CSTs are not OPERABLE (e.g., level is not within TA3.7-142 limits), the OPERABILITY of the backup safety-related portion of the CL supply should be verified by administrative means within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

OPERABILITY of the backup safety-PA3.7-2611 related portion of the CL feedw-te-e

~supply must include verification that the flow paths from the backup water supply to the AFW pumps are OPERABLE in accordance with LCO 3.7.8., and that the backup supply has the required volumc of water available. The CSTs must be restored to OPERABLE status within 7 days, because the bakup supply may be performing this funtion in addition to its normal*,

funetions.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to verify the OPERABILITY of the TA76 backup safety-related portion of the Cooling Wwater supply.

Additionally, verifying the backup water supply every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is adequate to ensure the backup water supply continues to be available. The 7 day Completion Time is reasonable, based on an OPERABLE backup safety-related (conti nued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.6-5

PA3.7-201 CST IcL3 "7-141 B 3.7.6 BASES (continued) portion of the CLwater supply being available, and the low probability of an event occurring during this time period requiring the CSTs.

B.1 and B.2 If the CSTs cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply.

To achieve this status, the unit must be placed in at CL3.7-144I least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4, without reliance on the steam generator for heat removal, within 12+/-8 hours.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.6.1 REQUIREMENTS This SR verifies that the CSTs contains the required useable volume of cooling water.

(The required CST volume may b single value or a funtion of RCS onditions.)

, R-111 L-j The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is based on operating experience and the need for operator awareness of unit evolutions that may affect the CST inventory between checks.

Also, 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 in the control room, including alarms, to alert the operator to abnormal deviations in the CST level.

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.6-6

CL SystemSWS B 3.7.8 PA3.7-146 11 PA3.7-201 1 BASES OPERABILITY of the equipment serviced by the CLSWS System and required to be OPERABLE in these MODES.

In MODES 5 and 6, the OPERABILITY requirements of the CL System areSWS are determined by the systems it supports.

A.1 If no safeguards CL pumps are OPERABLE for one train, action must be taken to restore one CL safeguards pump to OPERABLE status within 7 days.

CL3.7-147J Either the diesel driven CL pump for the train may be restored to OPERABLE status, or the 121 CL pump may be aligned to fulfill the safeguards function for the train that has no OPERABLE safeguards CL pump.

The 7 day Completion Time is based on:

a.

Low probability of loss of offsite power during the period;

b.

The low probability of a DBA occurring during this time period;

c.

The safeguards cooling capabilities afforded by the remaining OPERABLE train; and

d.

The capability to route water from the non-safeguards pumps, if needed.

The second Completion Time for Required Action PA3"7-3481 A.1 establishes a limit on the maximum time allowed for combinations of Conditions A and B to be inoperable during any continuous failure to meet this LCO for these Conditions.

The 10 day al 1 owed in failure to Completion Time provides a limitation time this specified Condition after discovery of meet the LCO.

This limit is considered IR-11 (continued)L -------,

Markup for PI ITS Part E ACTIONS WOG STS Rev 1, 04/07/95 B 3.7.8-8

CL SystemSW-S B 3.7.8 PA3.7-1461I PA3.7-201 BASES reasonable for situations in which Conditions A entered concurrently.

The AND connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

and B are I PA3.7-34*3 Required Action A.1 is modified by 3 notes.

Note 1 requires Unit 1 entry into the applicable Conditions and L

Required Actions of LCO 3.8.1, "AC Sources-Operating,"

for an emergency diesel generator made inoperable by the CL system.

For Unit 1, the diesel generators are major heat loads supplied by the CL system. Thus, inoperability of two safeguards CL pumps will affect at least the heat loads on one CL header, including one Unit 1 diesel generator.

Inability to adequately remove the heat from the diesel generator will render it inoperable.

Note 2 requires entry into the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE CL3 4", for both units for the RHR loops made inoperable by the CL System.

If either unit is in MODE 4, inoperability of two safeguards CL pumps may affect all the heat loads on one CL header, including a CC train and subsequently one RHR heat exchanger on each unit. Inability to adequately remove the heat from a RHR heat exchanger will render it inoperable.

Note 3 specifies that the Condition with no safeguard CL pumps OPERABLE for one train may not exist for more than 7 days in any consecutive 30 day period.

If such a condition occurs, Condition C must be entered with the specified Required Action taken because the equipment reliability is less than considered acceptable.

(continued)

I R-111

-I

.7-1471 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-9

CL SystemSW-S B 3.7.8 IPA3.7-146I PA3.7-201 BASES ACTIONS BA.1,B.2 and B.3 I ~CL3. 7-148I If one CLSWS supply headertriai-n is inoperable, action must be taken to verify the vertical motor driven CL pump and the opposite train diesel driven CL pump are OPERABLE within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and restore the inoperable CL header to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Verification of vertical motor driven CL pump OPERABILITY does not require the pump to be aligned and may be performed by administrative means. Verification of the opposite train diesel driven CL pump may be performed by administrative means.

Completion of the CL pump surveillance tests is not required.

R-1 1 R-11,

Conditions may occur in the CL System piping, valves, or L -------,

instrumentation downstream of the supply header (e.g.,

closed or failed valves, failed piping, or instrumentation in a return header) that can result in the supply header being considered inoperable. In such cases, Condition B and related Required Actions shall apply.

In this Condition, the remaining OPERABLE CLS&WS headertira-n is adequate to perform the heat removal function. However, the overall redundancyrel-abili-ty is reduced because only a single CL train remainsfailure in the

,OPERABLE S"S trai could result in loss of SWS fun.tion.

Required Action B.1 ensures that the vertical motor driven 121 CL pump may be used to provide redundancy CL3.7-148 for the safeguards CL pump on the OPERABLE header.

Required Action B.3 assures adequate system reliability is maintained.

The second Completion Time for Required Action B.3 establishes a limit on the maximum time allowed for combinations of Conditions A and B to be inoperable during R-11 I

(continued)L ------- 1 Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-10

CL SystemSW&

B 3.7.8 PA3.7-146 I PA3.7-201 BASES any continuous failure to meet this LCO for Ill!

these Conditions.

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently.

The AND connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Required Actions BA.1 B.2 and B.3 arei-s modified by two Notes.

The first Note indicates that the applicable Conditions R11 and Required Actions of LCO 3.8.1, "AC Sources Operating," should be entered for Unit 1 since+4f an inoperable CLSWIS train results in an inoperable emergency diesel generator.

The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," should be entered if an inoperable CLSW-S train results in an inoperable decay heat removal train.

This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

The 4 and 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Times are+i-sbased on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

In addition, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for Required Actions B.1 and B.2 is within the time period anticipated to verify OPERABILITY of the required CL pump by administrative means.

CB.1 and CB.2 If the-at least one safeguards CLS44S pump for a train or a CL supply header cannot be restored to OPERABLE status within the associated Completion Time, the units must be (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-11

CL SystemSW-S B 3.7.8 PA3.7-146 PA3.7-201 BASES placed in a MODE in which the LCO does not apply.

To achieve this status the units must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1 In this Condition, the 14 day fuel oil supply for the PA3 diesel driven CL pumps is not available.

However, the Condition is restricted to fuel oil supply reductions that maintain at least a 12 day supply.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank(s).

A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required supply prior to declaring the diesel driven CL pumps inoperable.

This period is acceptable based on the remaining 12 day fuel oil supply, the fact that procedures will be initiated to obtain replenishment, availability of the vertical motor driven CL pump and the low probability of an event during this brief period.

The second Completion Time for Required PA3.7-348 Action D.1 establishes a limit on the maximum time allowed for combinations of Conditions A and D to be inoperable during any continuous failure to meet this LCO for these Conditions.

r...

l I

I R-11,

I I

L----------

.7-1591 I

The 9 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and D are entered R-11 (conti nued.-------

Markup for PI ITS Part E I

I WOG STS Rev 1, 04/07/95 B 3.7.8-12

CL SystemSW-S B 3.7.8 1PA3.7-146, PA3.7-201 BASES I PA3.7-348 concurrently.

The AND connector between 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and 9 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

E.1 With the stored fuel oil supply not within the limits specified or Required Actions and associated Completion Times of Condition D not met, the diesel driven CL pumps may be incapable of performing their intended function and must be immediately declared inoperable.

r

--- ---- I I R-11 I L

I I PA3.7-159]

SURVEILLANCE REQUIREMENTS SR 3.7.8.1 This SR is modified by a Note indicating that the isolation of the CL SystemSW-S components or systems may render those components inoperable, but does not affect the OPERABILITY of the CL System&WS.

This SR verifiesVeri-ying the correct alignment for manual, power operated, and automatic valves in the CL SystemS&WS flow path topiavrevides assurftee that the proper flow paths exist for CL Systemt&W operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured.

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

PA3.7-272 Control room indication may be used to fulfill this SR.

(continued)

Markup for PI ITS Part E I

WOG STS Rev 1, 04/07/95 B 3.7.8-13

CL SystemS+6 B 3.7.8 IPA3.7-146 I PA3.7-201 BASES This SR does not apply to valves that cannot be CL3.7-151I inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.8.2 This SR verifies each diesel driven CL pump can be started and be up to operating speed and assumes load within one minute to provide assurance that equipment would perform as expected in the safety analysis.

Diesel CL pump start will normally be initiated by the manual start switch. Once per calendar year, start should be initiated by use of the low pressure header pressure switch.

The 31 day Frequency is based on the experience that the CL pump usually passes the Surveillance when performed at this Frequency.

SR 3.7.8.3 This SR provides verification that there is an IP adequate inventory of fuel oil in the storage tanks to support the operation of one diesel driven CL pump for 14 days.

The 14 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

A3.7-159 The specified fuel oil inventory for the diesel cooling water pumps is in addition to the fuel CL3.7160 oil inventory specified for the Unit 1 emergency diesel generators (EDGs)

(LCO 3.8.3) that must be available in the Unit 1 diesel fuel oil storage system.

There are four Design Class I fuel oil storage tanks for the Unit 1 EDGs and two Design Class I fuel oil storage tanks for the r-diesel driven cooling water pumps.

These six Design Class 1R L(

n (continued)

-8 1

i Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-14

CL SystemSW-S B 3.7.8 PA3.7-146 PA3.7-201 BASES I tanks are interconnected such that any tank can be manually aligned to supply any Unit 1 EDG or diesel driven cooling water pump day tank.

Any combination of inventory in these six tanks may be used to satisfy the inventory requirements for the diesel driven cooling water pumps and the Unit 1 EDGs.

Since the fuel oil for the CL pumps comes from the common fuel oil tanks shared by the Unit 1 diesel generators, the testing and the quality of the fuel oil is controlled by Technical Specification 5.5.11, "Diesel Fuel Oil Testing Program."

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and plant operators would be aware of any large uses of fuel oil during this period.

I I

R-11,

L I

SR 3.7.8.4 This SR verifies the vertical motor driven CL pump is OPERABLE to provide assurance that equipment, when lined up in the safeguards CL3.7-151l mode, will perform as expected in the safety analysis.

For this test, an acceptable level of performance shall be:

a.

Pump starts and reaches required developed head; and

b.

Control board indications and visual observations indicate that the pump is operating properly for at least 15 minutes.

The 92 day Frequency is based on the Inservice Testing Program requirements (Ref. 3).

Under some plant conditions, the vertical motor driven CL pump is required to operate to provide additional CL flow.

When this CL3.7-151 pump is operated to support plant operations, this test can not be performed and this pump is considered inoperable as a safeguards CL pump.

SR 3.7.8.5 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-15

CL System&WS B 3.7.8 SPA3.7-1467I PA3.7-201 BASES This SR verifies proper automatic operation of the CL SystemSWS valves on an actual or simulated safety injection actuation CL3.7-282 signal, including those valves that isolate non-essential equi-pment from the system.

The CL SystemSW5 is a normally operating system that is shared between the two units and cannot be fully actuated as part of normal testing.

This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

These tests demonstrate the operation of the valves, pump circuit breakers, and automatic circuitry.

CL3.7-282 Unit 1 SI actuation circuits for Train A and Train B valves shall be tested during Unit I refueling outages.

Unit 2 SI actuation circuits for Train A and Train B valves shall be tested during Unit 2 refueling outages.

A test is considered satisfactory if control board indication and visual observations indicate that all components have operated satisfactorily and if cooling water flow paths required for accident mitigation have been established.

The 24-fIB]- month Frequency is based on the need to perform CL3.7-116I this Surveillance under the conditions that apply during an outage of one unit (the other unit may be operating) and

......I the potential for an unplanned transient in the unit affected by the R-2 tested components if the Surveillance were performed with that t-h-Le...

reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequeney. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.8.6 The safeguards CL pumps may be actuated by either a safety injection (SI) signal or system low pressure.

This SR verifies proper automatic operation of the diesel driven and vertical motor driven CL&W-S pumps on an actual or simulated safety injection actuation signal and verifies proper automatic operation of these pumps on an actual or simulated CL3.7-153 CL3.7-283 CL3.7-2821 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-16

CL SystemSWS B 3.7.8 PA3.7-1461I PA3.7-201 BASES low pressure actuation signal.

The CLSWIS is a normally operating system that cannot be fully actuated in a safeguards mode as part.Qf normal testing during normal operation.

A test is considered satisfactory if control board indication and visual observations indicate that all components have operated satisfactorily.

The 24{l--8 month Frequency is based on the need to perform the SI signal portion of this Surveillance under the conditions that apply during a unit Sr 3.7.8.3

(

-ontinued)

CL3.7-1161[

I I

1R-2 I

I L-.

outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month

,requen*,.

Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES

1.

UFSAR, Section 10.4E9-2-.*1].

2.

UFSAR, Section 6{6--2]-.

3.

FSAR, Se-tion [5.4.7r.ASME Boiler and Pressure Vessel Code,Section XI.

(conti nued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.8-17

I PA3.7-201 I Emergency CL SupplyUl4S B 3.7.9 CL3.7-154 BASES (continued) should not fall below [562 ft mfean sea level] during normfal unit operation.

Both safeguards traveling screens are required to be OPERABLE.

A safeguards traveling screen isl CL3.7-287 considered OPERABLE when:

a.

The valve,instrumentation and controls required to provide the screen backwash function are OPERABLE; and

b.

The safeguards traveling screen can turn.

Safeguards traveling screen OPERABILITY is not required for OPERABILITY of the safeguards CL pumps (LCO 3.7.8)

The Emergency CL Line is OPERABLE when a flow path through the pipe exists.

APPLICABILITY With either unit i-n MODES 1, 2, 3, and 4, the Ui+SSafeguards Traveling Screens and Emergency CL Line are4s--required to support the OPERABILITY of the equipment serviced by the CL System during the design basis conditionU4-S and required to be OPERABLE in these MODES.

With both units i-I-n MODE 5 or 6, the OPERABILITY requirements of the Emergency CL SupplyUHIS-are determined by the systems it supports. The design basis does not include shutdown conditions.

ACTIONS r ---.

I I R-11 I I

I (conti nued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.9-5

PA3.7-201 ICL3.7-154 Emergency CL SupplyWIfS B 3.7.9 BASES (continued)

A.1 and A.2 If one safeguards traveling screen is inoperable, action must be taken to verify an emergency bay sluice gate is open within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and restore that safeguards traveling screen to OPERABLE status within 90 days.

I I

IR-11 1 L -.

I ScL3.7-156 1 In this Condition, the remaining OPERABLE safeguards traveling screen or open emergency bay sluice gate is adequate to provide the CL supply to any of the three vertical CL pumps during any design basis condition.

Required Action A.1 is modified by a Note which states the action is not required during testing periods of less than or equal to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is based on the redundant capability afforded by the OPERABLE safeguards screen.

The 90 day Completion Time is based on:

a.

The redundant capability afforded by the remaining OPERABLE safeguards traveling screen;

b.

The low risk impact of traveling screen; and

c.

The low probability of that could destroy Dam interval.

an inoperable safeguards a high magnitude earthquake No.

3 during this time (continued)

Markup for PI ITS Part E traveling r --- I ---

I R-111I LI--

WOG STS Rev 1, 04/07/95 B 3.7.9-6

Emergency CL SupplybllS PA3.7-201I B 3.7.9 CL3.7-154 BASES (continued)

ACTIONS B.1 and B.2 If both safeguards traveling screens are inoperable, action must be taken to verify one CL3.7156 emergency bay sluice gate is open within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and restore one safeguards traveling screen to OPERABLE status within 7 days.

In this Condition, the open emergency bay sluice gate is adequate to perform the CL supply function except in those cases where use of the Emergency CL Line is needed. As a result, overall reliability is reduced.

The 7 day Completion Time is based on the low probability of a design basis earthquake occurring during this time interval.

ACTIONS AC.1 and C.2 If the Emergency CL Line isone or more cooling CL3.7457 towers have one fan inoperable -(i.e., up topC37-5 one fan per cooling tower inoperable), action must be taken to verify one emergency bay sluice gate is open within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and restore the inoperable cooling tower fan(s) Emergency CL Line to OPERABLE status within 7 days.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and 7 day Completion Times arets reasonable based on the low probability of an-aee-dentia design basis earthquake occurring during the 7 days that the Emergency CL Lineone cooling tower fan is inoperable (in one or more ecoling towers), the number of available availability through the normal operating path and associated traveling screenssystem&,

and the time required to reasonably complete the Required Actions.

r------

R-11 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.9-7

CRSVSCREFS B 3.7.10 IPA3.7-162 PA3"7-201 1

BASES in both trains.

associated:

A -REF-SCRSVS train is OPERABLE when the

a.

Cleanup fFan is OPERABLE;

b.

HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; errd

_______________IcL3".7-298 I

C.

"eater, demister, Dductwork, valves, and dampers are OPERABLE, and air circulation can be maintained; and-

d. Instrumentation, including associated radiation monitor for starting the cleanup fan, is OPERABLE, PA3.7-296 or the system is aligned to perform its safety function and is operating.

In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

IPA3".7-297I Opening a door for personnel ingress or egress does not make the control room ventilation zone boundary inoperable.

Blocking a door open (e.g., for maintenance) without a person present to close the door requires entry into an ACTION.

ITA3.7-354 I

The LCO is modified by a Note allowing the control room boundary to be opened intermittently under administrative controls.

For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the (continued)

Markup for PI ITS Part E r ------ "i I R-11 I I

I L

WOG STS Rev 1, 04/07/95 B 3.7.10-5

CRSVS-REFS B 3.7.10 JPA3.7-162 PA3"7-201 BASES control room.

This individual will have a method to rapidly close the opening when a need for control room isolation is indicated.

APPLICABILITY In MODES 1, 2, 3, and 4 for either unit, E5, and 6 and during movement of irradiated fuel asemblies [n duri-ng CORErALTERATIONIS],,GREF-&CRSVS must be OPERABLE to control operator exposure during and following a DBA.

1 R-11 1 I

cL3.7-164 IA3.7-165 In [MODE 5 or 6], the CR[FS is required to

.pe with therelease from the rupture of an outside waste gas CL3 7164 In addition, dguring movement of irradiated fuel assemblies [and CORE ALTERATION',

the iREFSCRSVS must TA3.7-165 be OPERABLE to cope with the release from a fuel handling accident.

A.1 When one -REfSCRSVS train is inoperable, action must be taken to restore OPERABLE status within 7 days.

r

...- -- I R-11 !

I I

In this Condition, the remaining OPERABLE

-REFSCRSVS train is adequate to perform the control room protection function.

However, the overall redundancyreliability is reduced because only a single CRSVS train remainsfailure in the OPERABLE CREFS train could result in loss of rREFS functiont.

The 7 day Completion Time is based on the low probability of a DBA or fuel handling accident occurring during this time period, and ability of the remaining train to provide the required capability.

JCL3.7-301 I

(conti nued)

Markup for PI ITS Part E ACTIONS WOG STS Rev 1, 04/07/95 B 3.7.10-6

CRSVSCGREF-S B 3.7.10 JPA3.7-162 PA37-201 1

BASES B.1 ITA3.7-354 I

If the control room boundary is inoperable in MODES 1, 2, 3,

and 4, the CRSVS train cannot perform their intended functions.

Actions must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the period that the control room boundary is inoperable, appropriate compensatory measures should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security.

Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition.

The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.

BC.1 and BC.2 ITA3.7-354 In MODE 1, 2, 3, or 4, if the inoperable -REF-SCRSVS train or control room boundary cannot be restored to OPERABLE r------

status within the required Completion Time, thre-both units 1 R-11 must be placed in a MODE that minimizes accident risk.

To L ------ J achieve this status, the units must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.10-7

CRSVSCREFS B 3.7.10 IPA3.7-162 PA3*7-201 BASES

£D.I,

.-2.1,- and GD.2-.--

in MODE 5 or 6, or] during movement of irradiated fuel assemblies E, or d,,,urn CORE FE,,*,*,,&J-,-+If the inoperable -REF-SCRSVS train cannot be restored to ITA3.7 OPERABLE status within the required Completion Time, Required A-ction D.1 must be taken to immediately place the OPERABLE GREFSCRSVS train in the emergency mode.

This is a reasonable action, based on engineering R

judgement, to assure the control room air is filtered L__

in the event of an accident.

This actioe,,

,ustht PA3.

the remaining train is OPERABLE, that no falilures preventing automatic actuation will occur, and that any active failure would be readily detected.

-iI

-165

-1130 7-302 An alternative to Required Action

£D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room.

Required Action £-D.2 Th-i-s--places the t i-plant in a condition that minimizes risk.

This does not

!R-11 preclude the movement of fuel to a safe position.

L ------ J Required Action C.1 is modified by a Note indicatilng to place the system in the toxic gas protection mfode ifFCL3.7-166 automatic transfer to toxic gas protection mode is i noerab! e-.-

9E.1-a,,u--"-D.2

in MODE 5 or 6, or] If two CRSVS trains are inoperable during movement of irradiated fuel assemblies E,

o itnperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room.

r---[L-I R-11 I

. J ITA.7I6 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7. 10-8

CRSVSCREFS B 3.7.10 IPA3.7-162 IPA3.7-201 BASES This places the tni-t--plant in a condition that minimizes accident risk.

This does not preclude the movement of fuel to a safe position.

EF.1 ITA3.7-354 If both CREFSCRSVS trains are inoperable in MODE 1, 2, 3,

or 4, for reasons other than inoperable control room boundary (i.e., Condition B) the CREFSCRSVS may not be capable of performing the intended function and the unit i R-11 is in a condition outside the accident analyses.

L.......

Therefore, LCO 3.0.3 must be entered immediately for both units.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly.

As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system.

Monthly heater operations dr out any mfoisture accumulated in the charcoal fromn humnidity in the ambient air.

[Systems with heaters must be operated for t10 continuous hours with the heaters energized.

Each trainSyst-t-em must be operated without heaters need

,CL3.7-167 only be operated for > 15 minutes to demonstrate the I I

system functions of the system.+/-

The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

SR 3.7.10.2 This SR verifies that the required

-REF-SCRSVS filter testing is performed in accordance with the IPA3.7-303

-Ventilation Filter Testing Program (VFTP)+.

The-GREF filter tests are in accordance with Regulatory Guide 1.52 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.10-9

CRSVSCREF-S B 3.7.10 LPA3.7-162 IPA3.7-201 I

(Ref. 3). -The

-VFTP-includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal.

Specific test Frequencies and additional information are discussed in detail in the {VFTP+/-.

SR 3.7.10.3 The CRSVS may be actuated by either a safety injection signal or a high radiation signal.

This SR verifies ICL3.7-292 that each CREF-SCRSVS train starts and operates on an actual or simulated safety injection actuation signal and verifies each CRSVS train starts and operates on and actual or simulated high radiation signal.

The Frequency of JX3.7-137 24 f-[1 months allows performance when a unit is shutdownis specified in Regulatory Guide 1.52 (Ref. 3).

SR 3.7.10.4 This SR verifies the integrity of the ontrl rm enelosure, and the assumed inleakage rates of the ICL3.7-168 potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the GREF-&CRSVS.

During the emergency mode of operation, the CREF-SCRSVS train is designed to provide 4000

+ 10% cfm pres....ize the control raoom t [0. 125] ince water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage.

The-GREF-S--i-S designed to maintain this positive pressure with one train at a mfakeup flow rate of [3000] cfmn.

The Frequency of 24-E-8 months on a STAGGERED TEST BASIS is consistent with the guidance provided NUR[G 0800 (Ref. 4)industry component reliability experience.

LX3.7-137 ICL3.7-304 Markup for PI ITS Part E BASES WOG STS Rev 1, 04/07/95 B 3.7.10-10

CRSVSC-REF-S B 3.7.10 LPA3.7-162 IPA3.7-201 1

BASES REFERENCES

1.

UFSAR, Section 10.3{f--;4-.

2.

UFSAR, SectionChapteit 14.9f-.-5+.

3.

10 CFR 50 Appendix A, GDC Criterion 19Reg-la-*-ry Guide 1.52, Rev. 2.

4.

NUR[G 0800, Seti'n 6.4, Rev. 2, July 1981.

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.10-11

SCWSCREAT-S B 3.7.11 BASES (continued)

APPLICABILITY ACTIONS In MODES 1, 2, 3, and 4,

,rE5, and &,+ and during TA3 movement of irradiated fuel assemblies rand-durin, I

CORE ALTERAT-IONGS], the SCWSGREATG, must be OPERABLE to ensure that the een+r&, room temperatures will not exceed equipment operational requirements in the essential areas this system serves following an accidenti-s"elatina*

the eontrol room I P.

In MODES 5 and 6, the OPERABILITY requirements of the SCWS are determined by the systems it supports.

[In MODE 5 or 6j] CREATCS may not be required for these facilities that do not rcquire automatic ntEro*l room isolati*

n.-

A.1 With one SCWSREATCS trn loop inoperable, action must be taken to restore OPERABLE status within 30 days.

3.7-171 r....

L--I R-11 L -------

In this Condition, the remaining OPERABLE SCWSCR[ATC-S trai loop is adequate to maintain the

,,ntrol room temperature within limits provide cooling. However, the overall reliability is reduced because a single failure in the OPERABLE SCWS loopGREATe*S-+,tr n could result in loss of SCWSCREATC, function.

The 30 day Completion Time is based on the low probability of an event requiring SCWS loop separationcontrol room isolation, the consideration that the remaining loopt-rai-n-can provide the required protection, and that alternate safety or nonsafety related cooling means are available.

(continued)

Markup for PI ITS Part E SP37-1691J PA3.7-201 I

.7-165I WOG STS Rev 1, 04/07/95 B 3.7.11-4

SCWSCREA**S i-169 j372O1 B 3.7.11 BASE S ACTIONS (continued)

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable SCWSCREATCS train loop cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the risk.

To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

PA3.7-169 r - -- -- -.

I I

IR-11 I L -

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1,-C.-2-.1 and C.2.--Z i*,-MODE-,

5 -or 6,

,i^--dDuring movement of irradiated PA3 fuel

,orduring

,CORE ALTERATONS], if the inoperable I

SCWS CREATS tran loop cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE SCWSCREATGS train loop must be placed in operation immediately. This action ensures that the required cooling function is providedremaining train is OP[RABL[, that no failures preventing autematie actuation will occur, and that An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room.

Required Action C.2TH-hs places the unit in a condition that minimizes accident risk.

This does not R

preclude the movement of fuel to a safe position.

L__

(continued)

Markup for PI ITS Part E

-k--1

-111 1.7-1691I WOG STS Rev 1, 04/07/95 B 3.7.11-5

IPA3.7-172 II PA3.2o1 I ABSVSEGGS-*PREAG B 3.7.12 failure disables the other train coincident, with loss of offsite power.

This OPERABILITY requirement ensures that Teta4-sys failur*,

ould rcsult in the atmospheric releases,in

[jC the event of a Design Basis Accident (DBA) in containment, from 4Te-EccS pump rooemleakage and contaiment leakage which bypasses the shield building would not result in doses exceeding 10 CFR 100 limits (Ref. 5) in the ev of a Design Basis Accident (DBA).

EGGS PREACS is considered OPERABLE when the individual eomponents necessary to maintain the EGG pump room filtration are OPERABLE in both-C3 7-322 traints.

In order for the ABSVS to be OPERABLE, the Turbine Building roof exhauster fans must be capable of being de-energized within 30 minutes following a loss of coolant accident.

An ABSVSECCS-PREACS train is considered OPERABLE when its associated:

LCO (continued)

a.

Fan is OPERABLE;

b.

HEPA filter design flow and and charcoal adsorbers are not excessively flew,-and are capable of passing their and performing their filtration functions;

c.

Heater, demi-s-ter--, ductwork, v'a-l-ves-;-, and dampers are OPERABLE and air circulation can be maintained.

The ABSV boundary is OPERABLE if both of the following 7-14]

conditions can be met:

L3 J

(continued)

Markup for PI ITS Part E BASES

-321 1

I R-11 I L ------

WOG STS Rev 1, 04/07/95 B 3.7.12-4

PA3"7-1721 PA3.7-201 ABSVSEGGS PREAG, B 3.7.12 BASES

a.

Openings in the ABSV boundary are under direct administrative control and can be reduced to less than 10 square feet within 6 minutes following an accident; and

b.

Dampers and actuation circuits that isolate CL3.7-174 the Auxiliary Building Normal Ventilation System following an accident are OPERABLE or can be manually isolated within 6 minutes following an accident.

The LCO is modified by a Note allowing the ABSV boundary to be opened under administrative controls.

As discussed above, openings must be closed to less than 10 square feet within 6 minutes following CL3.

an accident.

r-------J APPLICABILITY In MODES 1, 2, 3, and 4 for either unit, the ABSVSE-C PREAGS is required to be OPERABLE consistent with the OPERABILITY requirements of the EGGS.

3.7-323 When both units are i4-n MODE 5 or 6, the ABSVSEGGS PREAC& is not required to be OPERABLE since the EGGS is not required to be OPERABLE.

A.1 With one ABSVSECCS PREACS train inoperable, action must be taken to restore OPERABLE status within 7 days. During this time, the remaining OPERABLE train is adequate to perform the ABSVSECC& P-RAGS. function.

The 7 day Completion Time is appropriate because the ABSVS risk contribution is substantially less than PA3.7-323 (continued)

Markup for PI ITS Part E ACTIONS I

r ------ "I I

I I R-11I L------ J 7-174 WOG STS Rev 1, 04/07/95 B 3.7.12-5

PA3.7-172I PA37 2o1 ABSVSEGe

,,REAGS B 3.7.12 BASES that for the ECCS (72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time),

and this system.

is not a direet support system for the The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

Concurrent failure of two ABSVSEGCS PREAG-S trains would result in the loss of functional capability; therefore, LCO 3.0.3 must be entered immediately.

B.1 With both ABSVS trains inoperable due to an inoperable CL3.-174 ABSV boundary, action must be taken to restore OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the availability of the ABSVS to provide a filtered release (albeit with potential for some unfiltered leakage).

If the ABSV boundary cannot be restored to within the associated Completion Time, the placed in a MODE in which the LCO does not OPERABLE status unit must be

[

apply.

R1 L R-11.

L ------ i (conti nued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.7.12-6

PA3.7-172I PA3.7_2o ABSVSE*

PREAGS B 3.7.12 C8.1 and C8.2 If anthe ABSVSEGC

,PREAES train cannot be restored to CL OPERABLE status or the ABSV boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply.

To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE REQUIREMENTS SR 3.7.12.1 This SR verifies that each ABSVS train can be manually started, the associated filter heater energizes, and the filter units remain sufficiently dried out to ensure they can perform their function.I circulation IPA3.7-324 Standby systems should be checked periodically to ensure that they function properly.

As the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system. Monthly heater operations, with air through the filter, driesy out any moisture that may FC3 7_

I have accumulated in the charcoal from humidity in LIJ the ambient air.

[Zyst'ms with h'aters Each ABSVS train must be operated ; 10 continuous hours per (continued)

Markup for PI ITS Part E BASES 3.7-174 1 I R-1i1 L ------

J 4AE WOG STS Rev 1, 04/07/95 R 3.7.12-7

PART F PACKAGE 3.7 PLANT SYSTEMS JUSTIFICATION FOR DIFFERENCES FROM IMPROVED STANDARD TECHNICAL SPECIFICATIONS (NUREG-1431) AND BASES See Part E for specific proposed wording and location of referenced deviations.

Difference Difference Justification for Differences Category Number 3.7 CL 111 CTS requires PI to have all MSSVs operable or the unit is required to shut down. PI has revised the associate Required Action to allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for one MSSV to be inoperable until initiation of a unit shutdown is initiated.

The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable due to the low probability of an event occurring during this time requiring MSSV operation. TSTF - 235, which mostly deals with graduated plant power levels associated with inoperable MSSVs, has generally not been incorporated in this Specification and Bases. However, the statement of the LCO has been revised to be consistent with TSTF - 235 since this is an improvement which applies without the provisions for graduated power levels.

CL 112 Since PI intends to require all MSSV to be operable, it is unacceptable to allow more than one MSSVs to be inoperable at any given time and keep the plant operating. Therefore, use of Separate Condition entry is not appropriate and has not been included in the PI ITS.

Prairie Island Units 1 and 2 1

2/2/02

Package 3.7 Difference Difference Category Number 3.7-Justification for Differences 113 Not used.

114 PA CL CL TA Since PI only has two MSIV, the affected portions of Specification 3.7.2 have been revised accordingly.

115 The Applicability modifier "de-activated" is not included since CTS requirements do not apply in MODE 3 when both MSIVs are closed. They are not required to be de activated, since they can not be re-opened without manually opening the bypass valve.

116 The CTS requirement for this surveillance requires the test to be performed each refueling cycle. Since Prairie Island intends to extend the plant refueling cycle up to 24 months, this Frequency is also extended to 24 months.

117 SR 3.7.2.1 and SR 3.7.3.1 are revised to separate the closure time testing and the actuation signal testing into separate surveillances. These changes incorporate TSTF-289.

Prairie Island Units 1 and 2 2/2/02 Part F 2

Package 3.7 Difference Difference Category Number 3.7-Justification for Differences 126 Not used.

PA CL CL 127 PI has two trains of AFW for each unit. Therefore, this specification is written to require two AFW trains.

128 This change adds a Note to the LCO and Bases which will allow the system to operate and still be considered OPERABLE for safety related requirements. PI requires this Note to incorporate NRC TS interpretation issued to NSP October 16, 1997. Since PI has only two trains of AFW per unit and the AFW system is required to operate as part of normal plant startup and shutdown, this change is required. This change is consistent with TSTF-245, Revision 1 (See TA3.7-136).

129 CTS only requires the AFW system to be operable in MODES 1,2, and 3; therefore the applicability requirements for MODE 4 are not included. Also, the related clause for Condition B and all of Condition E have been deleted.

Prairie Island Units 1 and 2 2/2/02 Part F 6

Part F Package 3.7 Difference Difference Category Number 3.7-x Justification for Differences 130 This ITS conversion LAR proposes to require testing of the SG PORV at the interval specified in the IST Program. The IST Program, which is approved by the NRC, currently requires the SG PORV to be tested quarterly. A change in this interval would be reviewed and approved by the NRC. This interval is more frequent than the bracketed 18 month interval in NUREG-1431.

This change is also discussed in DOC L3.7-95.

131 Prairie Island Units I and 2 Not used.

2/2/02 Package 3.7 Part F 7

Package 3.7 Difference Difference Category Number 3.7-Justification for Differences 141 PI has three condensate storage tanks which are interconnected to commonly serve both PI units. Thus, these tanks form a system which is shared between PI Units 1 and 2. Therefore, an "s" has been added to "CST" in the title and Condition A to show it is the system of tanks, not just one tank, that is under consideration.

CL TA CL This change incorporates approved traveler, TSTF-140 which requires the CSTs to be operable rather than specifying tank contents.

143 CTS requires CSTs operable when either unit is in MODE 1, 2, or 3. Therefore, MODE 4 operability requirements are not included in the PI CTS. This is acceptable since in MODE 4, the pressure and temperature limitation are such that the probability for a design basis event requiring plant cool down using SG PORVs is low. Also, in MODE 4 the RHR system is available to provide adequate decay heat removal. The associated Bases have also been modified to be consistent with these changes.

Prairie Island Units 1 and 2 2/2/02 Part F 142 10

Package 3.7 Difference Difference Category Number 3.7-Justification for Differences 149 Not used.

150 This change incorporates TSTF - 340, Revision 3.

Modification of the Bases inserts have been made to reflect the PI AFW system design features.

TA CL 151 Prairie Island Units I and 2 Two SRs and associated Bases, which are not provided in NUREG-1431, are included to incorporate CTS requirements for testing CL pump operability. Since these pumps may not be normally operating, operability testing is required.

2/2/02 Part F 13

Package 3.7 Difference Difference Category Number 3.7-Justification for Differences 155 Not used.

CL CL 156 New Action Statements A and B are included to incorporate CTS requirements for the safeguards traveling screens. These requirements are the same as CTS except for changes required to conform to the ISTS format (such changes were addressed in Part D, Discussion of Changes to CTS). Associated Bases have also been provided.

157 Prairie Island Units 1 and 2 The Action Statements and associated Required Actions and Completion Times have been modified to incorporate CTS requirements to assure that at least one emergency bay sluice gate is open. These requirements are the same as CTS except for changes required to conform to the ISTS format (such changes were addressed in Part D, Discussion of Changes to CTS, for this Section). Associated Bases have also been provided.

2/2/02 Part F 15

Package 3.7 Difference Difference Category Number 3.7-PA Justification for Differences 162 The system which provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity at P1 is called the Control Room Special Ventilation System (CRSVS).

Thus, this specification title, LCO, affected Action Statements, SRs and associated Bases have been revised to incorporate this change.

163 Not used.

CL 164 Bracketed MODES 5 and 6 are not included in the Applicability, affected Action Statements and Bases. As stated in the ISTS Bases for this specification, these MODES are applicable when the plant has external waste gas storage tanks which could rupture. Since P1 does not have external waste gas storage tanks, these MODES are not applicable.

Prairie Island Units 1 and 2 2/2/02 Part F 17

Part F Package 3.7 Difference Difference Category Number 3.7-PA PA 171 172 Justification for Differences The SCWS at PI is a shared system which supports the operation of both units. Since this system supports the CRSVS which is not required to be operable in MODES 5 and 6, the SCWS is likewise not required to be operable in MODES 5 and 6.

The PI Auxiliary Building Special Ventilation System (ABSVS) is the system which most closely resembles the Emergency Core Cooling System Pump Room Exhaust Air Cleanup System. Therefore, the name of this specification has been revised to ABSVS in the title, LCO, affected Action Statements, SRs and throughout the associated Bases.

173 Not used.

Prairie Island Units 1 and 2 2/2/02 Part F Package 3.7 20

Part F Package 3.7 Difference Difference Justification for Differences Category Number 3.7 CL 346 PI has two different designs of stored spent fuel which require two separate figures in Specification 3.7.17.

Thus, this discussion is modified to identify the two types of spent fuel and reference the PI specific figures.

CL 347 The Bases ASA discussion has been replaced with discussion derived from the CTS Bases. This discussion differs from NUREG-1431 since PI has been licensed to credit the soluble boron in the spent fuel pool.

PA 348 Specification 3.7.8 Required Actions A.land B.2 have been modified by the addition of the clause, "10 days from discovery of failure to meet the LCO". Similarly, required Action D.1 has been modified by the addition of the clause, "9 days from discovery of failure to meet the LCO". These additions are necessary because of the unique requirements of the Prairie Island Cooling Water specification requirements and to make the Completion Times consistent with similar ISTS Completion Time requirements. The associated Bases have also been revised to explain these additional allowed outage time limitations.

349 Not used.

350 Not used.

CL 351 The CTS also requires a minimum boron concentration when loading and unloading spent fuel storage casks.

For completeness, these activities are included in the Bases LCO discussion.

Prairie Island Units 1 and 2 49 2/2/02 Package 3.7 Part F

Package 3.7 Difference Difference Category Number 3.7-PA PA TA Justification for Differences 352 The Bases References have been changed to be consistent with the CTS references since most of the discussion in this Bases was derived from the CTS Bases.

353 ITS 3.7.4 Required Action B Completion Time and associated Bases have been revised from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The ISTS Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months was based on a 4 loop plant, whereas PI is a two loop plant. Due to only having two loops, PI cannot justify having both SG PORVs inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time allows time to plan an orderly shutdown of the unit. Even though the SG PORVs are inoperable for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the ADVs and MSIVs are still OPERABLE for decay heat removal as needed, in addition there would be a low probability of an event occurring during this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period that would require the SG PORVs to function. This Completion Time is consistent with CTS 3.0.C which allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate action a reactor shutdown.

354 Prairie Island Units 1 and 2 TSTF-287, Rev. 5 has been incorporated.

2/2/02 Part F 50

PART G PACKAGE 3.7 PLANT SYSTEMS NO SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL ASSESSMENT NO SIGNIFICANT HAZARDS DETERMINATION The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 1 OCFR Part 50, Section 50.91 using the standards provided in Section 50.92.

For ease of review, the changes are evaluated in groupings according to the type of change involved. A single generic evaluation may suffice for some of the changes while others may require specific evaluation in which case the appropriate reference change numbers are provided.

A - Administrative (GENERIC NSHD)

(A3.7-00, A3.7-01, A3.7-02, A3.7-04, A3.7-05, A3.7-06, A3.7-09, A3.7-20, A3.7-21, A3.7-34, A3.7-36, A3.7-44, A3.7-45, A3.7-47, A3.7-57, A3.7-62, A3.7-66, A3.7-74, A3.7 77, A3.7-78, A3.7-83, A3.7-94, A3.7-97, A3.7-105, A3.7-113)

Most administrative changes have not been marked-up in the Current Technical Specifications, and may not be specifically referenced to a discussion of change. This No Significant Hazards Determination (NSHD) may be referenced in a discussion of change by the prefix "A" if the change is not obviously an administrative change and requires an explanation.

These proposed changes are editorial in nature. They involve reformatting, renaming, renumbering, or rewording of existing Technical Specifications to provide consistency with NUREG-1431 or conformance with the Writer's Guide, or change of current plant terminology to conform to NUREG-1431. Some administrative changes involve relocation of requirements within the Technical Specifications without affecting their technical content. Clarifications within the new Prairie Island Improved Technical Specifications which do not impose new requirements on plant operation are also considered administrative.

Prairie Island Units 1 and 2 1

2/2/02

Part G Package 3.7 M - More restrictive (GENERIC NSHD)

(M3.7-08, M3.7-12, M3.7-13, M3.7-14, M3.7-15, M3.7-16, M3.7-23, M3.7-26, M3.7-27, M3.7-30, M3.7-35, M3.7-37, M3.7-39, M3.7-40, M3.7-42, M3.7-46, M3.7-48, M3.7-49, M3.7-51, M3.7-52, M3.7-53, M3.7-55, M3.7-58, M3.7-59, M3.7-60, M3.7-61, M3.7-65, M3.7-73, M3.7-75, M3.7-76, M3.7-104, M3.7-107, M3.7-108, M3.7-109, M3.7-110, M3.7-115, M3.7-116, M3.7-119)

This proposed Technical Specifications revision involves modifying the Current Technical Specifications to impose more stringent requirements upon plant operations to achieve consistency with the guidance of NUREG-1431, correct discrepancies or remove ambiguities from the specifications. These more restrictive Technical Specifications have been evaluated against the plant design, safety analyses, and other Technical Specifications requirements to ensure the plant will continue to operate safely with these more stringent specifications.

1. The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes provide more stringent requirements for operation of the plant. These more stringent requirements do not result in operation that will increase the probability of initiating an analyzed event and do not alter assumptions relative to mitigation of an accident or transient event.

These more restrictive requirements continue to ensure process variables, structures, systems, and components are maintained consistent with the safety analyses and licensing basis. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed changes do not involve a physical alteration of the plant, that is, no new or different type of equipment will be installed, nor do they change the methods governing normal plant operation.

These more stringent requirements do impose different operating restrictions.

However, these operating restrictions are consistent with the boundaries established by the assumptions made in the plant safety analyses and licensing bases. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Prairie Island Units 1 and 2 3

2/2/02

Part G Package 3.7 R - Relocation (GENERIC NSHD)

(R3.7-32, R3.7-69, R3.7-79, R3.7-81, R3.7-106)

This License Amendment Request (LAR) proposes to relocate requirements contained in the Current Technical Specifications out of the Technical Specifications into licensee controlled programs. These requirements are relocated because they 1) do not meet the Technical Specifications selection criteria defined in 10 CFR 50.36; or 2) are mandated by current Nuclear Regulatory Commission (NRC) regulations and are therefore unnecessary in the Technical Specifications.

In the NRC Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (dated 7/16/93), the NRC stated:

.. since 1969, there has been a trend towards including in Technical Specifications not only those requirements derived from the analyses and evaluations included in the safety analysis report but also essentially all other Commission requirements governing the operation of nuclear power reactors....

This has contributed to the volume of Technical Specifications and to the several fold increase, since 1969, in the number of license amendment applications to effect changes to the Technical Specifications. It has diverted both staff and licensee attention from the more important requirements in these documents to the extent that it has resulted in an adverse but unquantifiable impact on safety.

Thus, relocation of unnecessary requirements from the Current Technical Specifications should result in an overall improvement in plant safety through more focused attention to the requirements that are most important to plant safety.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

These proposed changes relocate requirements for structures, systems, components or variables which did not meet the criteria for inclusion in the improved Technical Specifications, or which duplicate regulatory requirements. The affected structures, systems, components or variables are not assumed to be initiators of analyzed events and are not assumed to mitigate accident or transient events.

Prairie Island Units 1 and 2 5

2/2/02

Part G Package 3.7 LR - Less restrictive, Relocated details (GENERIC NSHD)

(LR3.7-17, LR3.7-18, LR3.7-19, LR3.7-24, LR3.7-28, LR3.7-29, LR3.7-38, LR3.7-41, LR3.7-43, LR3.7-63, LR3.7-64, LR3.7-67, LR3.7-68, LR3.7-82, LR3.7-84, LR3.7-86, LR3.7-87, LR3.7-98, LR3.7-99, LR3.7-100, LR3.7-102, LR3.7-112)

Some information in the Prairie Island Current Technical Specifications that is descriptive in nature regarding the equipment, system(s), actions or surveillances identified by the specification has been removed from the proposed specification and relocated to the proposed Bases, Updated Safety Analysis Report or licensee controlled procedures. The relocation of this descriptive information to the Bases of the Improved Technical Specifications, Updated Safety Analysis Report or licensee controlled procedures is acceptable because these documents will be controlled by the Improved Technical Specifications required programs, procedures or 10CFR50.59. Therefore, the descriptive information that has been moved continues to be maintained in an appropriately controlled manner.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes relocate detailed, descriptive requirements from the Technical Specifications to the Bases, Updated Safety Analysis Report or licensee controlled procedures. These documents containing the relocated requirements will be maintained under the provisions of IOCFR50.59, a program or procedure based on 1 OCFR50.59 evaluation of changes, or NRC approved methodologies. Since these documents to which the Technical Specifications requirements have been relocated are evaluated under 10CFR50.59 or its guidance, or in accordance with NRC approved methodologies, no increase in the probability or consequences of an accident previously evaluated will be allowed without prior NRC approval.

Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Prairie Island Units 1 and 2 7

2/2/02

Part G Package 3.7 L - Less restrictive, Specific Each CTS change which is designated as Less (L prefix) restrictive on plant operations is provided with a specific NSHD.

Specific NSHD for Change L3.7-03 CTS does not provide an action statement addressing inoperability of one or more MSSVs; therefore the unit would be required to enter CTS 3.0.0 if a MSSV were inoperable. CTS 3.0.C allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to implement corrective action whereas this change proposes to allow four hours to implement corrective action. This change is acceptable because the probability is very low that a pressure transient will occur during this additional three hours; the SG PORVs will initially address a main steam pressure transient so the probability the MSSVs will be required to operate during this additional three hours is even lower. Furthermore, there are four other MSSVs, which service the SG being affected, which further reduces the likelihood that any particular MSSV will be required at any time. This change is consistent with the approved GITS.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change involves extending the time allowed for one MSSV to be inoperable while corrective actions are implemented. Since MSSV design or Function has not changed, this change does not affect the probability of an accident. There are other system design features, such as the SG PORVs, which provide for pressure transient protection. In addition, the probability of an event, which requires any particular MSSV to operate is very low. Therefore this change does not involve a significant increase in the probability or consequences of an accident.

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident.

Prairie Island Units 1 and 2 9

2/2/02

Part G Package 3.7 Specific NSHD for Change L3.7-03 (continued)

3.

The proposed amendment will not involve a significant reduction in the margin of safety.

The proposed change in effect extends the time for a MSSV to be inoperable while corrective actions are implemented from one hour to four hours. The probability of a plant transient during the three additional hours, which would require the inoperable MSSV to operate, is very low. The additional three hours allows the plant to attempt to make repairs and prepare for a well, planned shutdown. The process of shutting down the plant is more likely to cause a transient requiring the MSSVs than continued plant operation. Furthermore, there are other plant design features, such as the SG PORVs and Steam Dumps, to mitigate steam line pressure transients. Thus, this change does not involve a significant reduction in the margin of safety.

Therefore it is concluded this proposed change does not involve a significant hazards consideration.

Prairie Island Units 1 and 2 2/2/02 10

Part G Package 3.7 Specific NSHD for Change L3.7-07 CTS allow one SG PORV to be inoperable for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Since there are other means available to provide a heat sink for the SGs, it is acceptable to extend this outage time to 7 days. This change would also allow both SG PORVs to be inoperable for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This change is consistent with the guidance of NUREG-1431.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change involves extending the time allowed for one SG PORV to be inoperable and defines allowable outage time for both SG PORVs inoperable. Since the SG PORV design or Function has not changed, these changes do not affect the probability of an accident. There are other systems which provide a comparable SG heat sink such as the Steam Dumps to the condenser, Steam Dumps to the atmosphere and the Main Steam Safety Valves. Thus the unavailability of one SG PORV for up to 7 days or both SG PORVs up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months does not involve a significant increase in the consequences of an accident. Also the probability of an event requiring use of a SG PORV during these allowed outage times is low.

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed change makes the PI ITS consistent with the guidance of NUREG 1431 and does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident.

Prairie Island Units 1 and 2 11 2/2/02

Part G Package 3.7 Specific NSHD for Change L3.7-114 This change allows separate Condition entry when both MSIVs are inoperable while in Mode 2 or 3. This change is acceptable since the Required Actions assure that the safety function of the MSIVs continue to meet the PI safety analysis. This change is consistent with the guidance of NUREG-1431.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

This change will allow separate Condition entry for the MSIVs when the plant is in Mode 2 or 3. The Required Action require that an inoperable MSIV be closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verified closed once per 7 days. When in the closed position, the MSIV is performing its intended safety function. Since the MSIVs are not design basis accident initiators, this change does not involve an increase in the probability of an accident. Therefore, this change does not involve a significant increase in the consequences of an accident previously evaluated.

Since the Required Action requires the MSIV to be closed, it will be performing its intended safety function. Therefore, this proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change introduces no new mode of plant operation or changes in the methods governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Prairie Island Units 1 and 2 47 2/2/02

Part G Package 3.7 Specific NSHD for Change L3.7-114 (continued)

3.

The proposed amendment will not involve a significant reduction in the margin of safety.

The proposed change allows the plant to continue operating in Modes 2 or 3 with an inoperability in both MSIVs in conformance with the guidance of NUREG-1431.

Since a condition is not defined in the CTS for simultaneous inoperabilities of both MSIVs in these Modes, the plant would be required to enter LCO 3.0.C and shut down. Required Action C allows a MSIV to be closed in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verified closed once per 7 days. Since the MSIV would be closed, it would be performing its intended safety function. Therefore this change does not involve a significant reduction in the margin of safety.

Therefore it is concluded this proposed change does not involve a significant hazards consideration.

Prairie Island Units 1 and 2 2/2/02 48

Part G Package 3.7 Specific NSHD for Change L3.7-117 CTS 3.3.C.1 (b) requires that during STARTUP OPERATION or POWER OPERATION, "any one of" the following conditions of inoperability may exist provided startup operation is discontinued until OPERABILITY is restored. If OPERABILITY is not restored within the time specified, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

(1) One of the assigned component cooling pumps may be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

(2) One of the assigned component cooling heat exchangers may be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The CTS does not allow a component cooling pump and a cooling heat exchanger to be inoperable at the same time. The ITS allow an entire train to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . A train in this case is the component cooling pump and component cooling heat exchanger. Allowing both to be inoperable makes this a less restrictive change.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

This change eliminates the CTS requirement of having either a component cooling (CC) pump or CC heat exchanger inoperable at the same time whereas, the ITS allows having an entire CC train inoperable. The CC train, in the ITS, includes both the CC pump and CC heat exchanger. PI design is that the CC pumps are interconnected so that either pump from either unit can be manually aligned to serve any heat exchanger, and the capability of manually switching the pumps enables the two unit system to tolerate loss of an additional pump with one pump already out of service. The heat exchangers are not similarly interconnected, so loss or outage of a heat exchanger disables one set of essential equipment in one unit. Therefore, the ITS allowing a train to be inoperable allows either a CC pump or CC heat exchanger to be inoperable or both can be inoperable. Once the CC heat exchanger is lost, the entire train would be inoperable and therefore, requiring entry into Condition A. PI has been analyzed for the event where a failure disables an entire loop consisting a pump and heat exchanger, in the same train. In this case, the plant would have sufficient CC cooling to successfully and safely shut down the unit. For a LOCA, PI safety analysis shows that one CC pump and CC heat exchanger can accommodate the heat removal loads. Therefore, redefining the CTS requirements of allowing a CC train to be inoperable does not involve a significant increase in the consequences of an accident previously evaluated.

Since the CC system is not an assumed accident initiator in the PI USAR Safety Analysis, there is not a significant increase in the probability of an accident previously evaluated.

Prairie Island Units I and 2 49 92//02 I V

Part G Package 3.7 Specific NSHD for Change L3.7-117 (continued)

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change introduces no new mode of plant operation or changes in the methods governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

The proposed amendment will not involve a significant reduction in the margin of safety.

Allowing a CC train to be inoperable as allowed by the ITS supports PI safety analysis. PI is analyzed for losing a loop of CC during a LOCA and still ensuring plant safe shutdown as discussed in USAR 10.4.2.3. Therefore, the CTS change is consistent with NUREG-1431 and PI accident analysis. Therefore this change does not involve a significant reduction in the margin of safety.

Therefore it is concluded this proposed change does not involve a significant hazards consideration.

Prairie Island Units 1 and 2 2/2/02 50

Part G Package 3.7 Specific NSHD for Change L3.7-118 The proposed change would allow the control room boundary to be open with both trains of the CRSVS inoperable under administrative controls for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while the unit is in MODES 1, 2, 3, or 4. The CTS does not allow this flexibility.

1.

The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

This proposed change would allow the control room boundary to be opened with both trains of CRSVS inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months under administrative controls.

Requiring the plant to enter LCO 3.0.3 when the ventilation envelope is not intact is excessive and not appropriate. If the control room boundary is inoperable in MODES 1, 2, 3, and 4, the CRSVS trains cannot perform their intended functions.

Actions must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Preplanned measures would be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times is a typically reasonable time to diagnose, plan, and possibly repair, and test most problems with the control room boundary. Accident consequences are not significantly increased because any opening in the control room envelope (under this Specification) is under direct administrative controls, thus, the control room boundary integrity can be restored in the event of a DBA. This proposed change can only be applied to those areas where administrative control will not be precluded by the initiating event itself. For example, administrative control cannot be credited for an open door (required for steam exclusion) if the person(s) controlling the door would be precluded from restoring the control room boundary by a main steam line break. Therefore, allowing the control room boundary to be open with both trains of CRSVS to be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months under administrative controls does not involve a significant increase in the consequences of an accident previously evaluated.

Prairie Island Units 1 and 2 51 2/2/02

Part G Package 3.7 Specific NSHD for Change L3.7-118 (continued)

2.

The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change introduces no new mode of plant operation or changes in the methods governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

The proposed amendment will not involve a significant reduction in the margin of safety.

Allowing both CRSVS trains to be inoperable for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months under administrative controls is acceptable. During this time, entry and exit of plant personnel would be allowed. In addition, appropriate compensatory measures will be utilized to protect the control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. During this proposed time, control room integrity can be restored as needed. This proposed change can only be applied to those areas where administrative control will not be precluded by the DBA itself. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period in addition to the use of other compensatory measures. This change does not significantly reduce the margin of safety because it provides an equivalent level of CRSVS protection to the control room, such that the control room operators are not prevented from maintaining the integrity of fuel cladding, the reactor coolant system, or the containment. Based on the above, this change does not involve a significant reduction in the margin of safety.

Therefore it is concluded this proposed change does not involve a significant hazards consideration.

Prairie Island Units 1 and 2 52 2/2/02

Part G ENVIRONMENTAL ASSESSMENT Package 3.7 The Nuclear Management Company has evaluated the proposed changes and determined that:

1. The changes do not involve a significant hazards consideration, or

2.

The changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or

3.

The changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR Part 51 Section 51.22(c)(9). Therefore, pursuant to 10 CFR Part 51 Section 51.22(b), an environmental assessment of the proposed changes is not required.

Prairie Island Units 1 and 2 12/11/00 53

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Stored DG fuel oil NOTE-----------

Immediately supply:

Enter applicable Conditions and Required Actions of LCO 3.7.8, Unit 1 < 36,000 gal; "CL System" when Condition D is entered as a result of stored fuel Unit 2 < 65,000 gal.

oil properties not within limits.

OR D. 1 Declare DGs inoperable.

Required Action and associated Completion Time of Conditions A and C not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify stored DG fuel oil supply contains:

31 days Unit 1 2> 42,000 gal; Unit 2 _> 75,000 gal of fuel.

SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program.

Fuel Oil Testing Program Prairie Island Units 1 and 2 3.8.3-2 2/2/02

Diesel Fuel Oil B 3.8.3 BASES ACTIONS D. 1 (continued)

With the stored fuel oil supply not within the limits specified or Required Actions and associated Completion Times of Conditions A or C not met, the DGs may be incapable of performing their intended function and must be immediately declared inoperable.

A Note has been added to Condition D requiring entry into the applicable Conditions and Required Actions of LCO 3.7.8, "CL System" when Condition D is entered as a result of stored fuel oil properties not within limits. Since the diesel generators and the diesel driven CL pumps share a common storage tank, the diesel fuel oil properties are maintained by Specification 5.5.11, "Diesel Fuel Oil Testing Program." Therefore, if the fuel oil properties are not within limits, both the diesel generators and the diesel driven CL pumps are affected and appropriate Required Actions taken.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support the operation of one DG for 14 days. The 14 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The specified fuel oil inventory for the Unit 1 emergency diesel generators (EDGs) is in addition to the fuel oil inventory specified for the diesel driven cooling water pumps (LCO 3.7.8) that must be available in the Unit 1 diesel fuel oil storage system. There are four Design Class I fuel oil storage tanks for the Unit 1 EDGs and two Design Class I fuel oil storage tanks for the diesel driven cooling water pumps. These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any Unit 1 Prairie Island Units 1 and 2 B 3.8.3-4 2/2/02

Diesel Fuel Oil B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 (continued)

REQUREMENTS EDG or diesel driven cooling water pump day tank. Any combination of inventory in these six tanks may be used to satisfy the inventory requirements for the Unit 1 EDGs and the diesel driven cooling water pumps. There are four Unit 2 Design Class I fuel oil storage tanks. The four Unit 2 tanks are interconnected such that any tank can be manually aligned to supply either Unit 2 EDG day tank. Any combination of inventory in these four Unit 2 tanks may be used to satisfy the Unit 2 EDG inventory requirements.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 The tests for the new fuel oil prior to addition into the safeguards storage tank(s) are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the safeguards storage tanks without concern for contaminating the entire volume of fuel oil in the safeguards storage tanks. These tests are to be conducted prior to adding the new fuel to the safeguards storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests and limits for new and stored fuel are described in the Diesel Fuel Oil Testing Program of Specification 5.5.11.

Prairie Island Units 1 and 2 B 3.8.3-5 7/2/01

Diesel Fuel Oil B 3.8.3 BASES SURVEILLANCE SR 3.8.3.2 (continued)

REQUIREMENTS Failure to meet any of the limits specified in the Diesel Fuel Oil Testing Program is cause for rejection the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks. Failure to meet any of the limits for stored fuel requires entry into Condition B.

REFERENCES

1. USAR, Sections 8.4 and 10.3.

2.

USAR, Section 14.

Prairie Island Units 1 and 2 B 3.8.3-6 12/11/00

T.

3.7 3

REV 110 5/17/94 3.7.B.5.

COND EI Dl and D2 (Unit 2.. D and D6) Two diesel generators may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided t two required paths from the grid to the unit 4 kV safeguards distribution system are OPERABLE and the OPERABILITY of the two required paths from the grid are verified OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

IM3.8-14 IM.8-68 1

LC03.8.9 COND A, B, C, and D udng

R-11 L86 assocap~toct

-,Ii oeTor molcre sateguarcis ACeetrcl oe di sCt5iui

.Gru$ 1, 2

o motor control centersm may-be -inoperable orny

,i restore to U A I WA31.

8-63 tea in 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months si' 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months o days provided the redundant 4 kV safeguards bus and its associated 480 V safoguards buses arc vori fiod OPEPALE and tho diosol gonerate and atc

IAOL.A 0 -

are OPERADLE.

clatod with the redundant train IL3.8-09 I

7.

LC03. 8.4 COND A One battery charger may-be inoperable, restore Lae biatt*"ry chre oOEAL~ttswti for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months verity provd

d, (a) its associated battery is OPERABLE,--- (b)its r

-1 redundant counterpart is verified OPERABLEtn he (e-the diesel generator and safeguards equipment associated with its counterpart are OPERABLE* w[ n2 hours.

8.

One battery-eguars elctrica power source M3.81 inoperableglfor 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided tt the other battery LCO3.*8.

"a4 LC38 B

and both battery chargers remain OPERABLE aithii 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

9. in addition to tho roquiroments of Spocifieation TS.3.7.A.7 a R3.

R-2 8-02 Markup for PI ITS Part C

-01 second inverter+/-

lying instrum-nt Ae Panels 1*, 112, 11.,.[

and 114 may (Unit 2 panels 211, 212, 213 and 214) bo poworod from an

.nvort or bpas s sourco for hours.

IL AR R n PI Current TS 5 of 12

Part D Package 3.8 NSHD Change category number Discussion Of Change 3.8 65-67 Not used A

68 New Note. A new Note has been added to NUREG-1431, LCO 3.8.3 Condition D requiring that if the diesel fuel oil cannot be restored to within limits, declare the DGs inoperable and "enter applicable Conditions and Required Actions of LCO 3.7.8, "CL System" when Condition D is entered as a result of stored fuel oil properties not within limits." The PI design for the DGs and diesel driven CL pumps is a shared common fuel oil storage tank. The contents of the tank are controlled under ITS 5.5.11, "Diesel Fuel Oil Testing Program." In the event that the subject fuel oil properties are not within limits, ITS 3.8.3 provides specific Required Actions to restore the fuel oil to within limits or declare the DGs inoperable immediately.

There are no separate Required Actions for the diesel driven CL pumps. If the fuel oil in the storage tanks is not within limits for the DGs, it is also not within limits for the diesel driven CL pumps. Providing this Note in the ITS maintains CTS and provides assurance that the quality of the fuel oil for the diesel driven CL pumps is maintained to within standards and ensuring the pumps remain OPERABLE. Since this change maintains CTS, this is considered an Administrative change.

Prairie Island Units 1 and 2 37 2/2/02

ACTIONS (continued)

Diesel Fuel Oil, Lube Oil, and Starting Air IPA3.8-100 I 3.8.3 lCL3.8-1451 CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more DGs with starting ar rcever

.1 Restor starting air 48 ho-u'rs pressure -e

[225] psil receiver pressure to and t

[125] psig.

E225] p^'-

Stored DG fuel oil supply:

I < 36,000 2 < 65,000 Unit gal; Unit gal.

OR Required Action and associated Completion Time of Conditions A and C not met.

OR One or more 1BG diesel fuel oil, lube oil, or starting air subsystem I 4I. 1 61 1

1lli 1

I II

,.1 Iý reasons other than Condition A,B, C, D, NOTE--------

Enter applicable Conditions and Required Actions of LCO 3.7.8, "CL System" when Condition D is entered as a result of stored fuel oil properties not within limits.

DF.1 Declare

-rssee-ated DGs inoperable.

Immediately ICL3.8-146

.PA3.8-218 R-11 L ------

SURVEILLANCE REQUIREMENTS WOG STS Rev 1, 04/07/95 Markup for PI ITS Part E DF.

3.8.3-3

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 IPA3.8-100 1CL3.8-145 BASES ACTIONS E.4 (Conti....

With starting air receiver pressure <225] psig, suffi-i-nt caacpity for fiVe successive G-Dstart attempts does not exist. However, as long as the receivcr pressure is

"[ E125]

psig, there is adequate capacity for at ieast one start attempt, and the DG can be

.onsiderd OPERA{

while the air rcevrpiessure is restored to the required lifmit.

A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on the remaininig air start capacity, the fact that mfost DG starts arc accomplished on the first attempt, and the low probability of an event during this brief period.

DF.1 With the stored fuel oil supply not within the limits specified or *-Required Actions and associated Completion Times of Conditions A or C not met, or one or more DG's fuel oil, lube oil, or starting air subsystem not within li*mits for reasons other than addressed by Conditions A through D, the esso-ci-aed-DGs may be incapable of performing

-t-stheir intended function and must be immediately declared inoperable.

JPA3.8-218 A Note has been added to Condition D requiring entry into the applicable Conditions and Required Actions of LCO 3.7.8, "CL System" when Condition D is entered as a result of stored fuel oil properties not within limits.

Since the diesel generators and the diesel driven CL pumps share a common storage tank, the diesel fuel oil properties are r------------------

L R-11 I L -cnine J (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-7

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 PA3.8-100 CL3.8-145 BASES maintained by Specification 5.5.11, "Diesel Fuel Oil Testing Program."

Therefore, if the fuel oil properties are not within limits, both the diesel generatorslPA3.8-2181 and the diesel driven CL pumps are affected and appropriate Required Actions taken.

r........ I 1 R-11 L-I SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate JCL3.8-152 inventory of fuel oil in the storage tanks to support the operation of one DGeach DG's operation for

,714 daysI+

+/-ead.

The T14 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

The specified fuel oil inventory for the Unit 1 JCL3.8-160 emergency diesel generators (EDGs) is in addition to the fuel oil inventory specified for the diesel driven cooling water pumps (LCO 3.7.8) that must be available in the Unit 1 diesel fuel oil storage system.

There are four Design Class I fuel oil storage tanks for the Unit 1 EDGs and two Design Class I fuel oil storage tanks for the diesel driven cooling water pumps.

These six Design Class I tanks are interconnected such that any tank can be manually aligned to supply any Unit 1 EDG or diesel driven cooling water pump day tank.

Any combination of inventory in these six tanks may be used to satisfy the inventory requirements for the Unit 1 EDGs and the diesel driven cooling water pumps.

There are four Unit 2 Design Class I fuel oil storage tanks.

The four Unit 2 tanks are interconnected such that any tank can be manually aligned to supply either Unit 2 EDG day tank.

Any combination of inventory in these four Unit 2 tanks may be used to satisfy the Unit 2 EDG inventory requirements.

I R-8 (continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-8

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 JPA3.8-100 ICL3.8-145 BASES The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 This Surveillan, e ensures that suffi"ient lube oil inventory is available to support at least 7 days of full lead

,URnELLA,,E SR 3.8.3-2 (continued) operation for each 0G.

The [500] gal requirement is based on the DG mnanufaeturer consumption values for the run time of the DG.

Implicit in this SR is the requirement to verify the eapability to transfer the lub oil from its storage location to the DG, when the DG lube oil sump doesr not hold adequate inventory for 7 days of full lead operation without the level reaching the manufacturer recommended mfinimumn level.

A 31 day rrequeney is adequate to ensure that a sufficient lube oil supply is onsite, since BG starts and run timfe arc closely mnitored by, the unit staff.

SR 3.8.3.-32 The tests lis-ted-be!ewfor the new fuel oil prior to addition into the ICL3.8-1541 safeguards storage tank(s) are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the safeguards storage tanks without concern for contaminating the entire volume of fuel oil in the safeguards storage tanks.

These tests are to be conducted prior to adding the new fuel to the safeguards storage tank(s), but in no case is the time between (conti nued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-9

Diesel Fuel Oil, Lub, Oil, and Starting Air B 3.8.3 IPA3.8-100 ICL3.8-145 BASES receipt of new fuel and conducting the tests to exceed 31 days.

The testsT and limits, for new and stored fuel areand appli'able ASTM, Standards described in the Diesel Fuel Oil Testing Program of R-3 Specification 5.5.11. arc as follows:

i i

a. Sample the new fuel oil in accordance with ASTM 94057-[88]

JCL3.8-155

b.

Verify in aecordance with the tests specified in AST-M 0975 [77]

(Ref. 6) that the sample has an absolute specific gravitya 60/60OF of t 0.833 and

ý 0.89 or an API gravity at 604F of t27' and

39', a kinematic viscosity at 400C of t 1.9 centistokes and

4.1

-entistokes, and a flash point of t 125 0F, and

c.

Verify that the new fuel oil has a clcar and bright apparance with proper caolr when tested in actordan..

with ASTM 04176 E I SURVELLAN,,

SR 3.83.3-3 (continued+

REQU+/-REMEN-TS Failure to meet any of the ebove-limits specified in the Diesel Fuel Oil Testing Program is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Failure to meet any of the limits for stored fuel requires entry into Condition B.

Within 31 days following the initial new fuel oil sample, the fuel o,,CL3.8-155 properties specified in Table 1 of ASIM 0975 [77] (Ref. 7) arc mnet for new fuel oil when tested in accordancc with ASTM D975 [77] (Ref. 6),

ex^cpt that the analysis for sulfur may be performed in accordance wih*

ASTM 01552 [

] (Ref. 6) or ASTM D2622 [

] (Ref. 6).

The 31 day period is acccptablc because the fuel oil properties of interest, even if they were not within stated limfits, would not have an immediate (continued)

WOG STS Rev 1, 04/07/95 B 3.8.3-10 Markup for PI ITS Part E

Diesel Fuel Oil, Lube Oil, an' "tarting Air B 3.8.3 JPA3.8-100 ICL38-145 BASES effe. t on pTration ThL.-

Srveillance ensures the availabili*,y, of high quality fuel oil for the rGs.

Fuel oil degradation during long term storage shows up as an increase CL3.8-155 in particulate, due mostly to oxidation.

The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine.

The parti*.uate n

.ause fouing of filters and fuel oil inje-tion equipment, however, which an cause engine failure.

rarticulate concentrations should be determined in aecordance with ICL.

ASTM D2276-[

], Method A (Ref. 6).

This method involves--a gravirfetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg,'l.

it is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing.

EFo those designs in which the total stored fuel oil volume is contained int two or more interconnected tanks, each tank must be considered and tested separately.]

"The Frequency of this test takes into consideration fuel oI degradation trends that indicate that particulate concentration i unlikely to change significantly between Frequency intervals=.

ICL 3.8-1551 3.8-155 SURE+/-L E

SR 3.8.3.4 REQUIREMENT~S (eant-iue)

This Surveillance cnsures that, without the aid of the refill compressor, sufficient air start capacity for each DC is available.

The system design requirements provide for a mninimum of [five] engine start ey*les without recharging.

[A start eycle is defined by the DC vendor, but usually is measured in terms of time (seconds of cranking) or cranking s-peed.]

The pressure specified in this SRi "intended to reflect the lowest value at which the [fiv,] starts can be aeeampi-shed-(continued)

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-11

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 IPA3.8-100 ICL3.8-145:I BASES The 31 day Frequency takes into aeount the capacity, eapability, redundancy, and diversity of the AC..ur.es and other indications available in the.ontrol room, including alarms, to alert the operator to below normal air start pressure.

SR 3.8.3.-5 r3.8-147 are numerous bacteria that 4a-row [in fuel oil and cause fouling' but all must have a water environment in order to survive.

Removal of, "water from the fuel storage tanks

n*

e every [31] days eliminates the necessary envir nt for batrial survival.

This is the most effective means of controlling microbiological fouling. in addition, i-t eliminates the potential for water entrainment in the fuel oil during D eopcratior..

Water may come from any of several sourccs, ineluding condensation, ground water, rain water, and contaminated fuel] oill, and from breakdown of the fuel oil by bacteria.

Frrequent checking for and removal of accumulated water minimizes flouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies ar!stablished by Regulatory Guide 1.137 (Ref. 2).

This SR is for preventive maintenance.

The presence of wate does not necessarily represent failure of this SR, provided the accumulated water is removed during performancc of the Surveillance.

SURVEHLtAL REQUI\\REMEN-T (eenti nttd}

SR-3.8.3--36 Draining of the fuel oil stored in the supply tanksr, CL.-156 removal of accumulated sediment, and tank cleaning are required at 10 year intervals by Regulatory Guide 1.137 R-3 (Ref. 2), paragraph 24f.

This SR also requires the I

performance of the ASME Code,Section X! (Ref. 8),

examinations of the tanks.

To preclude the introduction of surfaetants in the fuel oil system, the cleaning should be a~eemplished using sodium hypoehlorite solutions, or their equivalent, rather thnsoap or detergents.

This SR is for preventive maintenance.

The presence of sediment does not necessarily represent a failure of this SR, provided that accumulated sediment is removed during performance of the Surveil11anee.

Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-12

Diesel Fuel Oil, Lube Oil, and *Start*ng Air B 3.8.3 IPA3.8-100 CL3.8-145I BASES REFERENCES

1.

FUSAR, Sections f9--5-8.4 and 10.3--.--21-.

2.

Regulatory Guide 1.137.

3. -

ANSI N195 1976, Appendix B.

24-.

FUSAR, Section -146-.

5.

FSAR, Chapter [15].

6.

ASr tandrds B4l057ll~

L--E

B7 1;916E 91 5 E!J~'

1;~l ll 62l E.* ];v~- 92276 iJ t

h-L 1 Jvu. I/U L

J CL3.8-154

7.

ASTM Standards, "975, Table-. 1

8.

ASME, Boiler and Pressa; ITA3.8-156 rVessel Code,Section I Markup for PI ITS Part E WOG STS Rev 1, 04/07/95 B 3.8.3-13

Part FPakg3.

Difference Difference Category Number Justification for Differences 3.8 PA 218 NUREG-1431 LCO 3.8.3, Required Action D, has been revised by a Note stating, "Enter applicable Conditions and Required Actions of LCO 3.7.8, 'CL System' when Condition D is entered as a result of stored fuel oil properties not within limits". The requirements for diesel fuel oil volume have been divided into two separate specifications. ITS 3.7.8 provides diesel fuel oil volume for the diesel driven CL pumps and ITS 3.8.3 provides the requirements for the diesel generators. In addition, ITS 5.5.11 provides the requirements for the Diesel Fuel Oil Testing Program. Both the diesel driven CL pumps and the plant diesel generators share a common storage tank and fuel oil contents. ITS 3.8.3 provides requirements for testing the tank contents and associated Required Actions if the fuel oil properties are not restored to within limits. A Note was added to Condition D instructing the operators that if the diesel fuel oil in the storage tanks is not within limits, to enter the associated Conditions and Required Actions for the diesel driven CL pumps. This change provides consistency between the two systems and is consistent with current plant design and practices.

Prairie Island Units I and 2 53 2/2/02 Package 3.8 Part F

Part G PACKAGE 3.8 ELECTRICAL POWER SYSTEMS NO SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL ASSESSMENT NO SIGNIFICANT HAZARDS DETERMINATION The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 1 OCFR Part 50, Section 50.91 using the standards provided in Section 50.92.

For ease of review, the changes are evaluated in groupings according to the type of change involved. A single generic evaluation may suffice for some of the changes while others may require specific evaluation in which case the appropriate reference change numbers are provided.

A - Administrative (GENERIC NSHD)

(A3.8-01, A3.8-10, A3.8-13, A3.8-15, A3.8-17, A3.8-20, A3.8-22, A3.8-23, A3.8-25, A3.8-30, A3.8-38, A3.8-39, A3.8-40, A3.8-51, A3.8-53, A3.8-56, A3.8-57, A3.8-58, A3.8-60, A3.8-62 and A3.8-63, A3.8-68)

Most administrative changes have not been marked-up in the CTS, and may not be specifically referenced to a discussion of change (DOC). This NSHD may be referenced in a discussion of change by the suffix "A" if the change is not obviously an administrative change and requires an explanation.

These proposed changes are editorial in nature. They involve reformatting, renaming, renumbering, or rewording of existing TS to provide consistency with NUREG-1431 or conformance with the Writer's Guide, change of current plant terminology to conform to NUREG-1431 or change of NUREG-1431 terminology to conform to CTS. Some administrative changes involve relocation of requirements within the TS without affecting their technical content. Clarifications within the NEW PI ITS which do not impose new requirements on plant operation are also considered administrative.

Prairie Island Units 1 and 2 1

2/2/02

ML020800670

Contents

Text

3.7.4 APPLICABILITY

3.7.5 APPLICABILITY

3.7.6 APPLICABILITY

3.7.8 APPLICABILITY

TA3.7'354

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ML020800670

Text

3.7.4 APPLICABILITY

3.7.5 APPLICABILITY

3.7.6 APPLICABILITY

3.7.8 APPLICABILITY

TA3.7'354

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