Text

Supplement Dated 02/15/2002 to License Amendment Request Dated 12/11/2000 Conversion to Improved Technical Specification Part D - Package 3.4 - Discussion of Change
	ML021900601
Person / Time
Site:	Prairie Island
Issue date:	02/15/2002
From:	Nazar M; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML021900601 (130)
	v • d • e

Part D Packaqe 3.4 NSHD Change Category Number Discussion of Change 3.4-80 Not used.

M 81 CTS 3.1.D.2.a. In accordance with the guidance of NUREG-1431, verification that the limits of Figure TS.3.1-3 (ITS Figure 3.4.17-1) are met shall be performed every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Since CTS do not specify a time frequency, this is a more restrictive change. This change is acceptable since it will assure that the limits are met on a timely basis and it does not introduce any unsafe plant operating conditions.

L 82 CTS 3.1.C.3 and Table 4.1-2B, Item 4a. CTS RCS specific activity limits when the RCS temperature is below 500°F and above cold shutdown have not been retained. The purpose of Specification 3.4.17 is to limit SGTR releases to a small fraction of 10CFR100 limits. This change is acceptable because below 500'F the release of radioactivity in the event of a SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the main stream safety valves. Since this change would not retain CTS requirements it is less restrictive on plant operations. This change is consistent with the guidance of NUREG-1431.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 83 CTS 3.3.A.3 and 3.3.A.4. For clarity and to be consistent with the guidance of NUREG-1431, "MODE 4, MODE 5 when the SG primary system manways and pressurizer manway are closed and secured in position, and MODE 6 when the reactor vessel head is on and the SG primary system manways and pressurizer manway are closed and secured in position." have been included in the description of when this specification is applicable. This is an administrative change since the plant is by definition in MODE 4 when the RCS temperature meets the criteria for the OPPS enable temperature.

M 84 CTS Table 4.1-1C, Item 25. For consistency with NUREG-1431, the functional test of the low temperature overpressure protection system will be performed monthly when the RCS temperature is below the LTOP enable temperature. Since CTS require this test each refueling outage, this is a more restrictive requirement. This change will provide additional assurance that the LTOP system will perform as required and is consistent with the surveillance interval for instrumentation providing similar plant protection.

M 85 Table 4.1-1C, Note 38. CTS do not specify a time frame within which this SR must be in compliance. Since ITS includes a time limit of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , this is a more restrictive change. This change conforms to the guidance of NUREG-1431 and is acceptable because it assures that the plant is maintained in a safe condition.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 L 86 CTS 4.6.C and Table 4.1-2A, Item 7. In accordance with GL 91 04, the surveillance interval for PORV functional testing and emergency pressurizer heater power supply are increased to 24 months to accommodate planned future extended reactor fuel cycles. Since this testing will occur less frequently, this is a less restrictive change. PORV functional tests were reviewed for a five year period and no problems were identified. Therefore it was concluded that an increased surveillance interval would have a minimal effect on plant safety. The emergency pressurizer heater power supply is currently tested prior to each refueling outage so that if a problem is identified it could be corrected during the ensuing outage. Review of testing experience on the emergency power supply did not identify any problems. Therefore it was concluded that an increased surveillance interval would have a minimal effect on plant safety.

L 87 CTS 4.3. This proposed change would revise the allowable PIV leakage of 1.0 gpm to 0.5 gpm per inch of nominal valve size up to 5 gpm maximum. This change is acceptable since the CTS 1.0 gpm limit imposes an unjustified limitation on larger valves. The restrictive limit, when applied to the larger valve, would require a repair effort when the relative degradation of the valve does not warrant the cost or exposure. A leakage limit based on valve size is more apt to provide meaningful information with respect to the mechanical condition of the valve, and is considered superior.

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

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Part D Package 3.4 NSHID Change Category Number Discussion of Change 3.4-L 88 CTS Table 4.1-2B, Item 1. The surveillance interval for RCS gross activity determination would be increased to once per week by this change in conformance with the guidance of NUREG-1431. This change is acceptable because fuel failures are most likely to occur during startup and fast power changes and not during steady state power operation during which the majority of sampling is performed. Gross fuel failures will also result in letdown radiation alarms and possibly containment radiation alarms providing additional operator indication.

89 Not used.

90 Not used.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-L 91 CTS Table 4.1-2B, Item 4a. The CTS requirement to sample once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when specific activity exceeds 100 1I pCi/gram has not been included. In accordance with ITS 3.4.17 Action B, whenever this limit is not met, the plant is required to be in MODE 3 with Tave

< 500'F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Thus the requirement for sampling in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months serves no useful purpose and is unnecessary. Since this change will require less sampling this change is less restrictive.

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

92 Not used.

93 Not used.

LR 94 CTS Table 4.1-2B, Items 5 and 6, and Note 2. The purpose of Specification 3.4.17, RCS Specific Activity is to limit the offsite radioactivity dose consequences from a SGTR to a small fraction of 10CFR100. This change will relocate Items 5 and 6, RCS Radiochemistry and RCS Tritium activity, from CTS Table TS.4.1 2B to the TRM since these items are not significant in limiting SGTR offsite dose and therefore should not be in TS. This is less restrictive since the TRM is under licensee control. However this change is acceptable since the TRM is under the controls of 10CFR50.59. This change conforms the PI ITS to the guidance of NUREG-1431.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-95 Not used.

LR 96 CTS Table 4.1-2B, Item 8 and Note 4. RCS boron concentration measurement at power was not included in the ITS since RCS Chemistry does not meet the NRC Policy Statement for TS Screening Criteria and is not required to be addressed within the TS. This requirement is relocated to the TRM. While this is a less restrictive change since the TRM is under licensee control, this change is acceptable because the TRM is under the controls of 10CFR50.59. This change is consistent with the guidance of NUREG-1431.

LR 97 CTS 4.3. For consistency with NUREG-1431, the list of valves and the test methodology have been relocated to the Bases. This detailed information is not required in the TS to run the plant in a safe manner. Since ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) is licensee controlled, relocation of CTS requirements to the Bases is a less restrictive change.

LR 98 CTS 4.6.C. The methodology for performing this surveillance has been relocated to the Bases. This detailed information is not required in the TS to run the plant in a safe manner. Since ITS Bases (under the Bases Control Program in Section 5.5 of the ITS) is licensee controlled, relocation of CTS requirements to the Bases is a less restrictive change.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-A 99 CTS 4.3. CTS require this SR to be performed prior to resuming power after each refueling. Since the NUREG-1431 format requires SR Frequency statement in months, this is revised to every 24 months. Since this change does not materially change the testing of these valves, this is an administrative change.

A 100 CTS 3.10.J. CTS 3.10.J states, "Compliance with c. is demonstrated by verifying that the parameter is within its limit after each refueling cycle." The parameter being referenced is the Reactor Coolant Flow which is referred to in the ITS as the RCS total flow rate. In addition, "c" states, "Reactor Coolant Flow > the value specified in the CORE OPERATING LIMITS REPORT." These statements have been editorially changed to be more consistent with the wording of the STS SR 3.4.1.4 as follows, "Verify RCS total flow rate is within the limit specified in COLR." The CTS requires that the Frequency for this SR as "after each refueling". This Frequency has been changed to "24 months" in the ITS which is still consistent with the CTS.

This change is considered to be an Administrative change since only editorial changes were made and no parameter, technical or operational changes made.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 LR 101 CTS 3.1O.J. The CTS requires that an engineering evaluation be performed to determine the effects of the out-of-limit condition on the structural integrity of the RCS. This information is being relocated to the ITS Bases 3.4.3, Action A.1 and A.2 section. Therefore, besides restoring the RCS pressure and temperature to within limits, a determination will be made if the RCS is acceptable for continued operation. This is accomplished through an evaluation. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continued operation. Several methods can be used, including an engineering evaluation, comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection of the components. Relocating this CTS information to the Bases retains the CTS and provides additional guidance for performing this determination as required in Required Action A.2.

A 102 CTS 3.1.A.1.c.(1). The CTS states "...whenever the reactor coolant system average temperature is below 350 OF, except during REFUELING ... " This has been changed to state in Mode 4 which is consistent with the Mode definition changes made in ITS 1.0. In MODE 4 the reactor temperature is 350 OF

> Tavg > 200 OF. This is considered to be an Administrative change since the temperature limits stated in the CTS are the same as Mode 4. This change is consistent with NUREG-1431.

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Part D Packaqe 3.4 NSHD Change Category Number Discussion of Change 3.4 A 103 CTS 3.1.A.1.c.(1). The CTS states "... whenever the reactor coolant system average temperature is below 350 OF, except during REFUELING .. ." This has been changed to state in Mode 5 with RCS loops filled which is consistent with the Mode definition changes made in ITS 1.0. In MODE 5 the reactor temperature is < 200 °F. This is considered to be an Administrative change since the temperature limits stated in the CTS are the same as Mode 5. This change is consistent with NUREG-1431.

A 104 CTS 3.1 .A. 1.c (2). Both the CTS and ITS require two loops (methods) of decay heat removal be OPERABLE when the reactor is in MODE 4. The CTS states that with only one OPERABLE method of removing decay heat, initiate prompt action to restore two OPERABLE methods of removing decay heat. This requirement has been editorially changed to be consistent with NUREG 1431 by stating, one required loop inoperable, immediately initiate action to restore a second loop OPERABLE. The actions are the same in both the CTS and ITS in that when one loop (method) of decay heat removal is inoperable, then the second loop (method) must immediately (promptly) be restored to OPERABLE. Since the Required Actions and associated Completion Times are the same and no technical changes or operating practices were changed, this is considered to be an Administrative change.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-A 105 CTS 3.1.A.1.c (2). The CTS states that if one method of decay heat removal is inoperable and if the only remaining operable method is an RHR loop, be in Cold Shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The ITS editorially changes this requirement such that when one required loop is inoperable, Required Action A.2 requires that the unit be placed in MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months only if the required RHR loop is OPERABLE. The Actions and Completion Times in both the CTS and ITS are the same, no technical or operational changes have been made to this requirement, therefore this is an Administrative change.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 106 CTS 3.1.A.1.c (3). The CTS requires that with no methods of removing decay heat, suspend all operations involving a reduction in boron concentration of the RCS and initiate prompt action to restore one loop OPERABLE method of removing decay heat. This requirement has been editorially changed to be consistent with NUREG 1431 by stating that two required loops inoperable or required loop not in operation, suspend operations that would cause introduction into RCS coolant with boron concentration less than required to meet SDM of LCO 3.1.1 and immediately initiate action to restore one loop OPERABLE and in operation. Both the CTS and the ITS require the same actions and associated Completion Times.

Both the CTS and ITS require two loops (methods) of decay heat removal. This specific action is for when both loops (methods) of decay heat removal are inoperable. In both cases, the primary action is to suspend actions that might reduce RCS coolant boron concentration. The ITS is more specific by referring to SDM as stated in LCO 3.1.1 whereas the CTS does not specifically refer to the TS LCO but the required actions and intent are the same as the ITS. The Completion Times in both the CTS and ITS are the same. In addition, both the CTS and ITS require that a loop (method) of decay heat removal be restored to OPERABLE status. The CTS requires prompt action whereas the ITS uses the phrase immediate action. Both terms mean the same at PI. Based on the above, this is considered to be an Administrative change since no technical or operational changes are being made to the CTS.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-A 107 CTS 3.1.A.1.c.(1). The CTS requires that two methods for decay heat removal be OPERABLE with one in operation. The CTS further states that acceptable methods for removing decay heat are at least one reactor coolant pump (RCP) and its associated steam generator (SG), or residual heat removal (RHR) loop including a pump and its associated heat exchanger. As stated in DOC LR3.4-24, the RCS loop consists of the RCP and associated SG. In addition, the RHR loop consists of the RHR pump and associated heat exchanger.

Therefore, the ITS uses the RHR loop and RCP loop instead of all the associated components. Even though the components are not specifically mentioned in the LCO, they are included in the definitions of loop. The CTS also states that two acceptable methods of decay heat removal are needed and provide those acceptable methods. The intent is that any of the two methods identified are acceptable. This has been changed in the ITS to state that two loops consisting of any combination of the RHR loops or RCS loops are the acceptable methods. This is only an editorial change in that the both the CTS and ITS allow the use of the same decay heat removal system or a combination of the two to meet the LCO requirements. Therefore, this is considered to be an Administrative change.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-108 Not used.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 L 109 CTS 3.1.A.2.b(1). CTS 3.1.A.2.b(1) requires two RCS pressurizer safety valves (PSVs) to be operable when the RCS temperature is > 350'F. This change will require two RCS PSVs to be operable whenever both RCS cold leg temperatures are greater than the OPPS enable temperature specified in the PTLR. This change is consistent with the guidance of NUREG-1431 and will provide additional overpressure protection when the RCS is between 3500°F and the OPPS enable temperature. Per the ITS, in the event that an inoperable PSV cannot be restored to OPERABLE status within 15 minutes or if both PSVs are inoperable, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 with any RCS cold leg temperatures < the OPPS enable temperature specified in the PTLR in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The CTS requires the plant to be below 350 degrees F within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Increasing the Completion Time from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is considered to be a less restrictive change. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. With any RCS cold leg temperatures at or below the OPPS enable temperature specified in the PTLR, overpressure protection is provided by the LTOP function. This Completion Time change is consistent with the guidance of NUREG-1431 as modified by approved traveler TSTF-352, Revision 1. These changes are acceptable because they will not cause any unsafe plant operating or testing conditions.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 110 CTS 3.1 .A.2.c (1) (b) 4. CTS and ITS LCO 3.4.11, Condition C both require that with one block valve inoperable, place its associated PORV in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The ITS provides additional clarification by adding a Note stating that the Required Actions C.1 and C.2 do not apply if sole reason for the block valves being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) are adequate to address the conditions. Even though not specifically stated, the intent and required operational practices stated in the ITS are the same as the CTS. Since there are no operational or technical changes associated, this is considered to be an Administrative change. Making an editorial change to the CTS by specifically adding the Note for clarification also supports this change as Administrative.

A 111 CTS 3.1.A.2.c (1)(b)5. CTS and ITS LCO 3.4.11, Condition F both require that with both block valves inoperable, restore one block valve to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The ITS provides additional clarification by adding a Note stating that the Required Action F.1 does not apply if sole reason for the block valves being declared inoperable is as a result of power being removed to comply with other Required Actions. In this event, the Required Actions for inoperable PORV(s) are adequate to address the conditions. Even though not specifically stated, the intent and required operational practices stated in the ITS are the same as the CTS. Since there are no operational or technical changes associated, this is considered to be an Administrative change. Making an editorial change to the CTS by specifically adding the Note for clarification also supports this change as Administrative.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 112 CTS Table 4.1-2A Item 9. CTS Item 9 requires that the Primary System Leakage be evaluated daily. A Note has been added stating that this evaluation is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation. The RCS water inventory balance must be met with the reactor at steady state operating condition (stable temperature, power level, equilibrium xenon, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows).

Therefore, this SR Note does not require the performance of this SR until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. Performance of this SR at steady state conditions is standard PI operating practice and consistent with the intent of the CTS. Since this SR Note only provides clarification for CTS requirements, this change is considered to be an Administrative change.

A 113 CTS Table 4.1-2A, Item 6. CTS requires that the Pressurizer PORV Block Valves be functionally tested every 92 days. The ITS adds a note stating that this test only be required to be performed in Modes 1 and 2. This Note allows entry into Mode and operation in Mode 3 prior to performing the SR. This allows the test to be performed under operating temperatures and pressures. This is considered to be an Administrative change since this is consistent with current operating practices and the intent of the CTS. In addition, no technical nor operational changes are made as a result of this Note.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4-A 114 CTS Table 4.1-2A, Item 7. CTS requires that the PORVs be functionally tested every 18 months. The ITS adds a note stating that this test only be required to be performed in Modes 1 and 2.

This Note allows entry into Mode and operation in Mode 3 prior to performing the SR. This allows the test to be performed under operating temperatures and pressures. This is considered to be an Administrative change since this is consistent with current operating practices and the intent of the CTS. In addition, no technical nor operational changes are made as a result of this Note.

115 Not used.

116 Not used.

M 117 CTS Table 4.1-2.B, Note 1. Note 1 states that a sample is to be taken after a minimum of 2 EFPD and 20 days of POWER OPERATION have elapsed since reactor was last subcritical for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or longer. The ITS Note states that the SR is not required to be performed until 31 days after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The CTS does not have specific time limit of 31 days to perform the SR, therefore making this a more restrictive change. The 31 days is acceptable since it further ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal event.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 L 118 CTS 3.1 .A.1 .b(3)(a). The CTS requires that with both reactor coolant pumps inoperable or not in operation, immediately "de energize all control rod drive mechanisms, and ... ." ISTS LCO 3.4.5, Required Action D.1 requires that if two RCS loops are inoperable or required RCS loops are not in operation, immediately place the control rod drive system in a condition incapable of rod withdrawal. This is considered to be a Less Restrictive change since the CTS only allows for de energization of the control rod drive system, whereas, the ISTS allows for various methods of making the control rod drive system incapable of rod withdrawal. The overall intent, assuring that control rods can not be withdrawn and thereby increase any potential heat input to the reactor coolant is maintained. Since the revised Actions still assure rod withdrawal is precluded, details of specifically stating de energization of the control rod drive system is not necessary nor required to provide adequate protection of the public health and safety. The requirement that the control rods are inserted and are not capable of being withdrawn is also maintained.

This change allows alternate options to preclude rod withdrawal. These options are necessary to allow testing. This Less Restrictive change provides several options to assure that the control rods are not capable to withdraw. This change is consistent with the guidance provided by NUREG-1431 and TSTF-87, Rev. 2.

119 Not used.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 120 CTS 3.1 .A.1 .c (2). Both the CTS and ITS require two loops (methods) of decay heat removal be OPERABLE when the reactor is in MODE 5. The CTS states that with only one OPERABLE method of removing decay heat, initiate prompt action to restore two OPERABLE methods of removing decay heat. Although not specifically stated, the methods for decay heat removal can be a combination of two RHR loops or a RHR loop and a SG. This is also true in the ITS. The CTS requirement has been editorially changed to be consistent with NUREG 1431 by stating, one required loop inoperable and one RHR loop OPERABLE, immediately initiate action to restore a second loop to OPERABLE status. The actions are the same in both the CTS and ITS in that when one loop (method) of decay heat removal is inoperable, then the second loop (method) must immediately (promptly) be restored to OPERABLE. Another option of restoring adequate decay heat removal is ensuring that the SGs secondary side water level is adequate so they are capable of decay heat removal. The only difference between the CTS and ITS is that the ITS specifically identifies the methods for ensuring decay heat removal, whereas the CTS is not as specific even though it has the same intent.

Since the Required Actions and associated Completion Times are the same and no technical changes or operating practices were changed, this is considered to be an Administrative change.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 121 CTS 3.1.A.1.c (2). Both the CTS and ITS require two loops (methods) of decay heat removal be OPERABLE when the reactor is in MODE 5. The CTS states that with only one OPERABLE method of removing decay heat, initiate prompt action to restore two OPERABLE methods of removing decay heat. Although not specifically stated, the methods for decay heat removal can be a combination of two RHR loops or a RHR loop and a SG. This is also true in the ITS. The CTS requirement has been editorially changed to be consistent with NUREG 1431 by stating, one or more SGs not capable of decay heat removal and one RHR loop OPERABLE, immediately initiate action to restore a second loop to OPERABLE status or initiate action to restore the required SG capable to remove decay heat. The actions are the same in both the CTS and ITS in that when one loop (method) of decay heat removal is inoperable, than the second loop (method) must immediately (promptly) be restored to OPERABLE. Another option of restoring adequate decay heat removal is ensuring that the SGs secondary side water level is adequate so it is capable of decay heat removal. The only difference between the CTS and ITS is that the ITS specifically identifies the methods for ensuring decay heat removal, whereas the CTS is not as specific even though it has the same intent. Since the Required Actions and associated Completion Times are the same and no technical changes or operating practices were changed, this is considered to be an Administrative change.

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W....

Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 122 CTS 3.1.A.1 .c (3). The CTS requires that with no methods of removing decay heat, suspend all operations involving a reduction in boron concentration of the RCS and initiate prompt action to restore one loop OPERABLE method of removing decay heat. This requirement has been editorially changed to be consistent with NUREG 1431 by stating that two required loops inoperable or required loop not in operation, suspend operations that would cause introduction into RCS coolant with boron concentration less than required to meet SDM of LCO 3.1.1 and immediately initiate action to restore one loop OPERABLE and in operation. Both the CTS and the ITS require the same actions and associated Completion Times.

Both the CTS and ITS require two loops (methods) of decay heat removal. This specific action is for when both loops (methods) of decay heat removal are inoperable. In both cases, the primary action is to suspend actions that might reduce RCS coolant boron concentration. The ITS is more specific by referring to SDM as stated in LCO 3.1.1 whereas the CTS does not specifically refer to the TS LCO but the required actions and intent are the same as the ITS. The Completion Times in both the CTS and ITS are the same. In addition, both the CTS and ITS require that a loop (method) of decay heat removal be restored to OPERABLE status. The CTS requires prompt action whereas the ITS uses the phrase immediate action. Both terms mean the same at Pl. Based on the above, this is considered to be an Administrative change since no technical or operational changes are being made to the CTS.

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Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 M 123 CTS 3.1.A.2.c (1) (b) 5. The CTS requires that with both block valves inoperable, within one hour either restore the block valve to OPERABLE or place the PORVs in manual control.

The ITS requires that the block valves be restored to OPERABLE and does not provide an alternate option of placing the PORVs in manual. This option has been deleted from the CTS. Although in the CTS, due to the short Completion Time of placing the PORVs in manual in addition to restoring the block valve to OPERABLE status within the next hour, placing the PORVs in manual is not a commonly utilized action. Since the ITS does not include this option, deleting additional flexibility is a More Restrictive change.

Deleting the action of placing the PORVs in manual control when both block valves are inoperable, does not reduce the safety or operation of the plant since the ultimate action is to either restore the block valve to OPERABLE status within the next hour (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months total) or initiate a reactor shutdown. In addition, if a block valve cannot be restored to OPERABLE within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the plant will be required to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . When the plant is shutting down, the PORVs will be needed for Temperature Over Pressure Protection. Therefore, the PORVs should not be placed in manual. The CTS Completion Time of a total of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore an inoperable block valve, when both are inoperable, is consistent with NUREG-1431.

Prairie Island Units 1 and 2 59 1/2/02

k -

Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 A 124 CTS Table 4.1-2.B Item 3. The CTS requires that the RCS Radiochemistry and E determination test be preformed once per 6 months when the reactor is at power. This is also annotated with a footnote that states, "Sample to be taken after a minimum of 2 EFPD and 20 days of POWER OPERATION have elapsed since reactor was last subcritical for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or longer." The ITS has editorially revised the CTS SR and associated footnote to state, "Determine E from a sample taken in MODE 1 after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ." The only changes made are that the ITS combines the CTS SR and footnote, and the CTS refers to POWER OPERATIONS vs. MODE 1 in the ITS.

The CTS definition of POWER OPERATIONS is the same as MODE 1. The CTS definition of POWER OPERATIONS was revised to be consistent with MODES as documented in ITS markup of Section 1.0. Since this change is purely editorial and no technical or operational changes were made, this change is considered to be an Administrative change.

A 125 CTS Table 4.1-2.B, Item 2. The CTS requires the RCS Isotopic Analysis for DOSE EQUIVALENT 1-131 Concentration test be performed once every 14 days when the reactor is at power. The ITS requires the same test to be performed at the same Frequency. However, the ITS in conformance with the ISTS contains a note that states that the SR is only required to be performed in MODE 1. This change is considered to be an Administrative change since the only change made is editorial and in presentation. The CTS has a requirement of when the reactor is at power whereas the ITS contains the same requirement but it is in a note. The CTS definition of power operation is essentially equivalent to MODE 1 in the ITS. In addition, this change does not make any technical or operational changes and is therefore considered an Administrative change.

Prairie Island Units 1 and 2 60 1/2/02

Part D Package 3.4 NSHD Change Category Number Discussion of Change 3.4 L 126 CTS 3.1 .A.1 .c.(1). The CTS requires two methods for removing decay heat with one of the methods in operation.

The CTS further states that acceptable methods for removing decay heat are at least one reactor coolant pump (RCP) and its associated steam generator (SG) or a residual heat removal loop including its associated heat exchanger. DOCs A3.4-107 and LR3.4-24 document what constitutes a RCS loop or RHR loop. No other discussion on this will be discussed in this DOC. The CTS states that a RCP and its associated SG are an acceptable method whereas the ITS only requries the SG to be OPERABLE if the RHR is not used as the second method of decay heat removal. If the SG is the second method of decay heat removal, its associated RCP is not needed to be OPERABLE in order for the SG to perform its decay heat removal function. Therefore, the ITS does not require the RCP to be OPERABLE for this LCO making this a less restrictive change. This change is acceptable since the one RHR loop that is OPERABLE and in operation provides forced circulation to perform the safety functions of the reactor coolant under Mode 5, loops filled condition. An additional RHR loop is required to be OPERABLE to provide redundancy. However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is a SG. The SG could be used to remove decay heat via natural circulation. This change is consistent with NUREG-1431.

Prairie Island Units 1 and 2 61 1/2/02

Part D Package 3.4 P rt D NSHD Change Category Number Discussion of Change 3.4 A 127 CTS3.3.A.3 (b). The CTS requires that only one SI pump may be capable of injecting into the RCS whenever the RCS temperature is less than the OPPS enable temperature specified in the PTLR except that both Sl pumps may be run for up to one hour while conducting the integrated SI test**

when either of the following conditions is met: (b) the reactor vessel head is removed. This statement is not being incorporated into the ITS since it is no longer applicable. In the conversion process from the CTS to the ITS, the MODES and Conditions of Applicability have been changed. The ITS provides two LCOs for the LTOP function. LCO 3.4.12 is with the MODE of Applicability in MODE 4 when any RCS cold leg temperture is greater than the Sl pump disable temperature specified in the PTLR. The second LCO is 3.4.13 with the MODE of Applicability in MODE 4 when any RCS cold leg temperture is less than or equat to the SI pump disable temperature specified in the PTLR, MODE 5 when the SG primary system manways and pressurizer manway are closed and secured in position, and MODE 6 when the reactor vessel head is on and the SG primary system manways and pressurizer manway are closed and secured in position.

Based on the redefinition of the MODES and conditions of Applicability in the ITS, the CTS requirement is not applicable.

The CTS requirement of requiring the reactor vessel head to be removed would take the reactor out of the MODE of Applicability and therefore, ITS 3.4.12 and 3.4.13 would not be applicable nor would their subject LCO notes. Based on the above, the CTS requirement for reactor head removal is not incorporated into the ITS.

Prairie Island Units 1 and 2 62 1/2/02

RCS Pressure, Temperature, and Flow-DNB Limits 3.4.1'.L_-1iOl IEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is greater than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or equal to the limit specified in the COLR t E220] ".TA3.4109 SR 3.4.1.2 Verify RCS average temperature is less than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or equal to the limit specified in the COLR

ý E5114. A3.4109

-SR-.... 3. 4.1. 3 I-I;.~

ronI

!r

-P n,.-r, C i n1.nl _-- 2- h ICL3.4-1037

- L**,wvvvJ ýJjlll.

.1.

SR 3.4.1.34 ------------------- NOTE --------------------

Nt ruirea to af ter t E901% RT-P.

13 pertormeluntil

-m-'* 2j4 hocurs z~49t1.l5 Lu CL.-104 mnnf-hc l)

I-' LIIj.iu [

' R-9 L

SPA3.-106 L----

Verify by precision heat balance that RCS total flow rate is within the limit specified in the COLR> ,000] gpffl.

ICL'.-107 !

CL3.4-102 R-2 I

WOG STS, Rev 1, 04/07/95 3.4.1-3 Markup for PI ITS Part E

RCS Loops-MODE 3 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3,4.5 RCS Loops-MODE 3 LCO 3.4.5 -Twol RCS loops shall be OPERABLE, and either: ICL3.4-113 1

a. {Two+/- RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal; or

b. One RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

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

BothA41- reactor coolant pumps may be ICL3.4-1141 de-energized for

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to perform preplanned work activities per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period ICL3"4-117 I provided: ITA3"4-1151 R-9L J

a. No operations are permitted that would cause L.. .. ...

introduction intoreduction of the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10'F below saturation temperature.

APPLICABILITY: MODE 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One requi--red*-RCS loop A.1 Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. inoperablerequired RCS loop to OPERABLE [CL3.4-I13_

status.CL.-1 WOG STS, Rev 1, 04/07/95 3.4.5-1 Markup for PI ITS Part E

RCS Loops-MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY i

SR 3.4.5.2 Verify required steam generator capable of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months removing decay heat. secondary side water ICL3"4-121 _j* ...

-U - L-L; j _ IUI u I 'UlIIZU \ IUUJ..

IR-9 I.-

SR 3.4.5.3 NOTE ----------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ITA3.4-125 j Verify correct breaker alignment and 7 days indicated power are available to eachthe required pump that is not in operation. R-1 WOG STS, Rev 1, 04/07/95 3.4.5-4 Markup for PI ITS Part E

RCS Loops-MODE 4 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops-MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops shall be OPERABLE, and one loop shall be in operation.

-NOTES -------------------- IPA3-12

1. All reactor coolant pumps (RCPs) and RHR pumps may be de-energized for

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided: - -

R-9I I

a. No operations are permitted that would cause L introduction intoredution af the RCS, coolant with boron concentration less than required .

to meet the SDM of LCO 3.1.1; and LTA3.4-115

b. Core outlet temperature is maintained at least 100 F below saturation temperature.

2. No RCP shall be started with any RCS cold leg lTA3'4-119 j temperature < the Over Pressure Protection System (OPPS) enable temperature specified in the PTLRE275]F unless:

a. Tt-he secondary side water temperature of each steam generator (SG) is * {50+/- 0 F above each of the RCS cold leg temperatures; or-

b. There is a steam or gas bubble in the S-123 pressurizer.

APPLICABILITY: MODE 4.

WOG STS, Rev 1, 04/07/95 3.4.6-1 Markup for PI ITS Part E

RCS Loops-MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required-RG- loop A.1 Initiate action to Immediately inoperable, restore a second loop to OPERABLE status.

AND Two RUIR loops inerable. A.2 ------- NOTE-----

Only required if RHR lTA3.4-330 I loop is OPERABLE.

Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. One required R'"R loop B.1 Be in MODE 5. ITA3.4-330 I inoperable.

Two required RCS loops 24-hou-rs inoperable.

r -.. . i R-9 1 L ----- J WOG STS, Rev 1, 04/07/95 3.4.6-2 Markup for PI ITS Part E

RCS Loops-MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME LB. BothRqu-ired R-G GB.1 Suspend-a-l4 Immediately or-RHR loops operations that would ITA3"4-115 inoperable, cause introduction into theinvolving a OR reductioneof RCS, coolant with boron ITA3.4-330 No RCS or RHRRequired concentration less loop not in operation. than required to meet Immediately SDM of LCO 3.1.1.

AND GB.2 Initiate action to ICL3.4"-13 restore one loop to OPERABLE status and operation. R-9 L --

WOG STS, Rev 1, 04/07/95 3.4.6-3 Markup for PI ITS Part E

RCS Loops-MODE 4 3.4.6 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one required RHR or RCS loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ITA3.4-33F0 J_

' R-9 ,

SR 3.4.6.2 Verify required SG capable of removing 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months decay heatsecondary side water levels are

,[171for required RCS loops. .4-121 I I LR-9 SR 3.4.6.3 ------------------- NOTE -------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. iTA3"4-125 i Verify correct breaker alignment and indicated power are available to each-h-e 7 days required pump that is not in operaton.

WOG STS, Rev 1, 04/07/95 3.4.6-4 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops Filled LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

a. One additional RHR loop shall be OPERABLE; or IrF *7o*

b. The seeondary side water level of at lea-stý IL -LU I

{-twe I One steam generators (SGa) shall be ICE3.4-121 capable of removing decay heat->--F!1-7+/-.

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

1. The RHR pump of the loop in operation may be de-energized for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

r I IR-9

a. No operations are permitted that would cause L .

introduction intoreduction o-f the RCS, coolant ITA3.4-115 with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10'F below saturation temperature.

2. One required RHR loop may be inoperable for <tt* IPA3"4-127 I t-e 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3. No reactor coolant pump shall be started with one or more RCS cold leg temperatures < the Over lTA3.4-119 Pressure Protection System (OPPS) enable temperature specified in the PTLR{27-5, 2F unless:

a. Tt-he secondary side water temperature of each SG is

< f50j°F above each of the RCS cold leg temperatures; or--

b. There is a steam or gas bubble in the ICL3.4-123 j pressuri zer.

WOG STS, Rev 1, 04/07/95 3.4.7-1 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled 3.4.7

4. BothA-l-l- RHR loops may be removed from operationone C 4 when at least " -1 during planned heatup to MODE RCS loop is in operation.

APPLICABILITY: MODE 5 with RCS loops filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop A.1 Initiate action to Immediately inoperable, restore a second RHR loop to OPERABLE ITA3.4-330 AND status.

OR IcL3'4-113 One RHR loop OPERABLE Requi red Sssecondary side water levels ,,t A.2 Initiate action to Immediately within lmimts, restore required SG capable to remove decay heats-econa-ry si d woter levels to .... . .

within limits.

B. One or more SGs B.1 Initiate action Immediately not capable of to restore a decay heat second RHR loop removal, to OPERABLE status.

AND ADOR JT3.-330O One RH-R loop OPERABLE. B.2 Initiate action Immediately to restore required SG CL3.4-121 capable to remove decay heat.

1R-91

! I L -....

WOG STS, Rev 1, 04/07/95 3.4.7-2 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled 3.4.7 CONDITION I REQUIRED ACTION I COMPLETION TIME BC. No Rrequired RHR immICL3.4-128 loops inoperable BC. 1 Suspend--a+

OPERABLE. operations that would ediately cause introduction GRAND ITA3"4-115I into theinvolving a reduction of RCS, NeRequired RHR loop coolant with boron not in operation. concentration less than required to meet ITA3 .4-330 SDM of LCO 3.1.1. Immediately AND BC.2 Initiate action to restore one RHR loop to OPERABLE status IR-9 and operation. L -.---

WOG STS, Rev 1, 04/07/95 3.4.7-3 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required &re RHR loop is in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months operation. ITA3.4-330 SR 3.4.7.2 Verify SG seondary side water level is 3.4-121 17]-in required SGs- capable of removing

>-E--

decay heat.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued) 1R-9 1 L-i SR 3.4.7.3 ------------------- NOTE -------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ITA3.4-125 Verify correct breaker alignment and 7 days indicated power are available to each*t-e required RHR pump that is not in operation.

WOG STS, Rev 1, 04/07/95 3.4.7-4 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

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

1. All RHR pumps may be de-energized for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period 15 minutes when switching from one loop to another-provided: J -131 ab. No operations are permitted that would causeR-9 I of the RCS, coolant introduction intoa reduction with boron concentration less than required IT,3 iii to meet the SDM of LCO 3.1.1;--adI ba. fThe core outlet temperature is maintained > 10'F below saturation temperature; and--.

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled.

ACTTIfNNS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop A.1 Initiate action to Immediately I

inoperable. restore RHR loop to 33 I R-9 OPERABLE status. L-.

______________________________ J a WOG STS, Rev 1, 04/07/95 3.4.8-1 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled 3.4.8 ACTIONS c nREQUIRED ACTION COMPLETION TIME (continued)

B. No Rrequired RHR loops B.1 Sus pen d-a4l Immediately OPERABLE inoperable. operations that would cause introduction ICL3.4-128 OR into theinvolving reduction in RCS, N&Required RHR loop coolant with boron ITA3.4-115 not in operation. concentration less than required to meet SDM of LCO 3.1.1.

AND ITA3.4-330 NOTE ---------- -------------. I I A Safety Injection pump may I R-9 I I

L- ... .

be run as required to maintain adequate core CL.-132 cooling and RCS inventory. Immediately B.2 Initiate action to restore one RHR loop to OPERABLE status and operation.

WOG STS, Rev 1, 04/07/95 3.4.8-2 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled 3.4.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I

SR 3.4.8.1 Verify onerequired RHR loop is in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months operation. TA3.4-330 IR

R-9"

' I L-SR 3.4.8.2 -------------------NOTE----------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation. ITA3.4-125 Verify correct breaker alignment and 7 days indicated power are available to eacht-he required RHR pump that is not in operation.

WOG STS, Rev 1, 04/07/95 3.4.8-3 Markup for PI ITS Part E

Pressurizer Safety Val]ves

In a

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Time not met.

AND OR B.2 Be in MODE 4 with any 24-1-Z hours ITA3.4-139 1 BothTwe or more RCS cold leg pressurizer safety temperatures < the ICL3.4-142 valves inoperable. OPPS enable temperature speciRfi ed IT.4-119 in the PTLR-E2-7-1+-2F.

I ______________________________

qlIIVFTI IANCF RFOLITREMENTS SURVILLACE RQUIRMENT SURVEILLANCE FREQUENCY t

IPA3.4-143 I SR 3.4.10.1 Verify each pressurizer safety valve is In II OPERABLE in accordance with the Inservice accordance with Testing Program. Following testing, lift the Inservice Testing settings shall be within 1% (2460 to 2510 psig). Program R-9 L - - - - -..

WOG STS, Rev 1, 04/07/95 3.4.10-2 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-tem 3.4.12 1 R-9 3.4 REACTOR COOLANT SYSTEM (RCS) L......

3.4.12 Low Temperature Overpressure Protection (LTOP) Sysem - CL34-161 Reactor Coolant System Cold Leg Temperature (RCSCLT) >

Safety Injection (SI) Pump Disable Temperature R-9 LCO 3.4.12 Af1-LTOP--System shall be providedOP,,rAB LE with: L----- '

a) a maximum of tone] [high pressure injection SI (-PI-)

pump [and one ,harging pump] capable of injecting into the RCS; (ECCS) CL3.4-163 b) and-the emergency core cooling system accumulators isolated; c) an OPERABLE Over Pressure Protection System (OPPS); and either a or b below.

a. Two RCS relief valves, as follows; d) tTwo OPERABLE pressurizer power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR.,--er

[2. Two residual heat removal (.IR), suction r.lief valves with setons [3.]pi n E463.5] psig, or]

[3. One PORV with a lift setting within the limits specified in the PTLR and one R"R suction relief valve with a setpoint [436.5] pJ and

b. The RCS depressurized and an RCS vent of >! [2.0:7]

square ] linehe,

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

1. Both SI pumps may be run for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months while conducting SI system testing providing there is I -164 a steam or gas bubble in the pressurizer and at least one isolation valve between the SI pump and the RCS is shut.

WOG STS, Rev 1, 04/07/95 3.4.12-1 Markup for P1 ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSystem 3.4.12

2. ECCS accumulator may be unisolated when ECCS accumulator pressure is less than the maximum TA3.4-166 RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR APPLICABILITY: MODE 4 when any&-+/- RCS cold leg temperature is ITA3.4-165

< the OPPS enable temperature specified in the PTLR{2-7-5+/-ý-H and > the SI pump disable TA3.4-119 temperature specified in the PTLR.

MODE 5, MfllF- A '- I r-RA~ r'.1R - I - - I- I--

u

-J !

I 1 CL3.4-167

-- -- NOTE -

I i~11 - 4 1 4 c A ! 0 i- a w pq

"_ý: "*

,AI II ,, I I , ý U. I J L .- I I

~LuI

-I ITA3.4-166 aecuflUuIlaro presrI:35U ure NOT[---

el IUI VQIA ýq

-C J-

, 4- 4R F:;u - I L;u i U U

GLA 11..J L.. nit 1MUM44 . .I ,

UJ/ , II / ~l b £ . I,,. F*I*. I UUU- -

1 11I the PTLR.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Two or more SI{-PJ-I- A.I Initiate action to Immediately pumps capable of verify a maximum of JPA3"4-159 injecting into the fonel SI-HP-I-+ pump is RCS. capable of injecting JcL3"4-163 into the RCS.

WOG STS, Rev 1, 04/07/95 3.4.12-2 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperatureis-t-em 3.4.12 R--- I----I R-91 ACTIONS (continued) L- ----. J CONDITION REQUIRED ACTION COMPLETION TIME U. Two or mo.re chargg B.i NOTE punTps c oToharging pumfps injecting into the mnay be capable o-f RGS. injecting into the CS during pum,- p swap. J 4-163 operation for E

15 mninute-s-.

Initiate action to *,,,,,,dt ,

verify a mnaximum of Eone] charging pump i-s-eaable-o-f injecting into the Be. An ECCS BG.1 Isolate affected ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months accumulator not accumulator.

isolated when the ICL3.4-163 ECCS accumulator pressure is greater than or R-9 equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

(continued)

WOG STS, Rev 1, 04/07/95 3.4.12-3 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureS-tem 3.4.12 r.--I]--l IR-9I ACTTONS (continued) !

CONDITION REQUIRED ACTION COMPLETION TIME CD. Required Action CI.1 Increase RCS cold leg 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated temperature to > the Completion Time of OPPS enable Condition B{C-- not temperature specified met. in the PTLR{2-o-5]F. ITA3.4-1191 OR CO.2 Depressurize affected 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ECCS accumulator to less than the maximum JCL3.4-163 RCS pressure for existing cold leg temperature allowed in the PTLR.

DE. One required DE.1 Restore required 7 days PORVRS relief PORVRS relief valve valve inoperable to OPERABLE status. ICL3.4-1631 i nMODE 4.

F. One r ,quircd R*S F.I Restore required RCS 24-+/-oura relief valve relief valve to inoperable in MODE 5 -s--4-167 OPERABLEs*a*u,*.

oro6.

(conti nued)

WOG STS, Rev 1, 04/07/95 3.4.12-4 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSysteffl 3.4.12 ACTIONS (continued) REQUIRED ACTION COMPLETION TIME R-91 AONDITIONu L -- -- - .i EG. Two required PORVsRGS-reel-i-e-f EG.1 Be in MODE 5. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months valves inoperable. IPA3"4-168 OR AND JCL3 .4-169 Required Action and E.2 Depressurize RCS and 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months associated Completion establish RCS vent of Time of Condition A, >_ 3E2.07] square ITA3.4-139 C, or f&7] D, E, or F inches.

not met.

OR OPPSTP*"System inoperable for any reason other than Condition A, [Ni] C, DEor F SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY pump is 12 ICL3 "4-163 SR 3.4.12.1 Verify a maximum of tone] SI-FJ4P capable of injecting into the RCS. hours

_ _ _ _ _ _ _ _ _ _ _ _ _ m

__,n *-163 SRi3.4.12.2 Verify a maximfumf of one charging pumflp is 2-capable of injecting into the RCS-.hor WOG STS, Rev 1, 04/07/95 3.4.12-5 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSystem 3.4.12 r--'---1 IR-9 SURVEILLANCE REQUIREMENTS (continued)

I L-i--

SURVEILLANCE FREQUENCY i

SR 3.4.12.23 ---------------- NOTE ----------------

Only required to be performed when ECCS accumulator pressure is greater than or equal to the maximum RCS pressure for the Ix3.4-171 existing RCS cold leg temperature allowed in the PTLR.

Verify each ECCS accumulator is isolated. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter R--.'IVerify ,, sution valve is open for each ,,o, required. RR suction relief valve. ZIiCL3.4-163 SR 3.4.12.5 NOTE Only required to be performed when complying with L*O 3.4.12.b.

Verify RCS*:vent 2.07] square inches ICL3.4163 e hours for unlocked open vent valv.e(s)

AND 3l days for locked openf WOG STS, Rev 1, 04/07/95 3.4.12-6 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperature 3.4.12 R

SR-9 I, SIIRVFTI IANCE REQUIREMENTS (continued) L i SURVEILLANCE FREQUENCY SR 3.4.12.36 Verify PORV block valve is open for each 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months required PORV.

T-n

-CL3.4-163sl

-SR 3.4. 12.7 Verify associated RR suction isolati, +*

valve is locked open ,it,,h aerat power days remnoved for cach, require, R,,I% suction relief valve.

SR 3.4.12.48 ----------------- NOTE---------------

Not required to be performedme- until JTA3.4-157 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to _<the OPPS enable temperature specified in the PTLR2q--]-+. TA3"4-119 31 days Perform a COT on OPPSeach required pORV, ICL3.4-162 excluding actuation.

(continued) cE3. 10--L-I_

J!

SR 3.4.12.59 Perform CHANNEL CALIBRATION for each OPPS 24f R-2 requ-ired ' actuation channel. +8I months - j LCL3.4-162

-L ____________________________

WOG STS, Rev 1, 04/07/95 3.4.12-7 Markup for PI ITS Part E

LTOP-RCSCLT _<SI Pump Disable Temperature 3.4.13 ,- -----

IR-9 L-3.4 REACTOR COOLANT SYSTEM (RCS) ICL3.4-172]

3.4.13 Low Temperature Overpressure Protection (LTOP)- Reactor Coolant System Cold Leg Temperature (RCSCLT)

Safety Injection (SI) Pump Disable R-9 i Temperature L ------ J LCO 3.4.13 LTOP shall be provided with: 1) no SI Pumps capable of injecting into the RCS; 2) the emergency core cooling system (ECCS) accumulators isolated; and 3) one of the following pressure relief capabilities:

a. An Over Pressure Protection System (OPPS) shall be OPERABLE with two pressurizer power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or

b. The RCS depressurized and an RCS vent of Ž 3 square inches.

--- -- -- -- -- --- ---NOT ES ........ .......

1. Both SI pumps may be run for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months while conducting SI system testing provided there is a steam or gas bubble in the pressurizer, the reactor vessel head is I I on, and at least one isolation valve between the SI I R-9 I

pump and the RCS is shut.

2. During reduced inventory conditions an SI pump may be run as required to maintain adequate core cooling and RCS inventory.

3. ECCS accumulator may be unisolated when ECCS R-9 accumulator pressure is less than the maximum RCS ..... ...... .

pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR.

APPLICABILITY: MODE 4 when any RCS cold leg temperature is < the SI pump disable temperature specified in the PTLR, 3.4.13-1 Markup for PI ITS Part E New Specification

LTOP-RCSCLT

SI Pump Disable Temperature 1 3.4.13 --

1 R-9, L.. . . ... -J MODE 5 when the steam generator (SG) primary system manways and pressurizer manway are closed and secured in position, MODE 6 when the reactor vessel head is on and the SG primary system manways and pressurizer manway are closed and secured in position.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both SI pump(s) A.I Initiate action to Immediately capable of injecting verify no SI pump is into the RCS. capable of injecting R-9 into the RCS.

I- i B. An ECCS accumulator B.1 Isolate affected ECCS I hour not isolated when the accumul ator.

ECCS accumulator R-9 pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

________________________ .1___________________________ J _______________

(conti nued)

New Specification 3.4.3-2 Markup for PI ITS Part E

LTOP-RCSCLT < SI Pump Disable Temperature 3.4.13 r-- -1 R-9 L-ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. Increase RCS cold leg 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion temperature to > the Time of Condition B OPPS enable not met. temperature specified in the PTLR.

OR C.2 Depressurize affected 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ECCS accumulator to less than the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

D. ------ NOTE ----- D.1 Restore required PORV 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Only applicable to OPERABLE status.

in LCO 3.4.13.a One required PORV inoperable.

(continued)

New Specification 3.4.13-3 Markup for PI ITS Part E

LTOP-RCSCLT

SI Pump Disable Temperature 3.4.13---

1R-9 L

ACTIONS (con t "ued)

CONDITION REQUIRED ACTION COMPLETION TIME E Two PORVs inoperable for LCO 3.4.13.a. E.1 Depressurize RCS and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months establish RCS vent of OR Ž 3 square inches.

Required Action and associated Completion Time of Condition A, C, or D not met.

OR OPPS inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 Verify no SI pumps are capable of injecting 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months into the RCS.

SR 3.4.13.2----------------- NOTE-------------------

Only required to be performed when ECCS accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR.

Verify each ECCS accumulator is isolated. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter New Specification i3.ii4.!i13-4*i NMarkup for PI ITS Part E

LTOP-RCSCLT

SI Pump Disable Temperature 3.4.13 I I R-9, I- - - -

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.13.3-------------------NOTE---------------

Only required to be performed when complying with LCO 3.4.13.b.

Verify required RCS vent Ž 3 square inches 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for open. unlocked open vent valve(s)

AND 31 days for other vent path(s)

SR 3.4.13.4 Verify PORV block valve is open for each 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months required PORV, R-9 SR 3.4.13.5 ------------------- NOTE -----------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to . the OPPS enable temperature specified in the PTLR.

2. Only required to be performed when complying with LCO 3.4.13.a.

31 days Perform a COT on OPPS.

New Specification 3.*4.13-5 Markup for PI ITS Part E

LTOP-RCSCLT -SI Pump Disable Temperature 1 3.4.13 -----

R-9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.13.6 Perform CHANNEL CALIBRATION for OPPS actuation channel. 24 months New Specification 3.4. 13- 6 Markup for P1 ITS Part E

RCS Operational LEAKAGE 3.4.143 I

SURVEILLANCE FREQUENCY SR 3.4.143.1 ------------------

NOTE---------------- -NOTE Gtl'*l Not required to be performed in MOBE 3 or 4 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation. dto be perf~rmfe-d during steady Verify RCS operational leakage within e ITA3.4-177 I limits by performance ofPerfoifm RCS water oper 0

inventory balance. at ion

-1CL3.4-331

-- 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1-R-9 1 L_ --- I SR 3.4.143.2 Verify steam generator tube integrity is in In accordance with the Steam Generator--T-ube accordalPA3.4-1799 Surveilla Program. nce with the Steam GeneratorrTube Survei 11 ance Program WOG STS, Rev 1, 04/07/95 3.4.14-3 Markup for PI ITS Part E

RCS Specific Activity 3.4.176 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.176 RCS Specific Activity LCO 3.4.176 The specific activity of the reactor cool ant shall be within limits.[

I I IR-9 I !

L APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (Tvg) Ž 500'F.

ACTTONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT 1-131 -- -- -- Note--------- ---

F----l-I

> 1.0 pCi/gm. LCO 3.0.4 is not applicable.

R-9 A.1 Verify DOSE Once per EQUIVALENT 1-131 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months within the acceptable region of Figure 3.4.176-1.

AND A.2 Restore DOSE EQUIVALENT 1-131 to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months within limit.

WOG STS, Rev 1, 04/07/95 3.4.17-1 Markup for PI ITS Part E

RCS Specific Activity 3.4.176 CONDITION. REQUIRED ACTION COMPLETION TIME ACTIONS (continued) __

B. Gross specific h.f

-) A 1 r Per'Tfuiff -SiR 3.-4-16.,

1) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months activity of the reactor coolant not ITA3.4-201 within limit.

B.1Z Be in MODE 3 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Tavg 5000F.

__ _ _ _ __ __ _I__ _ _ L _ _ _ _ _ _ __ _ _ _ _ _ _

(continued)

C. Required Action and C.1 Be in MODE 3 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Tavg < 500'F.

Time of Condition A not met.

OR DOSE EQUIVALENT 1-131 in the unacceptable R-91 region of L -

Figure 3.4.176-1.

I _________________________ -, _______________

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.176.1 Verify reactor coolant gross specific 7 days activity

IO0/E gCi/gm, 3.4.17-2 Markup for PI ITS Part E WOG STS, Rev 1, 04/07/95

RCS Specific Activity 3.4. 176 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

-I SR 3.4.176.2 -------------------

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

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 14 days 1-131 specific activity

1.0 MCi/gm.

AND Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of

> 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period I_______________________________

(continued)

SR 3.4.176.3 -- NOTE----------------

Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for Ž 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine P from a sample taken in MODE 1 184 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for : 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

I. __________________________ R-9 L ..... .

WOG STS, Rev 1, 04/07/95 3.4.17-3 Markup for PI ITS Part E

RCS Pressure, Temperature, and Flow - DNB Limits B 3.4.1 IPA3*4-11 PA3.4-211 to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate.

This verification may be performed via a precision calorimetric heat balance or other means.

The Frequency of 24{-1E-8 months reflects the importance of verifying flow after a refueling outage when the core has been altered, which may have caused an alteration of flow resistance.

This SR is modified by a Note that allows entry into MODE 1, without having performned the SR, and placement of thce uni't iin the best condition for pcrformfing the SR. The Note statesa that the SR is not required to be performfed until 24 hour-s after E90%]

[ R"P. This exception is appropriate since the "heat balanc... i... es the plant to be at CL3.4-104 BASES SURVEILLANCE SR 3.4.1.34 (continued)

REQUIREMENTS a minimum of E90%]l RIP to obtain thc stated RCS f olow Iaccuraies. The Surveillance shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching [90%.] RTIP.

I II R-9 L -.. .

REFERENCES 1. UFSAR, Section 14{+/-S-1-.

WOG STS, Rev 1, 04/07/95 B 3.4.1-7 Markup for PI ITS Part E

RCS P/T Limits B 3.4.3 IPA3.4-2111 BASES ACTIONS A.1 and A.2 (continued) required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including an engineering evaluation to determine effects of the out-of-limit ICL3.4-3291 condition on the structural integrity of the RCS, a comparison with pre-analyzed transients in the stress i.......

analyses, new analyses, or inspection of the components. I R-9 I L - - - --

ASME Code,Section XI, Appendix E(Ref-,. ,)-, may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable to accomplish the evaluation. The evaluation for a mild violation is possible within this time, but more severe violations may require special, event specific stress analyses or inspections. A favorable evaluation must be completed before continuing to operate.

Condition A is modified by a Note requiring Required Action A.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action A.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.

B.1 and B.2 If a Required Action and associated Completion Time of Condition A are not met, the plant must be placed in a lower MODE because either the RCS remained in an unacceptable P/T region for an extended period of increased stress or a (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.3-6 Markup for PI ITS Part E

RCS Loops-MODE 3 B 3.4.5 BASES IPA3.4-211i LCO The purpose of this LCO is to require that botha-t--eas-t

{twe] RCS loops be OPERABLE. In MODE 3 with the Rs- irn the closed position and Rod Control System capable of rod withdrawal, both{+/-wej RCS loops must be in operation. {Two RCS loops are required to be in operation in MODE 3 with theRTBs closed and Rod Control System capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the transient analysis acceptanceS-aey L--Hml-t criteria will be met for all of the postulated ac"idents.

WhenWith the RTBs in the open position, or the *,*,Ds TA3.4-118 de energized-,- the Rod Control System is not capable of rod withdrawal -therefore, only one RCS loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. An additional RCS loop is required to be OPERABLE to ensure redundant capability for decay heat removal that safety ICL3.4-227I analyses limits are meIt.

The Note permits both&-I- RCPs to be de-energized for

< 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period to perform preplanned ICL341171[

work activities. R-9 L - I OneThe purpose of the Note is to allow performance of tests that are designed to validate various accident analyses values. One of these tests is validation of the pump IPA3.4-2281 coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test was+-i generally performed in MODE 3-during the initial startup testing program, and would normallyas such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input LCO values of the coastdown curve must be revalidated by (continued) conducting the test again. Another test performed during (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.5-3 Markup for PI ITS Part E

RCS Loops-MODE 3 B 3.4.5 BASES IPA3.4-2111

.oncentration distribution throughout the RCS cannot be ens d when in natural circulation (Ref.. 1); and

b. Core outlet temperature is maintained at least 10OF below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

An OPERABLE RCS loop consists of one OPERABLE RCP IPA3.4-2321 and one OPERABLE SG in accordance with the Steam - I Generator lube Survillance Program, which is CL3.4-121I capable of removing decay heat as has the miimum*,,,

water leve specified in SR 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and is able to provide,- r..- 1 forced flow if required. ----i APPLICABILITY In MODE 3, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. The most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with the Rod Control ITA3.4_1181 System capable of rod withdrawaRT-s, in t. he APPLICABILITY closed position. The least stringent condition, that is, (continued) two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawapRoin Bs otphen.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.5-5 Markup for PI ITS Part E

RCS Loops-MODE 3 B 3.4.5 BASES IPA3.4-2111 withdrawalSuspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core; however, coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loops are in operation. Verification may includes flow rate, temperature, ora-nd pump status monitoring, which helps ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop performance.

SR 3.4.5.2 SR 3.4.5.2 requires verification that the SG has the capability to remove decay heat. The ability to remove decay heat requires the ability to IcL3"4-121 pressurize and control pressure in the RCS, sufficient secondary side water level in the SG relied on for decay heat removal, and an available supply of feedwater (Ref. 2). o S OPERABLT, SG OPERABLTY is v by ensuring that the secondary side narrow range water level is t 17]9, forreuie RCS loops. if the SG secondary side narrow range water level is [17jr*,The ability of the SG to provide an adequate heat sink for decay heat removal further ensures that the SG tubes remain covered. may- becoie R-9 (continuedý .....

WOG STS, Rev 1, 04/07/95 B 3.4.5-8 Markup for PI ITS Part E

RCS Loops-MODE 3 B 3.4.5 BASES IPA3.4-2111 unovered and the associated loop may not be capable of providing the heat sink for removal of the decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of the other indications available in the control room to alert the operator to a loss of the SG to remove decay heat leel.

R3.R-9.5 SR 3.4.5.3 Verification that eacht-he required RCPs a-reis OPERABLE TA3.4-125 ensures that safety analyses limits are met. The requiremen, also ensures that an additional RCP can be CL3.4-227 placed in operation, if needed, to maintain decay heat removal and reactor cool ant circulation. Verification is performed by verifying proper breaker alignment and power availability to eachthie required RCP5. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability.

This SR is modified by a Note that states the SR is not ITA3.4-1251 required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is not in operation.

REFERENCES 1. License Amendment Request Dated November 19, 1999. ICL3.4-1171 None) (Approved by License Amendment 152/143, July 14, 2000.)

2. NRC Information Notice 95-35, "Degraded ICL3.4-121 7i Ability of Steam Generators to Remove Decay Heat by Natural Circulation."

I L R-9 WOG STS, Rev 1, 04/07/95 B 3.4.5-9 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6 IPA3.4-211 BASES APPLICABLE In MODE 4, RCS circulation increasesis considered in the CL3.4-237 SAFETY ANALYSES determination of. the time available for mitigation of antiie accidental boron dilution event. The RCS and RHR loops provide this circulation.

RCS Loops- MODE 4 have been identifi'ed in the NRC Policy Statement as important contributors to reduetei-onsatisfies Criterion 4 of 10 CFR 50.36(c) (2) (ii).

LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS LCO loops and RHR loops. Any one loop in operation provides (continued) enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

Note 1 permits all RCPs or RHR pumps to be de-energized I for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note F__I_

is to permit tests that are designed to validate various R-9 1, 1L ------

accident analyses values. One of the tests performed during the startup testing program was-s--the validation of lpA3.4_2281 rod drop times during cold conditions, both with and without flow. If changes are made to the RCS that would cause a change in flow characteristics of the RCS, the input values must be revalidated by conducting the test again.

Any future-The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits stoppingthe de.ener.izi,,

e-f the pumps in order to perform this test and validate the assumed analysis values. if changes are made to the RC that would cause a change to the flow (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.6-2 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6 IPA3.4-211l BASES An OPERABLE RCS loop consists ofeempis-es an OPI ERABLE RCP and an OPERABLE SG in accordane with the te,,

Generator Tube IPA3.4-2321 LCO urvci I anec Irograff, wMl C[ i s capdaJb l e TlIIIUV I Irin decay heat ashas the mlinimum water level ICL3. I (continued) specified in SR 3.4.6.2. 4-121 Similarly for the RHR System, an OPERABLE RHR loop consists R-9 oftesmprise an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE if they are capable of being powered and are able to provide forced flow if required.

APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of either RCS or PA3.4-238 R"R provides sufficient circulation for these purposes.

However, two loops consisting of any combination of RCS and RIlR loops are required to be OPERABLE to m.eet single failure considerations.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.6-4 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6 IPA3.4-211 BASES ACTIONS A.1 TA3.4-330 If one required-RC- loop is inoperable and two RI¥ R loops are inoperable, redundancy for heat removal is lost.

R-9 Action must be initiated to restore a second RCS or RHRI loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. Entry to a reduced MODE IpA3. S-2391 (MODE 5 or 6) requires RHR availability for long term decay heat removal. Remaining in MODE 4, with RCS loop operation, is conservative.

B4 I1A3.4-330 ]

If one required R1R loop is OPERABLE and in operation and there are no RCS loops OPERABLE, an inoperable RCS or R"R ACTIONS Bi (continued) loop must be restored to OPERABLE status to provide a redundant means for decay heat remo.val.

If the parameters that are outside the limits cannot be res-tredIf restoration is not accomplished and an RHR Loop is OPERABLE, the unit must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative I I R-9 action with regard to decay heat removal. With only one I I RHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop it would be safer to initiate that loss from MODE 5

(-:tn200F)-rather than MODE 4 (200 to 35**04). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on I I operating experience, to reach MODE 5 from MODE 4 in an R-9 L ---- J orderly manner and without challenging plant systems.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.6-5 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6 IPA3.4-211I BASES The Required Action is modified by a Note which {TS3.4-330 indicates that the unit must be placed in MODE 5 only if a RHR loop is OPERABLE. With no R-R loop OPERABLE, the unit is in a condition with only limited cooldown capabilities. Therefore, the actions are to be concentrated on the restoration of a RHR loop, rather than a cooldown of extended duration.

ITA3.4-330

£B.1 and GB.2 L3113 If both" loops is OPERAB**are inoperable or a required loop not in operation, except during conditions permitted r __..... I by Note 1 in the LCO section, all operations involving e I R-9 I I.

red+/-uct-ionintroduction of coolant into the RCS with boron L4-1!

concentration less than required to meet the minimum SDM iTA3 of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and tThe margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation.

With coolant added without forced circulation, unmixed coolant could be introduced to the core; however, coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.6-6 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6 IPA3.4-2111 BASES

[TA3 .4-330::

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that enethe required RCS or RHR loop is in operation. Verification may includes flow rate, temperature, or pump status IR-9 monitoring, which helps ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

SURVEILLANCE SR 3.4.6.2 REQUIREMENTS (continued) SR 3.4.6.2 requires verification &fthat the required SG has the capability to remove decay CL3.4-121 heat. The ability to remove decay heat requires the ability to pressurize and control pressure in the RCS, sufficient secondary side water level in the SG relied on for decay heat removal, and an available supply of feedwater (Ref. 2). The ability of the SG to provide an adequate heat sink for decay heat removal further ensures that the SG tubes remain covered. OPER,,AB.IITY. +-SG OP[RABILITY is veri-fied by cnsuringý that. the seeo ndary sidc narrow range wat.*er level is > [17]%. If the SG seondary te may side narrow range water level is th-4r,.

become uncovered and the associated loop may not. be apab* y of providing the heat sink necessary for removal of decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of the other indications available in the control room to alert the operator to thea loss of capability of the SG to remove decay heatleve+/-.

R-9 (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.6-7 Markup for PI ITS Part E

RCS Loops-MODE 4 B 3.4.6

[PA3.4-211 BASES SR 3.4.6.3 Verification that eacht-te required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in I I operation, if needed, to maintain decay heat removal and [A.4125 reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to eacht-he required pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not ITA3.4-1251 required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is not in operation.

ICL3.4-1171 REFERENCES 1. License Amendment Request Dated November 19, 1999.

Noee. (Approved by License Amendment 152/143, July 14,

.2000.)

2. NRC Information Notice 95-35, "Degraded Ability of Steam Generator to Remove Decay Heat by Natural Circulation." ICL3.4-12

R-9 WOG STS, Rev 1, 04/07/95 B 3.4.6-8 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-211 BASES (continued)

LCO is to require that a second path be available to provide redundancy for heat removal.

The LCO provides for redundant paths of decay heat removal capability. The first path can be an RHR loop that must be OPERABLE and in operation. The second path can be another OPERABLE RHR loop or maintaining at-we SGm capable TA3.4-2461 of removing decay heat with sccondary sid wot, I levels above-[H-- to provide an alternate method CL3.4-121 j for decay heat removal via natural circulation. ......

R-9 APPLICABLE In MODE 5, RCS circulation increasesis considered in the SAFETY ANALYSES determination of the time available for mitigation of CL3.4-237 antlhe accidental boron dilution event. The RHR loops provide this circulation.

RCS Loops -MODE 5 (Loops Filled) have been identified in the NRC Policy Statement as important contributors tc risk

'e-duie-t-ionsatisfies Criterion 4 of 10 CFR 50.36(c) (2)(ii).

LCO The purpose of this LCO is to require that at least one-of thee RHR loop& be OPERABLE and in operation with an additional RHR loop OPERABLE or atwo SG- capable of removing decay heat via natural circulationwith sccondar L3y121 S....

side water level > [17.'.. One RHR loop provides sufficient forced circulation to perform the safety R-9 functions of the reactor coolant under these conditions. .....

to An additional RHR loop is required to be OPERABLE provide redundancymect single failure considerations.

However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is atw" SGs with their TA3.4 -246 !

secondary side water levels - [171%W. Should the operating RHR loop fail, the SG* could be used to remove-the decay heat via natural circulation.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.7-2 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-211]

BASES (continued)

Note 1 permits all RHR pumps to be de-energized < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests designed to validate various accident analyses R-9 One of the tests performed during the startup ..............

values.

testing program was-s-t-he validation of rod drop times __________

Jf PA3.4-228 during cold conditions, both with and without flow.

changes are made to the RCS that would cause a change in flow characteristics of the RCS, the input values must be revalidated by conducting the test again. Any future-The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits stoppingde-encrgizing of the pumps in order to perform this test and validate the assumed analysis values. If changes are made to the RS that wou cause a change to the flow haracteristies of the S,, te "input values must be revalidated by onducting the, test again. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.

Utilization of No.te 1 is permitted provided the following conditions are met, along with any other conditions JPA3.4-228 imposed by initial startup test procedures:

LCO a. No operations are permitted that would dilute the RCS (continued) boron concentration with coolant with boron ITA3.4-1151 concentration less than required to meet SDM of LCO 3.1.1, therefore maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained is prohibited to preclude the need for a boration, due to the time required to achieve be-auseCL3.4-117 a uniform *,,cntration distribution throughout th RGS cannet be ensured when in natural circulation (Ref. 2); and (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.7-3 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-211 BASES

b. Core outlet temperature is maintained at least 10'F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

Note 3 requires a steam or gas bubble in the pressurizer ICL3.4 or that the secondary side water temperature of each SG be

< [50]-F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold,]TA3.4-119 specified leg temperature _<the OPPS enable temperature in the PTLR22 F. A steam or gas bubble ensures that the pressurizer will accommodate the swell resulting from an RCP start. Either of these restraintsThis restrition is to prevents a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being ITA3.246[

powered and are able to provide flow if required.

A SG is capable of removing decay heat via natural [PA3.4-232 circulation when: 1) there is the ability to IC 3 i2i pressurize and control pressure in the RCS; 2) there is sufficient secondary side water level in the SG (continued) R-9 WOG STS, Rev 1, 04/07/95 B 3.4.7-4 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-2111 BASES relied on for decay heat removal; and 3) there is an available supply of feedwater (Ref. 1). An OPERABLE SG can perform as a heat sink via natural circulation when it has an adeqta the capability to remove decay heat as wa-ter level and is OPERABLE in accordance with the Steam Generator Tube Surv'eillance Progra specified in SR 3.4.7.2.

R-9 APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes.

However, one additional RHR loop is required to be OPERABLE, APPLICABILITY or the secondary side water level of at least r-..twoL SGs- is (continued) capable of removing decay heatrequired to be > [!7]o.

1o7 3.4-121 Operation in other MODES is covered by: R-9 LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

ITA3.4-330 ACTIONS A.1. afnd A.2. B.1 and B.2 ICL3.4-121 If one RHR loop is inoeeerab1eOPERABLE and the required SGs are not capable of removing decay heat-a-ye secondary side water level-s-<E!7],-o, redundancy, for heat removal is lost. Action must be initiated immediately to R-9 L--

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.7-5 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-2111 BASES (continued) restore a second RHR loop to OPERABLE status or to restore the required SG capability to remove decay heatseeondary side water levels. Either Required Action A.! or Required Aetion A.2 will restore redundant heat removal paths.

The immediate Completion Time reflects the importance of R-9 maintaining the availability of two paths for heat L----- j removal.

BC.1 and BC.2 If rrea required RHR loop is not in operation, ITA3"4-330 ]

except during conditions permitted by Note 1, or r ..... I if no loop is OPERABLE, all operations involving TA3.4-115 I R-9 L.

a-redtetio"introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. To prevent boron dilution, forced circulation is required to o...de proper mixing and preserve the m.argin to criticality in this type of oprton Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation.

With coolant added without forced circulation, unmixed coolant could be introduced to the core; however, coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Times reflect the importance of maintaining operation for heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loop is in operation. Verification may includes flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other WOG STS, Rev 1, 04/07/95 B 3.4.7-6 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 IPA3.4-211]

BASES (continued) indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.7.2 ICL3.4-121 SR 3.4.7.2 requires verification that the required SG has the capability to remove decay heat via natural circulation. This provides an alternate decay heat removal method in the event that the second RHR loop is not ITA3.426 OPERABLE. The ability to remove decay heat requires the ability to pressurize and control pressure in the RCS, sufficient secondary side water level in the SG relied on for decay heat removal, and an available supply of feedwater(Ref. 1). Verifying that at least two SGs are OPERABLE by ensuring their seondary side narrow range wat.r, levels are t [171% ensures an alternate de.ay heat rem..oval method in the event that the second R1iR l*oop is not OERABLLE. ifbIothl111R loops are OPERABLE, this Surveillance is not need*d. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available lR-9 in the control room to alert the operator to a+4me loss of L ......

capability of the SG to remove decay heatlevel..

r ----- i 1R-9 1 L ..... J SR 3.4.7.3 Verification that each requireda seeond RHR pump is I -125 OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to thieeach required RHR pump. Alternatively, verification that a pump is in operation also verifies proper breaker alignment and power availability. If seeondary-si-de, l i [o In at least one-wo SGs- is CL3.4-121 capable of decay heat removal, this Surveillance is not needed. The Frequency of 7 days is considered --

reasonable in view of other administrative controls R-9 I L -.--- J WOG STS, Rev 1, 04/07/95 B 3.4.7-7 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Filled B 3.4.7 SI21 BASES (continued) available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not ITA3.4-1251 required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is not in operation.

"Degraded ICL3.4-121 REFERENCES 1. NRC Information Notice 95-35, Ability of Steam Generators to Remove Decay Heat by Natural Circulation"+4ofte. I I TA3.4-246 SR-9 '1 L -- -

ICL3.4-I17

2. License Amendment Request Dated November 19, 1999. (Approved by License Amendment 152/143, July 14, 2000.)

WOG STS, Rev 1, 04/07/95 B 3.4.7-8 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 IPA3.4-211]

BASES LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation to!

An OPERABLE loop is one that has the capability of transferr+/-ftg heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used. A minimum of one operatingrunning RHR pump meets the LCO requirement for one loop in operation.

An additional RHR loop is required to be OPERABLE to provide redundancyiymeet single failure consideratins.

LCO Note 1 permits all RHR pumps to be de-energized for (continued) < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period 15 minutes when"CL3.4-131I Swi tching fro.oe.oo.t.aoter The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short tand R-9 core outlet temperature is maintained > 10OF belowR J saturation temperature+. The Note prohibits boron ITA3.4-1151 dilution with coolant at boron concentrations less than required to assure SDM is maintained or draining operations when RHR forced flow is stopped.

Note 2 allows one RHR loop to be inoperable for a period of S2 hours, provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.8-2 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled B 3.4.8

[PA3.4-211 BASES APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

ACTIONS A. 1 TA3.4-330 If orft3y one required RHR loop is inoperable OPERAB'LE- af, Action must- ------- 1 in poera-,n, redundancy for RHR is lost.

be initiated to restore a second loop to OPERABLEthe iR-9 L ------ J status. The immediate Completion Time reflects importance of maintaining the availability of two paths for heat removal.

ACTIONS B.1 and B.2 [TA3.4-330 (continued)

If no required RI+R loops areis OPERABLE or the required loop is not in operation, except during conditions permitted by ---------

Note 1, all operations involving a reduttioftintroduction IR-9I of coolant into the RCS with boronto meet the T L-.

concentration less than required minimum SON of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires fored circulat,*ion for uniform dilution, and tThe margin to criticality must not be reduced in this type of operation.

WOG STS, Rev 1, 04/07/95 B 3.4.8-3 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 IPA3.4-211 BASES Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core; however, coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

I -132 The Note in Required Action B.2 allows the use of one safety injection pump to provide heat removal in the event of a loss of RHR system cooling during reduced RCS inventory conditions.

SURVEILLANCE SR 3.4.8.1 TA3.4330 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that o-fethe required loop is in operation. Verification may include-a flow rate, temperature, or pump status,

',R-9 monitoring, which helps ensure that forced flow is L.------.

providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.8.2 Verification that eachtme required number of pumps isa-re OPERABLE ensures that an additional pump-- can be placed in TA3.4-1251 operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to th-eeach required pumps-. Alternatively, verification that a pump is in operation also verifies proper breaker alignment WOG STS, Rev 1, 04/07/95 B 3.4.8-4 Markup for PI ITS Part E

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 LPA3.4-211 BASES and power availability. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

This SR is modified by a Note that states the SR is not TA3.4-1251 required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a pump is not in operation.

REFERENCES None.

WOG STS, Rev 1, 04/07/95 B 3.4.8-5 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-t-em B 3.4.12 I R-9 1 ICL3.4-162 CL3.4-271 I -211 L -1 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.12 Low Temperature Overpressure Protection (LTOP) - Reactor Coolant System Cold Leg Temperature (RCSCLT) > Safety Injection (SI)

Pump Disable Temperature I I IR-9 L ------ J BASES BACKGROUND The LTOP function limitsSyste,, controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. The Over Pressure Protection System (OPPS) and the pressurizer power operated relief valves (PORVs) provide the LTOP function (Ref. 2). The PTLR provides the maximum allowable OPPS actuation logic setpoints for the power operated relieff valve-s PORVs- and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Reference I requirements during the LTOP MODES. The LTOP MODES are the MODES as defined in the Applicability statement of LCO 3.4.12 and LCO 3.4.13.

I 272 The pressurizer safety valves and PORVs at their normal setpoints do not provide overpressure protection for certain low temperature operational transients. Inadvertent pressurization of the RCS at temperatures below the OPPS enable temperature specified in the PTLR could result in exceeding the ASME Appendix G (Ref. 3) brittle fracture P/T limits.Thc reactor vessel material is less tough at low temfperatures than at normal operating teniperature. As the vessel neutron exposure accumulates, the material toughness decreases and becoems less resistant to pressure stress at low temperaturcs (Ref. 2). RIS pressure, therefore, is mfaintained low at low tefflperatures and is increased. only as temiperaturc is increased.

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-1 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperature~ys-t-eI B 3.4.12 1

, R-9 1 ICL3.4-162 CL3.4-271 PA3.4-2111LL-------

BASES The potential for vessel v..pr.s.urization is most a.ute when the RlS is water solid, occurring onlI y while 3hutdown*;

pressure fluctuation can occur more ta an Uuickly operator can ,c t relieve the.ondition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the PTLR limits.

This LCO provides RCS overpressure protection by ICL3.4_163 restrictinghaving a minimum coolant input capability and ensuringbh n adequate pressure relief capacity. In MODE 4, above the safety injection (SI) pump disable temperature, lLimiting coolant input capability requires all--btt tone+/-

[high pressure injection (SIHP-I-)-+/- pump [and oneca p-mpfi--incapable of injection into the RCS and isolating the emergency core cooling system (ECCS) accumulators.--he pressure relief capacity requires either two redundant RS relief valves or a d sua an RS vent of sufficient size. In MODE 4, above the SI pump disable temperature, o~ne PORVRGS relief valve or the open RGS vent is the overpressure protection device that acts to terminate an increasing pressure event.

BACKGROUND With minimum Limiting coolant input capability reduces the ability to (continued) provide core coolant addition is rcstriet*d. The LCD does not require the makeup control system deactivated or the safety injectIon (SI- actuation circuits blocked. Due to the lower pressures in the LTOP MODES and the expected core decay heat levels, the chargingmaketil system can provide adequate flow via the ,akeup control valve. If conditions require the use of more than one S-EFI oI]-ehargAngpump for makeup in the event of loss of inventory, then pumps can be made available through manual actions.

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4. 12-2 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSyste B 3.4.12 1. .

1R-9 ICL.4-62]CL3.4-27 FA3.4-1 L---

BASES The LTOP System for In MODE 4, above the SI pump disable temperature, pressure relief consists of two PORVs with reduced lift settings, or two residual heat removal (HRI,)C.4-272 P

oil.nn r a d o ne- ...

su -tin suction relief valves, or relief valve, or a dpessrie ,CS and an RCS vent of sufficient size. Two PORVs RCS relief valves are required for redundancy. One PORVRCS relief valve has adequate relieving capability to preventkeep-fi-m overpressurization for the required coolant input capability.

P,,OR Reau,,.emen-s As designed for the LTOP functiony st-em, each PORV is signaled to open by OPPS if the RCS pressure approaches the lift setpoint provided when OPPS is enableda limit det* r by the LTOP actuation logic.

ined The OPPSL-TG.

actuation logic monitors both RCS temperature and RCS pressure and indicates dete-rmi-nes when a condition not acceptable in the PTLR limits is approached. The wide range RCS temperature setpoints indicate conditions requiring enabling OPPSions are auctioneered to select the lowest temperature signal.

-The lowest tperature s l i pr oessed through function generator that calculates a pressure limit for that temperature. The calculated pressure limit is then om.pa.re with indicated nCS pressure from a wide range pressure channel . If the indicated pressure meets. o ...... the alculated value, a tOR,, is signaled to open.

The PTLR presents the OPPSPGRV- setpoints for LTOP. The stpoints are normally staggered so only one valve opens during a low .te..peratr overpressure transient. "aving the setpoints of both valves within the limits in theTl ensures that the Reference 1 limits will not be ex...... i any, analyzed event.

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-3 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperature*ys-em B 3.4.12 ,.

1 .

1R-9 ic,.462[CL3.4-271 PA3.4-211L BASES When a PORV is opened in an increasing pressure transien."

the release of will cause the pressure increase to

,oolant slow and reverse. As the PORV releases e-oxant, the RC pressure decreases until is reahed and the valve is signaled to close. The pressre ontiu,,Les to decrease below the reset pressure as the valve closes.

"R"R Suction Relief Valv" CL3.4-272 During L-TOP MODES, the R1R, System11 is Operated. for decay--heat remfoval and low pressure letdown control. There fore-,-the RIIR suction isolation valvesaropnithppngfmte RCS hot legs to the inlets of the RIR pumps. While these valves are open and the R,,R suction valves are open, the RnuR suction relief valvesaeepsdt h C n r bet reli-eve- pressure it.ransients in the RCS.

The R*,R suction isolation valves and the RUR su.tion valves "must be open to mlake the R"R suction relief valves OPE ABLE for RGS overpressurelmitigation. Autoelosure interlocks are not permlitt*d to eause the lnHR suction isolation valves to elose. The Ri-R su.tion relief valves are spring loaded, bellows type wa*er relief valves with pressure toleranc and accumfulation limfits established by Section H!I of the American Society of Mechanical Engineers (ASME) 'ode (Ref. 3) for Class 2 relief valves.

V,,,n,,, R .,,

RCS Vent CL3.4-272 Once the RCS -ISdepressuI I U , aL-Vnt, exposed U to the eontainment atmnosplhere will maintain the RCS at containmenft amnbient pressure in an RCS overpressure transient, if the (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-4 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSysteff F 1 I

B 3.4.12 3 R-9 A IC3.-12]CL3.4-271][PA3.4 BASES relieving .requ.r.ments of the transient do not exceed the S.apa*ilitie of the vent.

Thus the vent path m.ust b capable of relivn th lw euting from the limtin LOP mass or heat input transic,,, and ma, tining pressure below the T t h ircd vent cap-at my provided br lev..ent- pathls.

Fo n C vn to, m tefow

,,t capacity requirement. it requires removing a pressurizer saet valve, removing ,

PIRV' s internalss, an di ng ts block valve in the open. .

pos-itin oI similarly establishing a vent by opening an ROS vent valve. The vent-pahs mu(st be a e h. *level of reactor coolant, so as not to drain the R.S when open.

APPLICABLE Safety analyses (Ref. 24) demonstrate that the reactor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference 1 ITA3.4_1191 P/T limits. In MODES 1, 2, and 3, and in MODE 4 with RCS T cold leg temperature exceeding the OPPS enable temperature specified in the PTLRTh5jIVF, the pressurizer safety valves will prevent RCS pressure from exceeding the Reference 1 limits. At about the OPPS enable temperature specified in the PTLR2-5*,°F and below, overpressure prevention falls to two OPERABLE PORVsRC2 relief valves or to a depressurized RCS and a sufficiently sized RCS vent. Each of these means has a limited overpressure relief capability. LCO 3.4.13, "LTOP < SI Pump Disable Temperature," provides the ........ I S requirements for overpressure prevention at the lower temperatures.

The actual temperature at which the pressure in the P/T limit curve falls below the pressurizer safety valve (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-5 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSyste B 3.4.12 ,1 R-9 1 ICL3.4-162 lCL3.4-271R9PA3.4-2111L -------

BASES setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the PTLR curves are revised, t-he--LTOP System--must be re-evaluated to ensure its functional requirements can still be met using the PORVRGS relief valve method or the depressurized and. -272 vented RCS eonditiont.

The PTLR contains the acceptance limits that define the LTOP requirements. Any change to the RCS must be evaluated against the Reference 24 analyses to determine the impact of the change on the LTOP acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients.- The bounding mass input transient exampls lC3-272 of whih follow:

Iiass Inout TJI e Transients

a. is i-Inadvertent safety injection; oer

-b-.with injection from one SI pump and three c--Gharging pumps, and Jletdown isolatedflow mismfal ,.

The bounding heat input transient is I I* _.l- T .... 4. T.

APPLICABLE S.

. .. .r' - o " .

T~

~

SAFETY ANALYSES (continued) a. inadvertent actuatior R'.f A.VrQQ -r 4 :7.0V hti ; or -

b. Loss of R,,R cooling; or

e. rReactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following limitations are required during the JCL3.4-2721 Applicability of this specification LTOP MODES to ensure (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-6 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-t-ef B 3.4.12 1. .

i R-9 BAJSES CL3.4-271 PA3.4- L BASES that mass and heat input transients in excess of analysis assumptions do not occur, which either of the LTOP overpressure protection means cannot handle:

a. Rendering all but -[one] f{-HSI- pump [and one charging pm-p]--incapable of injection;

b. Deactivating the ECCS accumulator discharge isolation valves in their closed positions; and

c. Disallowing start of an RCP if secondary temperature is more than 5O-0 °F above primary temperature in any one loop. LCO 3.4.6, "RCS Loops-MODE 4," ea-d L'O 3.4.7, "RCS Loops- MODE 5, Loops Fill1e-d," provides this protection.

The Reference 24 analyses demonstrate that either- one CL3.4-272I PORVRCS relief valve or the depressurized RS and RCS venwt--can maintain RCS pressure below limits when only one S{-4PI1- pump {and alleo-e charging pumps arel-i-& {-[re]

actuated. Thus, the LC0 allows only -one] S{-H-I] pump tan-d one chargin*-pu*mp] OPERABLE during the Applicability of this speci fication.,-OP-MODE.

Since neithe-rone PORVP\S relief valve nor the RS vent cannot handle the pressure transient resultinggneed from ECCS LCO accumulator injection, when RCS temperature is low, the also requires ECCS t4'te-accumulatora isolation when ECCS accumulator pressure is greater than or equal to the R-9 maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR.

The isolated ECCS accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions. ,L3.4-272show the effect Of The analyses accumulator discharge is oVer a narrower RCS tempecatiure (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-7 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperature~yS-týem B 3.4.12 ,. . .

. R-9 1 3.4-162 CL3.4-271][PA3*4-2111L ------ 3 BASES range [175] 0 F and below) t-an that of the LCO (E275]F and APPLICABLE Hleat it. Tr...ints (Innn Fracture mechanics analyses established the temperature of TA3.4-119 LTOP Applicability at the OPPS enable temperature specified in the PTLR[j2Th1S9F.

The consequences of a small break loss of coolant accident (LOCA) in LTOP MODE 4 above the SI pump disable temperature conform to 10 CFR 50.46 and 10 CFR 50, Appendix K +Ref*fsý and 6)--, requirements by having a maximum of {one+/- -E4+PSI1 pump [and one chari,,,ump] OPERABLE and SI actuation enabled.

OrI Perfo1manle The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit shown in the PTLR. The OPPS setpoints are derived by analyses that model the performance of the ETGP--system, assuming the limiting LTOP transient of fone] -H4SI- pump

-and allene charging pumpsl injecting into the RCS. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The OPPSP4R- setpoints at or below the derived limit ensures the Reference 1 P/T limits will be met.

The OPPSPOR- setpoints in the PTLR will be updated when the revised P/T limits conflict with the LTOP analysis limits.

The P/T limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-8 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-t-em B 3.4.12 .

1 R-9 ICL3 "4-162 ICL3.4-271 IPA3.4-211 L .......

BASES results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits,"

discuss these examinations.

The PORs are onsidered active com.ponent.s. Thus, the failure of one PRV is assumed to represent the worst-c-a, single activ failure.

CL3.4-272 CL3.4-163 APPLICABLE [PIRScin Relief Valve Performance]

SAFETY ANALYSES (ont n,-e, The RLR suetion relief valves do not, have var able pressure and t-eimperaturc lift setpoints like the POR~s. Analyse-s mflust show that one RHR suction relief valve with a setpoint at or between [436u.5 pEgan 463.5] psig will pass flow greater thA, required for th li LOP transient while maintaining RGS pressure less than the n/T li curve. Assuming all relief flow requirements duri,, the limiting LTOP event, an RR suction relief valve will maintain RCS pressure to within the valve rated lift setpoint, pus an accumulation < 1-o of the rated lift Alhough each RHR sucti on relief valve may itself me single failure criteria, its inclusion and location within the R*,R System does not allow it to ,eet sngle failure crteria when spuriolus RHR suction isolation valve closure is ostulated. Also, as the RCS 1/T 1limts are decrea-sed t refleet the loss of t1o..ughn..ess in the reactor vessel materials due to neutron embrittlement, the R--R suctionn relief valves must be analyzed to still accomml f-odate the design basis transients for LTcPt.

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-9 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSyse-tef I B 3.4.12 F 1 ......

R-9 I1 ICL3.4-162 1CL3.4-271]LPA3.4-211ILL------

BASES The RliR suction relief valves are considered active cofmponents. Thus, the failure of one valve is assumned to represent the worst case single active failure.

RCS Vent Perfrane CL3.4-272 With the RCS depressurized, analyses show a vent size of 2.07 square inches is capable of mitigating the allowed LTOP uverpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the [TOP eonfiguration, [one] 41 pumfp [and one charging pump]

OPERA*L*, maintaining RCS pressure less than the maximum.

pressure on the Pn1T limit curve.

The RCS vent size will be re evaluated for co.pliance each time the P/T limit curves are revised based on the results of the vessel material surveillance.

The RCS vent is passive and is not subject to actite flailure.

APPLICABLE R~G Vent Performnance (continued)

SArFETY ANIAILYSrS The LTOP functionwys-tem satisfies Criterion 2 of the-NRe Policy Statement*O CFR 50.36(c)(2)(ii).

LCO This LCO requires that the-LTOP System is OPERABLE. The LTOn System is OPERABLE when the Flinimube provided, by limiting coolant input capability and by OPERABLE pressure relief capabilityies are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-10 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-tem B 3.4.12 ,

1R-9 ic,.-16 PA3.4-2 L----_

BASES the LCO requires ITA3.4-1661 To limit the coolant input capability, that a maximum of fone]- {-EPSI] pump [and one ch.argiftg*Pum..p]

be capable of injecting into the RCS, and all ECCS ICL3.4-1631 accumulator discharge isolation valves be closed and deenergizedimmobilizd-. (wWhen ECCS accumulator pressure is greater than or equal to the maximum RCS pressure for R-9 the existing RCS cold leg temperature allowed in the .............

PTLR).

A3.4-166 The LCO is modified by two Notes. Note 1 allows operation T of both SI pumps for - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for conducting SI system [ 3.4-164 testing providing there is a steam or gas bubble in the pressurizer and at least one isolation valve between the SI pump and the RCS is shut. The purpose of this note is to permit the conduct of the integrated SI test and other SI system tests and operations that may be performed in MODE 4.

In this case, pressurizer level is maintained at less than 50% and a positive means of isolation is provided between the SI pumps and the RCS to prevent fluid injection to the RCS. This isolation is accomplished by either a closed manual valve or motor operated valve with the power removed.

This combination of conditions under strict administrative control assure that overpressurization cannot occur. . I A3.4-166_1 IT Note 2 states that ECCS accumulator isolation is only required when the ECCS accumulator pressure is more than or at the maximum RCS pressure for the existing RCS cold R-9 leg temperature allowed by the P/T limit curves provided R

in the PTLR (less allowance for instrument uncertainty). SR-9 This Note permits the ECCS accumulator discharge isolation valve Surveillance to be performed only under these

...R.. .......

pressure and temperature conditions.

The el .... *s of the 'GO thatTG provide low temperature overpressure mitigation through pressure relief, the LCO (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-11 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSyt-Sem I B 3 .4 .12 ---------r R-9 1

[CL3.4_162] CL3.4-271][PA3.4-211LL--...

BASES

.C...1 1 -.

a. Iwo iL ree valves, as

1. Two OPERABLE PORnVn; or A PORV is OPERABLE for LTOP when its block valve is open, its low pressure lift setpoint-+/--s-ýt the limit PTLR has been selected (OPPS enabled) and testing prove..its ability to

-open at this setpoint, and the backup air supply imotive rth powsr is available to tw valves and Itheir *onItrol-+ circuits.,

SUCZIOG r*i]*T '¢diV*b, v, 19 lw* ,,*,,,

<,,ri'*t']n, .... , ......

,,,,,* lj ICL3.4-1631

+, ........ BiUF Di ..... -in su lii n r% E R. A U'rva LL * , ,,+

xlIwUT

ý2 oB ......

An lIl, suction relief valve is OPERABLE for LTOP when its RHR suction isolation valve and its R,\,R, suction valve are open, its setpoint isat or, between [436.5] psig an [r3 pig and testing hs ven its ability to open at this setpoinet LCo 3. One OPERABLE I P1-V and one OPERABLE RrllR su.tion

(.onti nued) relief valve; or

b. A depressurized RGS and an RCS vent.

ICL3.4-2721 An RCS vent is OPERABLE when opel wi* t,, an area of F2.07.7 square inches.

Each of these methods of overpressure prev ention 4 of miiatn thlelim.1Iitti ng LIOP tr an sient APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg I 119 temperature is _<the OPPS enable temperature specified in the PTLR and > the SI pump disable temperature specified in the PTL [27514, in MODE. 5, and in MODE 6 wh~en th-e reaetor JL4 16 7 1 (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4. 12-12 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSystem B 3.4.12 F..

1,R-9 I.62. CL3.4-271 BASES essel head is on. The pressurizer safety valves provide overpressure protection that meets the Reference 1 P/T limits above the OPPS enable temperature specified in the PTLR[2q,]9-5F. When the rea.tor vessel head is off, overpressurization . annot occur.

LCO 3.4.3 provides the operational P/T limits for all MODES.

LCO 3.4.10, "Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1, 2, and 3, and MODE 4 above the OPPS enable temperature specified in the TA3.4-119 PTLRf2-*,,-. LCO 3.4.13 provides the LTOP requirements in CL3.4.167 MODE 4

SI pump disable temperature and in MODES 5 and 6.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

by a Note stating that TA3.4-166 The Applicability is maodified ly when the aPcumul';ar Uý- -u, isolation is IS O111 I re.u lU *,uI,,*, vI c ,

accumulator pressure is more than or at the mfaxilmum ,fRS pressure for the existing tefperature, aallowed by the Pn/T limit curves. This Note permits the accum,,ulator discharge isolation valve SurveillanIe to be performed only under these pressure and temlperaturel onditions.-.

ACTIONS A. 1 (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-13 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSystemf B 3.4.12 .

I_

I R-9 1 IC3.-162]IL.-271] PA3.4-211 IL---

BASES ACTIONS A.1 -f ..

With two or mfoare HPSI pumps capable of injecting into the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition.

Required Action B.1 is -odified by a Note that permits two TA3.4-166 charging pumnps capable of RCS injeetion for :t15 flmiue to allow for pumfp swaps.

BG.1. CD.1. and EIC.2 4-^

1 An unisolated EGGS accumulator requires isolation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This is only required when the ECCS. accumulator pressure is at or more than the maximum RCS pressure for R9 the existing temperature allowed by the P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action C9.1 and Required Action CB.2 provide two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to > the ITA3.4-1191 oPPS enable temperature specified in the PTLRF2751-F, an ECCS accumulator pressure of {-68001 psig cannot exceed the LTOP analysis limits if the ECCS accumulators are fully injected. Depressurizing the ECCS accumulators below the LTOP limit from the PTLR also gives this protection.

R-9 The Completion Times are based on operating experience that these activities can be accomplished in these time (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4. 12-14 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSy*s-em I B 3.4.12 1.

1R-9 IL3.4i1 62WIL3.4-271]PA3.4-211 IL --

BASES the OPPS In MODE 4 when any RCS cold leg temperature is _<.TA3.4-119T enable temperature specified in the PTLR[2-7-5, F, with one required PORVRCS relief valve inoperable, the PORVRGS relief valve must be restored to OPERABLE status within a Completion Time of 7 days. Two PORVs RCS relief valves [i,,I anyCoembination of the PORVS and the RHR suction relief v are required to provide low temperature overpressure mitigation while withstanding a single failure of an active component.

ACTIONS DE.1 (continued)

The Completion Time considers the facts that only one of the PORVs RCS relief valves is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path during this time period is very low.

EF. 1 The consequences of operational events that will CL3.4-167]

overpressurize the RCS are more severe at lower temperature (Ref. 7). Thus, with one of the two R.S relief valves inoperable in MODE 5 or in MODE 6 with the head on, the Completion Time to restore two valves to OPERABLE statusY is 24 ho ur-s The Completion Time represents a reasonable timnet investigate and repair several types of relief valv failures without exposure to a lengthy period with only one OPERABLE RCS relief valve to protect against overpressure events.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-15 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-tem B 3.4.12 . . 1 1R-9 1 BAS3ESj6 CL3.4-271 PA3.4-211 L BASES

.4-168 MODE 5 must be entered, tfhe RCS must be depressurized and a vent must be established within 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months when: TA3"4-139

a. Both required*-PORVsRCS relief valves are inoperable; or

b. A Required Action and associated Completion Time of Condition A, CB,]r D, E, or DF is not met; or C. The OPPSlOP Sys*e*, is inoperable for any reason other than Condition A, EB,] C, D, E, or F.

The vent must be sized > 3{2-.07-] square inches to ensure CL3.4-169 that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. The vent opening is based on the cross sectional flow area of a PORV. A PORV maintained in the open position satisfies the vent requirement. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

ACTIONS EG.1 (continued)

The Completion Time considers the time required to place the plant in this Condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-16 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSy-tem B 3.4.12 r.

l 1R-9 CL3.4-162 CL3.4-271 L .PA3.

BASES SURVEILLANCE SR 3.4.12.1. [SR 3.4.12.2.1 and SR 3.4.12.23 REQUIREMENTS To minimize the potential for a low temperature overpressure event by limiting the mass input capability, a maximum of CL3.4163

[onel -HPSI pump isEand a m.laximum. of one pumpI

-harging a-re verified incapable of injecting into the RCS and the ECCS accumulator discharge isolation valves are verified closed and deenergizedlcked- out.

The {HPSI+/- pump[s] and charging pufmf"* are is rendered incapable of injecting into the RCS through removing the F .-2731 power from the pumps by racking the breakers out under administrative control. An alternate mfethod of LTOP control may be employed usingby employing at least two independent means to prevent a pump start such that a single failure or single action will not result in an injection into the RCS.

This may be accomplished through the pump control switch in being placed in {pullout to lock] and at least one valve the discharge flow path being closed with a blocking device installed over the control switch that would prevent an unplanned pump start.

The ECCS accumulator motor operated isolation valves can CL3.4-273 be verified closed and deenergized by use of control board indication. SR 3.4.12.2 is modified by a Note specifying iX34-171 that this verification is only required when the ECCS accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg R-9 If ECCS accumulator ...............

temperature allowed in the PTLR.

pressure is less than this limit, no verification is required since the ECCS accumulator cannot pressurize the RCS to or above the OPPS setpoint. R-9 The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-17 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperatureys-t-em B 3.4.12 .. .

1R-9 1 B S-162 CL3.4-271 PA3.4-211 L BASES control room, to verify the required status of the equipment.

SR 3.4.12.4 CL3.4-163]

Each required R..R suction relief valve shall be demonstrated OPERABLE by verifying its RHIR suction valve and RHR suction isolation valves are open and by testing it in accordance with the inservice T-esting Program. (Refer to SR 3.4.12.7 for the RIIR suction isolation valve Surveillance.) This Surveillance is only required to be performed if the 11,R suction relief valve is being used to meet this LC SURVEILLANCE SR 3.4.1.2.49 (continued)

The RHR suction valve is verified to be opened every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Frcquency is considered adequate in view of other adli nistrati v controls such as val"v status indications available to the operator in the control room that verify the RU1R suction valve remfains open.

The ASME Code, Section XA (Ref. 8), test per InservIl-c Testing Program verifies OPERABILITY by proving proper relief valve mfechanical mfotion and by mfeasuring and, if required, adjusting the lift setpoint.

SR 3.4.12.5 ICL3.4-2721 The RCS vent of t[2.07] square inches is proven OPERABLE by verifying its open condition either.

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a valve that cannot be locked.

b. Once every 31 days for a valve that is locked, scaled, or secured in position. A removed pressurizer safety valve fits thi-s category.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4. 12-18 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable Temperature]yse B 3.4.12 7. ..

i R-ICL417621 CL3.4-271]IA.-1 IL--

BASES The passive vent arrangemfent mfust only be open to be OPERABLE. This Surveillance is required to be pe.,rfomed if the vent is being used to satisfy the pressure relief requir...nts of the LCO 3.4.12-b SR 3.4.12.36 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve maymu-s-t be remotely verified open in the main control room. [This Surveillane.

is performed if the PORV satisfies the LC, The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required to be removed, and the manual operator is not required to be locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

SURVEILLANCE SR 3.4.12.3,6 (continued)

REQUIREMENTS The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

SR, .-3.4. 12.7- CL3.4- 1631 re quired R-R suction relief valve shall be dem-onstrated E[areh1',

CD-OP[RBL by verifying its RIIR suction valve and RIIR suction isolation valve are open and by testing it in accordance (continued)

WOG STS, Rev 1, 04/07/95 B 3.4. 12-19 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSys-t-eff B 3.4.12 I

1 . .

1R-9 1 CL3.4- PA3.4-211 L....

BASES with the inservi.e Testing Progr-a. (Refer to SR 3.4.12.4 for the Rf"R suction valve Surveillan.e and for a descript"io of th-e requirements of the inservice Test-ing Programf.) This Surveillance is only performed if the R"R suction relief valve is being used to satisfy this Lee.

Every .31 days the RR suction isolation valve is verified locked open, with power to the valve operator remfoved, to ensure that accidental closure will not occur. The "locked open" valve ,must be locally verified in its open position with the manual actuator locked in its inactive positio*n.

The 31 day Frequency is based on engineering jugment, is consistent wi.th the procedural control's gov.rni.ng valve operation, and ensures correct valve position.

SR 3.4.12.48 Performance of a COT is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS temperature to [275r and every 31 days on each required PRVOPPS to verify and, as necessary, adjust the PORV*+ts- lift setpoints. A successful test of the required contact(s) of a channel relay may be performed TA3 of the change of state of a single by the verification contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoints are4-s within the PTLR allowed maximum limits in the PTLR. PORV actuation during this testing could depressurize the RCS and is not required.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency considers the unlikelihood of a low teperature overpressure event during this time.

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.12-20 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSyste B 3.4.12 . .

1R-9 1 IBASE62 -271 PA3 .4-211 L BASE S A Note has been added indicating that this SR is required fTA3.4-1 to be performedme-t 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg I ;

temperature to -< the OPPS enable temperature specified in ITA3.4-1191 the PTLRE2*,*1F. The COT may not have beena,,,t, be performed before entry intountil in the LTOP MODES when the PGRV lift setpoint " -

an be reduced to the TOP SUntRVEILLIANCE[ SR 3.4.12*8q (*ontinut.e REQUl\ L R E-N1-I-setting. The test ust be perform'ed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering the LTOP MODE-&. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months initial time considers the unlikehood of a low temperature overpressure event during this time.

SR 3.4.12.5-9 Performance of a CHANNEL CALIBRATION on IOPPSett aeh4-07 requi red PGRV actuati on ehannel is requi red every T--

24l-818] months to adjust the whole channel so that it !R-2 responds and the valve opens within the required range and L----I accuracy to known input.

REFERENCES 1. 10 CFR 50, Appendix G.

2. USAR, Section 4.4.

3. ASME, Boiler and Pressure Vessel Code,Section XI, Appendix G, with ASME Code Case N-5l4Genferi-e Letter 88 !1.

3. ASME, Boiler and Pressure Vessel Code,Section II!.

4. FSAR, Chapter [15]

5. 5...46.

I0 CFR 50, Seto 6- 10 CFR 50, Appendix K.

WOG STS, Rev 1, 04/07/95 B 3.4.12-21 Markup for PI ITS Part E

LTOP - RCSCLT > SI Pump Disable TemperatureSystem _

B 3.4.12 F-1R-9 '

IcL3"4-162I CL3.4-271]1PA3.4-211I L.------ j BASES (continued)

7. Generic Letter 90 06.

8. AS*E, Boiler and Pressure Vessel Code, Section Xv.

WOG STS, Rev 1, 04/07/95 B 3.4.12 -22 Markup for PI ITS Part E

LTOP - RCSCLT I SI Pump Disable Temperature B 3.4.13 ICL3.4-1721L ......

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.13 Low Temperature Overpressure Protection (LTOP) - Reactor Coolant System Cold Leg Temperature (RCSCLT) < Safety Injection (SI) Pump Disable Temperature I R-9 LBASES.-

BASES BACKGROUND The LTOP function limits RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref. 1).

The reactor vessel is the limiting RCPB component for demonstrating such protection. The Over Pressure Protection System (OPPS) provides the actuation setpoints for the pressurizer power operated relief valves (PORVs) for the LTOP function (Ref.2). The PTLR provides the maximum allowable OPPS actuation setpoints and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Reference 1 requirements during the LTOP MODES. The LTOP MODES are the MODES as defined in the Applicability statement of LCO 3.4.12 and LCO 3.4.13.

The pressurizer safety valves and PORVs at their normal setpoints do not provide overpressure protection for certain low temperature operational transients. Inadvertent pressurization of the RCS at temperatures below the OPPS enable temperature specified in the PTLR could result in exceeding the ASME Appendix G (Ref. 3) brittle fracture P/T limits. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel.

LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits,"

requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the PTLR limits.

(continued)

New Specification B3.4.13-1 Markup for PI ITS Part E

LTOP - RCSCLT < SI Pump Disable Temperature B 3.4.13 BASES This LCO provides RCS overpressure protection by restricting coolant input capability and ensuring adequate pressure relief capacity. In MODE 4, at or below the safety injection (SI) pump disable temperature, limiting coolant input capability requires both SI pumps incapable of injection into the RCS and isolating the emergency core cooling system (ECCS) accumulators. The pressure relief capacity requires either two redundant RCS relief valves or a depressurized RCS and an RCS vent of sufficient size. One PORV or the open RCS vent is the overpressure protection device that acts to terminate an increasing pressure event.

BACKGROUND Limiting coolant input capability reduces the ability to (continued) provide core coolant addition. The LCO does not require the makeup control system deactivated or the SI actuation circuits blocked. Due to the lower pressures in the LTOP MODES and the expected core decay heat levels, the charging system can provide adequate flow. If conditions require the use of an SI pump for makeup in the event of loss of inventory, the pump can be made available through manual actions.

The LTOP pressure relief consists of two PORVs with reduced lift settings or a depressurized RCS and an RCS vent of sufficient size. Two PORVs are required for redundancy.

One PORV has adequate relieving capability to prevent overpressurization for the required coolant input capability.

OPPS and PORV Requirements As designed for the LTOP function, each PORV is signaled to open by OPPS if the RCS pressure approaches the lift setpoint provided when OPPS is enabled. The OPPS monitors both RCS temperature and RCS pressure and indicates when a condition not acceptable in the PTLR limits is approached.

The wide range RCS temperature setpoints indicate conditions (conti nued)

New Specification B 3.;4.13-2 eMarkup for PI ITS Part E

LTOP - RCSCLT < SI Pump Disable Temperature I I~

B 3.4.13 1R-9 1 BASES requiring enabling OPPS. The PTLR presents the OPPS setpoints for LTOP.

RCS Vent Reauirements Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting LTOP mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.

APPLICABLE Safety analyses (Ref. 2) demonstrate that the reactor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference I P/T limits. In MODES 1, 2, and 3, and in MODE 4 with RCS cold leg temperature exceeding the OPPS enable temperature specified in the PTLR, the pressurizer safety valves will prevent RCS pressure from exceeding the Reference 1 limits.

At about the OPPS enable temperature specified in the PTLR and below, overpressure prevention falls to two OPERABLE PORVs or to a depressurized RCS and a sufficiently sized RCS vent. Each of these means has a limited overpressure relief capability. LCO 3.4.12, "LTOP > SI Pump Disable Temperature," provides the requirements for overpressure prevention at temperatures above the SI Pump disable temperature.

The actual temperature at which the pressure in the P/T limit curve falls below the pressurizer safety valve setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the PTLR (continued)

New Specification B 3.i4.13-*3 Markup for PI ITS Part E

LTOP - RCSCLT

SI Pump Disable Temperature I B 3.4.13 I

1R-9 I L .. .. I BASES curves are revised, LTOP must be re-evaluated to ensure its functional requirements can still be met using the PORV method or the depressurized and vented RCS condition.

The PTLR contains the acceptance limits that define the LTOP requirements. Any change to the RCS must be evaluated against the Reference 2 analyses to determine the impact of the change on the LTOP acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients. The bounding mass input transient is inadvertent safety injection with injection from one SI pump and three charging pumps, and letdown isolated. The bounding heat input transient is reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following limitations are required during the Applicability of this specification to ensure that mass and heat input transients in excess of analysis assumptions do not occur:

a. Rendering both-SI pumps incapable of injection;

b. Deactivating the ECCS accumulator discharge isolation valves in their closed positions; and

c. Disallowing start of an RCP if secondary temperature "ismore than 50'F above primary temperature in any one loop. LCO 3.4.6, "RCS Loops-MODE 4," provides this protection.

The Reference 2 analyses demonstrate that either one PORV or the depressurized RCS and RCS vent can maintain RCS pressure below limits when all charging pumps are actuated. Neither one PORV nor the RCS vent can handle the pressure transient resulting from inadvertant SI pump or ECCS accumulator (continued)

New Specifi cation SB 3.4 134 Markup for PI ITS Part E

LTOP - RCSCLT

SI Pump Disable Temperature I B 3.4.13 ,

1R-9 1 LBA---- S BASES injection when the RCS is below the SI pump disable temperature. Thus, the LCO requires both SI pumps to be disabled below the temperature specified in the PTLR.

The LCO also requires ECCS accumulator isolation when ECCS accumulator pressure is greater than or equal to the R-9 maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR. The isolated ECCS accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions.

Fracture mechanics analyses established the temperature of LTOP Applicability at the OPPS enable temperature specified in the PTLR. The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit shown in the PTLR. The OPPS setpoints are derived by analyses that model the performance of the system, assuming the limiting LTOP transient of all charging pumps injecting into the RCS. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The OPPS setpoints at or below the derived limit ensures the Reference I P/T limits will be met.

The OPPS setpoints in the PTLR will be updated when the APPLICABLE revised P/T limits conflict with the LTOP analysis limits.

SAFETY ANALYSES The P/T limits are periodically modified as the reactor (continued) vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits,"

discuss these examinations.

With the RCS depressurized, analyses show a vent size equivalent to the cross sectional flow area of a PORV is (continued)

New Speci fication B 3.4.13-5 NMarkup for P ITS Part E

LTOP - RCSCLT < SI Pump Disable Temperature B 3.4.13 R 1 R-9 L - - - - -

BASES capable of mitigating the allowed LTOP overpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the LTOP configuration, both SI pumps disabled and all charging pumps OPERABLE when the RCS is below the SI pump disable temperature, maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vent is passive and is not subject to active failure.

The LTOP function satisfies Criterion 2 of 10 CFR 50.36(c) (2) (ii).

LCO This LCO requires that LTOP be provided, by limiting coolant input capability and by OPERABLE pressure relief capability.

Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient.

To limit the coolant input capability, the LCO requires both SI pumps be incapable of injecting into the RCS, and all ECCS accumulator discharge isolation valves be closed and deenergized (when ECCS accumulator pressure is greater... ......

than or equal to the maximum RCS pressure for the existing R-9 RCS cold leg temperature allowed in the PTLR). ...............

The LCO is modified by three Notes. Note I allows operation of both SI pumps for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for conducting SI system testing providing there is a steam or gas bubble in the pressurizer and at least one isolation valve between the SI pump and the RCS is shut. The purpose of this note is to permit the conduct of the integrated SI test and other SI system tests and operations that may be performed in MODES 4, 5 or 6. In this case, pressurizer level is maintained at less than 50% and a positive means of isolation is provided (continued)

New Specification B 3.4.13-6 Markup for PI ITS Part E

LTOP - RCSCLT < SI Pump Disable Temperature I B 3.4.13 R-9 L - - - - - --

BASES between the SI pumps and the RCS to prevent fluid injection to the RCS. This isolation is accomplished by either a closed manual valve or motor operated valve with the power removed. This combination of conditions under strict administrative control assure that overpressurization cannot occur.

Note 2 allows operation of an SI pump during reduced inventory conditions as required to maintain adequate core cooling and RCS inventory. The purpose of this note is to allow use of an SI pump in the event of a loss of other injection capability ( e.g., loss of Residual Heat Removal System cooling while in reduced inventory conditions). The operation of an SI pump under such conditions would be controlled by an approved emergency operating procedure.

Note 3 states that ECCS accumulator isolation is only "required when the ECCS accumulator pressure is more than or at the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided ...-.

in the PTLR (less allowance for instrument uncertainty).

This Note permits the ECCS accumulator discharge isolation valve Surveillance to be performed only under R-9 these pressure and temperature conditions.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. An OPERABLE OPPS with two PORVs.

A PORV is OPERABLE for LTOP when its block valve is open, its low pressure lift setpoint has been selected (OPPS enabled), and the backup air supply is charged.

b. A depressurized RCS and an RCS vent.

An RCS vent is OPERABLE when open with an area of

Ž 3 square inches. Because the RCS vent opening (continued)

New Specification B 3.4.13-7 Markup for P1 ITS Part E

LTOP - RCSCLT *< SI Pump Disable Temperature B 3.4.13 BASES a PORV maintained in the open position satisfies the RCS vent requirement.

Each of these methods of overpressure prevention is capable of mitigating the limiting LTOP transient.

APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg temperature is < the SI pump disable temperature specified in the PTLR, in MODE 5, and in MODE 6 when the reactor vessel head is on and the SG primary system manways and pressurizer manway are closed and secured. The pressurizer safety valves provide overpressure protection that meets the Reference I P/T limits above the OPPS enable temperature specified in the PTLR. When the reactor vessel head is off, overpressurization cannot occur.

LCO 3.4.3 provides the operational P/T limits for all MODES.

LCO 3.4.10, "Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1, 2, and 3, and MODE 4 above the OPPS enable temperature specified in the PTLR.

LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP)

SSafety Injection (SI) Pump Disable Temperature," provides the requirements for MODE 4 below the OPPS enable temperature and above the SI pump disable temperature.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

(continued)

New Specification B 3.4.13-8 Markup for PI ITS Part E

LTOP - RCSCLT < SI Pump Disable Temperature _I-B 3.4.13 1R-9 L - - - - - -J BASES ACTIONS A.1 With one or more SI pumps capable of injecting into the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition.

B.1. C.1. and C.2 An unisolated ECCS accumulator requires isolation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This is only required when the ECCS accumulator pressure is at or more than the maximum RCS pressure for R-9 the existing temperature allowed by the P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action C.1 and Required Action C.2 provide two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to > the OPPS enable temperature specified in the PTLR, an ECCS I accumulator pressure of 800 psig cannot exceed the LTOP analysis limits if the ECCS accumulators are fully injected. Depressurizing the accumulators ow -------- ............

the LTOP limit from the PTLR also gives this R-9 protection.

The Completion Times are based on operating experience that these activities can be accomplished in these time periods and on engineering evaluations indicating that an event requiring LTOP is not likely in the allowed times.

D.1 The consequences of operational events that will overpressurize the RCS are more severe at lower temperature.

(continued)

New Specification R 3.4.13-9 Markup for PI ITS Part E

LTOP - RCSCLT , SI Pump Disable Temperature B 3.4.13

. R-9 L-.

BASES (continued) leg temperature is _<the SI Pump disable temperature specified in the PTLR, MODE 5 or in MODE 6 with the head on, the Completion Time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . A Note clarifies that Condition D is only applicable when the OPPS and PORVs are being used to satisfy the pressure relief requirements of LCO 3.4.13.a.

The Completion Time represents a reasonable time to investigate and repair several types of relief valve failures without exposure to a lengthy period with only one OPERABLE PORV to protect against overpressure events.

ACTIONS E1 (continued) The RCS must be depressurized and a vent must be established within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when:

a. Both required PORVs are inoperable; or

b. A Required Action and associated Completion Time of Condition A, C, or D is not met; or C. The OPPS is inoperable.

The vent must be sized Ž 3 square inches to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. The vent opening is based on the cross sectional flow area of a PORV. A PORV maintained in the open position satisfies the vent requirement. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

The Completion Time considers the time required to place the plant in this Condition and the relatively low probability of an overpressure event during this time period due to (conti nued)

New Specifi cation B 3.4.13-10 Markup for PI ITS Part E

LTOP - RCSCLT

SI Pump Disable Temperature B 3.4.13 R-9 1 L-BASES (continued) increased operator awareness of administrative control requirements.

SURVEILLANCE SR 3.4.13.1. and SR 3.4.13.2 REQUIREMENTS To minimize the potential for a low temperature overpressure event by limiting the mass input capability, both SI pumps are verified incapable of injecting into the RCS and the ECCS accumulator discharge isolation valves are verified closed and deenergized.

The SI pumps are rendered incapable of injecting into the RCS by employing at least two independent means to prevent a pump start such that a single failure or single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in pullout with a blocking device installed over the control switch that would prevent an unplanned pump start.

The ECCS accumulator motor operated isolation valves can be verified closed and deenergized by use of control board indication. SR 3.4.13.2 is modified by a Note specifying that this verification is only required when the ECCS accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold legR9 If ECCS accumulator................

temperature allowed in the PTLR.

pressure is less than this limit, no verification is required since the ECCS accumulator cannot pressurize the RCS to or above the OPPS setpoint..R9 Th*2 h ~urs................

eq enc of The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the ec~ui pment.

SR 3.4.13.3 (conti nued)

New Specifi~cation B 3.4.13-11i NMarkup for PT ITS Part E

LTOP - RCSCLT . SI Pump Disable Temperature B 3.4.13 2

. R-9 1 BASES (continued)

The required RCS vent of ? 3 square inches is proven OPERABLE by verifying its open condition either:

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a valve that is not locked, sealed, or secured in the open position.

b. Once every 31 days for other vent path(s) (e.g., a vent valve that is locked, sealed, or secured in position). A removed pressurizer safety valve or open manway also fits this category.

The passive vent path arrangement must only be open when required to be OPERABLE. This Surveillance is required if the vent is being used to satisfy the pressure relief requirements of LCO 3.4.13b.

R-9 SR 3.4.13.4 ........

The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve may be remotely verified open in the main control room. This Surveillance is performed if the PORV satisfies the LCO.

The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required to be removed, and the manual operator is not required to be locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

SURVEILLANCE SR 3.4.13.4 (continued)

REQUIREMENTS The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Frequency is considered adequate in view of other administrative controls available to the operator in (continued)

New Specification SB 3.4 .13-2 Markup for PI ITS Part E

LTOP - RCSCLT _<SI Pump Disable Temperature B 3.4.13 . ...

R-9 BASES (continued) the control room, such as valve position indication, that verify that the PORV block valve remains open.

SR 3.4.13.5 Performance of a COT is required every 31 days on OPPS to verify and, as necessary, adjust the PORV lift setpoints. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoints are within the PTLR allowed maximum limits in the PTLR. PORV actuation during this testing could depressurize the RCS and is not required.

Note 1 has been added indicating that this SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to < the OPPS enable temperature specified in the PTLR. The COT may not have been performed before entry into the LTOP MODES. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months initial time considers the unlikehood of a low temperature overpressure event during this time.

Note 2 has been added to specify that this SR is only required to be performed when OPPS and PORVs are providing the LTOP function per LCO 3.4.13.a.

SR 3.4.13.6 Performance of a CHANNEL CALIBRATION on OPPS is required every 24 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

(continued)

New Specification B 3.4.13-13 Markup for PI ITS Part E

LTOP - RCSCLT _<SI Pump Disable Temperature B 3.4.13 IR-9 1 L - .!

BASES (continued)

REFERENCES 1. 10 CFR 50, Appendix G.

2. USAR, Section 4.4.

3. ASME, Boiler and Pressure Vessel Code, Section XI, Appendix G, with ASME Code Case N-514.

(contionued)

New Specification B3.4.13-14 B Markup for PI ITS Part E

RCS Operational LEAKAGE B 3.4.143 Si-21 BASES noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4.165, "RCS Leakage Detection Instrumentation." ICLýý .4-331 The 7h24 hour Frequency is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage I R-9 SURVEILLANCE SR 3.4.13.1 (conti...nue.d REUI\ I.NLT'I PL S L176 detection in the prevention of accidents. A Note ITA3 .4-176 under the Frequency columln states that,, this R isR required to be performed during steaudy state 0pera1-tion1.

SR 3.4.143.2 This SR provides the means necessary to determine SG PA34-17 i OPERABILITY in an operational MODE. The requirement to demonstrate SG tube integrity in accordance with the Steam Generator Tube Surveillance Program emphasizes the importance of SG tube integrity, even though this Surveillance cannot be performed at normal operating conditions.

REFERENCES 1. 10 CFR 50, ppen I A , GDC 30AEC "General Design L 21 Criteria for Nuclear Power Plant Construction Permits," Criterion 16, issued for comment July 10, 1967, as referenced in USAR Section 1.2.

2. Regulatory Guide 1.45, May 1973.

3. UFSAR, Section 14.5f751-.

WOG STS, Rev 1, 04/07/95 R 3.4. 14-9 Markup for PI ITS Part E

RCS Specific Activity B 3.4.167 PA3 .4-211 BASES (continued)

ACTIONS A Note to the ACTIONS excludes the MODE change restriction of LCO 3.0.4. Thi s-execept-icon a!llows rTA3.4-314 entry into the applicable MODE(

on the ACTIONS even though the ACTIONS may eventual .. ly require plant shutdown. This ecepti41On is - acceptable due to the significant conservatism incorporated into the speeific activity limit, the low probabil'ty of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remfains at, or proceeds to power operation.

A.1 and A.2 With the DOSE EQUIVALENT 1-131 greater than the LCO r--I.----I limit, I I samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to I L

R-9 U -. ..

demonstrate that the limits of Figure 3.4.167-1 are not exceeded. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample. Sampling is done to continue to provide a trend.

The DOSE EQUIVALENT 1-131 must be restored to within I limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months isr ..... '

required, if the limit violation resulted from normal , R-9 '

io d in e sp i k ing . L ...... I Permitting POWER OPERATION to continue for limited time CL3.4-325 periods with the primary coolant's specific activity greater than 1.0 tiCi/gm DOSE EQUIVALENT 1-131, but within the allowable limit shown on Figure 3.4.17-1, accommodates the possible iodine spiking phenomenon which may occur following changes in THERMAL POWER. Operation with specific activity levels exceeding 1.0 pCi/gm DOSE EQUIVALENT 1-131 but within the 'limits shown on Figure 3.4.17-1 should be minimuzed since the activity levels allowed by the figure (conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.17-5 Markup for PI ITS Part E

RCS Specific Activity B 3.4.167 PA3.4-211 BASES (continued) increase the dose at the site boundary following a postulated steam generator tube rupture.

A Note to the ACTIONS excludes the MODE change bA3.4-314!

restriction of LCO 3.0.4. This exception allows entry into the applicable MODE(S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

B. 1-and-B.

With the gross specific activity in excess of the allowed TA3.4-201 l limit, the reactor must be placed in a MODE in which the requirement does not applyan analysis must be prformed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to determnine DOS[ EQUIVALENT 1-131. The Comnpletion Timfe of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain an analyze a samfple.

The change within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to MODE 3 and RCS average temperature < 500'F lowers the saturation pressure of the reactor coolant below the setpoints of the main steam safety valves and prevents venting the SG to the environment in an SGTR event. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 500'F from full power conditions in an orderly manner afnd-without challenging plant systems.

ACTIONS C.1 (continued)

(conti nued)

WOG STS, Rev 1, 04/07/95 B 3.4.17-6 Markup for PI ITS Part E

RCS Specific Activity B 3.4.167 BASES JPA3.4-211 If a Required Action and the associated Completion Time of Condition A is not met or if the DOSE EQUIVALENT 1-131 is in the unacceptable region of Figure 3.4.167-1, the r------.I reactor must be brought to MODE 3 with RCS average 1R-9 The Completion Time L .......

temperature < 5007F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 500'F from full power conditions in an orderly manner eftd-without challenging plant systems.

SURVEILLANCE SR 3.4.167.1 REQUIREMENTS SR 3.4.167.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross specific activity.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The Surveillance is applicable in MODES 1 and 2, and in MODE 3 with T." at least 500'F. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time.

SR 3.4.167.2 This Surveillance is performed in MODE 1 only to ensure iodine remains within limit during normal operation and following fast power changes when fuel failure is more R-9 apt to occur. The 14 day Frequency is adequate to trend )IL ----- -J (continued)

WOG STS, Rev 1, 04/07/95 B 3.4.17-7 Markup for PI ITS Part E

RCS Specific Activity B 3.4. 167 BASES changes in the iodine activity level, considering gross activity is monitored every 7 days. The Frequency, II R-9 I between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change >_ 15% RTP L-L -.. ..

I J

within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time following fuel failure; samples at other times would provide inaccurate results.

SURVEILLANCE SR 3.4.167.3 REQUIREMENTS (continued) A radiochemical analysis for E determination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions. The P determination directly relates to the LCO and is required to verify plant operation within the specified gross activity LCO limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than 15 minutes, excluding iodines. The Frequency of 184 days recognizes E does not change rapidly.

This SR has been modified by a Note that indicates sampling is required to be performed within 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal event.

REFERENCES 1. 10 CFR 100.11, 1973.

2. Letter from Dominic C. Dilanni, NRC, to L. 0. Mayer, iCL3.4324 NSP, dated December 4, 1981.

3. UFSAR, Section 14.5[15.6.3].

(continued)

WOG STS, Rev 1, 04/07/95 B 3.4.17-8 Markup for PI ITS Part E

Part F Package 3.4 Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4-CL 103 NUREG-1431 SR 3.4.1.3 was not included since PI CTS do not contain this requirement and the existing control board flow meters do not provide sufficient resolution to measure the specified values. These flow meters are 100% scale devices that are intended to provide operators with indication that RCS flow through each loop is approximately equal, but not an exact flow indication. Since a modification would be required to implement this SR, a reactor trip currently exists for low RCS flow, and RCS total flow rate is verified following startup from each refueling outage, this surveillance was not added.

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

Part F Package 3.4 3.4 Part F Package Difference Difference Category Number Justification for Differences 3.4 CL 104 The Note for ISTS SR 3.4.1.4 was deleted. This SR provides for the verification of the RCS total flow rate. The associated Note states that this SR was not to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after

> [90]% RTP. PI CTS 3.10.J.c requires that the RCS flow be verified to be within its limits specified in the COLR after each refueling outage. The purpose of the SR is to measure RCS flow rate which allows for the installed RCS flow instrumentation to be calibrated and verifies actual RCS flow rate is greater than or equal to the minimum required RCS flow rate. PI currently performs this verification however, the CTS does not provide any specific time or RTP level as to when this verification must be performed. Even though the CTS does not require a specific time or RTP level, prudent operations would not allow PI to operate for a very long period of time at high power levels without performing this SR. In addition, during power escalation, various plant instrumentation and parameters are monitored to ensure that the reactor core is maintaining expected temperatures which provides further assurance that there is adequate RCS cooling (flow rate) until this verification can be performed. In accordance with the agreements made with the NRC for plants converting to the STS, plants are able to maintain their current license basis and CTS. As such, P1 will maintain our CTS requirements and not place a specific time or RTP for verification of the RCS flow rate.

Prairie Island Units 1 and 2 3 1/2/02

Part F Package 3.4 Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4-105 Not used.

PA 106 CTS does not specify a particular method for performing the RCS flow test. Thus the phrase, "by precision heat balance that" is not included in ITS SR 3.4.1.3.

CL 107 The CTS requirement for this surveillance requires the test to be performed each refueling cycle.

Since PI intends to extend the plant refueling cycle up to 24 months, this Frequency is also extended to 24 months.

TA 108 This deviation implements approved TSTF-26.

TA 109 This change incorporates approved TSTF-339, Revision 1 except for the RCS flow which is already in the COLR per CTS. This is addressed in CL3.4-102. Since PI ITS retains the SL curves in Section SL 2.1.1, changes in the 3.4.1 Bases, Applicability, last paragraph, are not included.

Prairie Island Units 1 and 2 4 1/2/02

Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4-CL 110 PI only has two groups of heaters to which this Specification applies and both groups are "required". Since both groups are required, the term "required" is not necessary and has been deleted in ITS 3.4.9, Condition B.

TA 111 This change implements TSTF-27, Rev. 3.

CL 112 Since PI is a two loop plant, "two" RCS loops has been specified and "all" has been replaced with "both".

CL 113 LCO, Actions, Surveillance Requirements and Bases are revised as appropriate to reflect that PI is a two loop plant. In some applications, use of "required" is not necessary or applicable since PI is a two loop plant; therefore, "required" has been deleted. (Markup did not include TSTF-263 since PI is a two loop plant).

CL 114 The Note to LCO 3.4.5 was modified by changing "All" to "Both" since PI is a two loop plant.

TA 115 This change incorporates TSTF-286, Revision 2.

116 Not used.

Prairie Island Units 1 and 2 5 1/2/02

Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4 CL 117 The allowed time and purpose of allowing both pumps to be not operating was extended to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and clarified that it is "to perform preplanned work activities". These changes were justified in a License Amendment Request dated November 19, 1999 (This LAR was approved by License Amendment 152/143, July 14, 2000). The justification presented in the LAR is factored in to the Bases. This justification argues that natural circulation provides sufficient flow for decay heat removal, and for boron addition requisite for provision of shutdown margin. The justification notes that this circulation may not be sufficient to respond to all potential dilution events. Thus, preplanned activities that stop forced flow must include actions to preclude the potential for events such as boron dilution.

TA 118 This change incorporated traveler TSTF-87, Rev.

2.

TA 119 This change incorporates TSTF-233. The specific phrase that has been inserted is modified to include PI specific terminology for the LTOP system, "Over Pressure Protection System (OPPS)."

120 Not used.

Prairie Island Units 1 and 2 6 1/2/02

Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4 CL 121 ISTS 3.4.5, 3.4.6, and 3.4.7 state in several places that the secondary side water levels for the steam generators will be > [17%] for the required RCS loop. PI CTS does not require a specific water level in the SG. The CTS requires at least two methods of decay heat removal shall be OPERABLE with one in operation.

Acceptable methods for removing decay heat are at least one reactor coolant pump and its associated steam generator. In addition, based on NRC Information Notice 95-32, TSTF 114, and WOG 155, the ITS statement has been revised to verify that the required steam generator is capable of removing decay heat. The current ISTS is incomplete and misleading. TSTF-114 revised the Bases for LCO 3.4.7 and incorporated a reference to IN 95-35, but did not include sufficient information for an operator to recognize the additional requirements discussed in the IN. The ISTS LCO 3.4.7 requirement that the secondary side water level of at least one SG be > 17% is insufficient to ensure the SG can be relied upon to remove heat from the RCS in the applicable conditions. The wording of the LCO and the referencing of the IN create a condition in which the document referenced in the Bases contains additional requirements necessary to meet the intent of the LCO. As a result, LCO 3.4.7, SR 3.4.5.2 and SR.3.4.6.2 have been revised to only require verification of SG secondary side water level and removes the specific level values.

Prairie Island Units 1 and 2 7 1/2/02

Part F Package 3.4 Difference Difference Category Number Justification for Differences 3.4-122 Not used.

CL 123 CTS require a steam or gas bubble in the pressurizer prior to low temperature starting of a RCP. This requirement has been included in the ITS for consistency with the current licensing basis.

124 Not used.

TA 125 This change incorporates TSTF-265, Revision 2.

CL 126 CTS for this mode of operation require one SG to be operable; thus "one" is specified to retain current requirements.

Prairie Island Units 1 and 2 8 1/2/02

Part F Package 3.4 Part F Package 34 Difference Difference Category Number Justification for Differences 3.4-PA 127 Minor wording change to make the ITS wording consistent with the NUMARC 93-03, Writer's Guide for Restructured Technical Specifications.

CL 128 LCO, Actions, Surveillance Requirements and Bases are revised as appropriate to reflect that PI has only two RHR loops.

129 Not used.

130 Not used.

Prairie Island Units 1 and 2 9 12/11/00

Part F Package 3.4 3.4 Part F Package Difference Difference Category Number Justification for Differences 3.4 CL 131 The note has been revised to incorporate PI CLB and CTS. PI CLB, which has been approved by the NRC, allows that both RHR pumps may be shutdown for one hour provided the reactor is subcritical, no operations are permitted that would cause dilution of the reactor coolant boron concentration and core outlet temperature is maintained at least 10 OF below saturation temperature. PI did add two other restrictions; no RCS draining operations are permitted during this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period and that the pumps can only be shutdown for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

These two additions are consistent with NUREG 1431. This change is acceptable since the circumstances are to be limited when the outage time is short and the other conditions of the note are met. This change is consistent with PI CLB and CTS which has been approved by the NRC.

One of the agreements between the industry and NRC is that during the conversion process to the ITS, a licensee is able to maintain their CLB or approved CTS. P1 is exercising this agreement for this note.

CL 132 A Note has been included in Required Action B.2 to incorporate current licensing basis provisions.

As allowed by the CTS, a Safety Injection pump may be operated if required to maintain adequate core cooling and RCS inventory during reduced RCS water inventory operations.

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

ML021900601

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