ML071410099

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Technical Specifications, Issuance of Amendments Nos 251 & 195 Regarding Technical Specification Task Force Change TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities
ML071410099
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 05/17/2007
From:
NRC/NRR/ADRO/DORL/LPLII-1
To:
Martin R, NRR/DORL, 415-1493
Shared Package
ML070870587 List:
References
TAC MD4225, TAC MD4226
Download: ML071410099 (16)


Text

for sample analysis or Instrument calibration, or associated with radioactive apparatus or components; (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nbdear materials as may be produced by the operation of the facility.

C. This renewed license shagl be deemed to contain and Is subject to the conditions specified In the following Commission regulations In 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Abt and the rules, regulations, and orders of the Commission now or hereafter In effect; and the additional conditions specified or Incorporated below.

(1) M*axium Power Level Southern Nuclear Is authorized to operate the facility at steady state reactor core power levels not In excess of 2804 megawatts thermal.

(2) Technical SBpecfications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 251 are hereby Incorporated In the renewed license. Southern Nuclear shall operate the facility In accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained In the Technical Specifications and listed below, Is not required to be performed Immediately upon Implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated prior to the time and condition specified:

SR 8.8.1.18 shall be successfully demonstrated at Its next regularly scheduled performance (3) R3re Protectlion Southern Nuclear shall Implement and maintain In effect all provisions of the fire protection program, which Is referenced In the Updated Final Safety Analysis Report for the faci1lty, as contained In the updated Fire Hazards Analysis and Fire Protection Program for Edwin I. Hatch Nuclear Plant Units I and 2, which was originally submitted by letter dated July 22, 1986. Southem Nuclear may make changes to the fire protection program without prior Commission approval only Ifthe changes Renewed License No. DPR-57 Amendment No. 251

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," may be suspended to allow reactor coolant temperature > 212 0 F:

  • For performance of an Inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing Initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:
a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment;
c. LCO 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)r; and
d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System.*

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

HATCH UNIT 1 3.10-1 Amendment No. 251

Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS


. NOTE Separate Condition entry is allowed for each requirement of the LCO.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more of the above A.1 - NOTE-requirements not met. Required Actions to be in MODE 4 Include reducing average reactor coolant temperature to ; 212 0 F.

Enter the applicable Immediately Condition of the affected LCO.

OR A.2.1 Suspend activities that Immediately could Increase the average reactor coolant temperature or pressure.

AND A.2.2 Reduce average 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reactor coolant temperature to <2120F.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.1.1 Perform the applicable SAs for the required According to the MODE 3 LCOs. applicable SRs HATCH UNIT 1 3.10-2 Amendment No. 251 1

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO Is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212°F (normally corresponding to MODE 3) or to allow completing these reactor coolant pressure tests when the Initial conditions do not require temperatures > 212 0 F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is Initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Inservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class I boundary are not pressurized during these system tests. System hydrostatic tests are required once per Interval and Include all the Class 1 boundary unless the test is broken-into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."

These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

The hydrostatic test requires Increasing pressure to approximately 1139 psig. The system leakage test requires increasing pressure to approximately 1045 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures > 800 psig. I With Increased retactor vessel fluence over time, the minimum allowable vessel temperature Increases at a given pressure. Periodic (continued)

HATCH UNIT 1 B 3.10-1 Amendment No. 251

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES BACKGROUND updates to the RCS P/T limit curves are performed as necessary, (continued) based upon the results of analyses of Irradiated surveillance specimens removed from the vessel. However, hydrostatic and leak testing may still be required with minimum reactor coolant temperatures > 212 0F. However, even with required minimum reactor coolant temperatures < 212°F, maintaining RCS temperatures within a small band during the test can be Impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Other testing may be performed In conjunction with the allowances for Inservice leak or hydrostatic tests and control rod scram time tests.

APPLICABLE Allowing the reactor to be considered in MODE 4 when the reactor SAFETY ANALYSES coolant temperature is > 2120F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing Initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, Including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems.

Since the tests are performed nearly water solid (except for an air I bubble for pressure control), at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent Increase In coolant activity above the LCO 3.4.6, "RCS Specific Activity, limits are minimized. In addition, the secondary containment will be OPERABLE, in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, (continued)

HATCH UNIT 1 B 3.10-2 Amendcment No. 251

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE "ECCS - Shutdown," would be more than adequate to keep the core SAFETY ANALYSES flooded under this low decay heat load condition. Small system leaks (continued) would be detected by leakage Inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, In addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.

A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described In LCO 3.0.7, compliance with this Special Operations LCO Is optional. Operation at reactor coolant temperatures > 212OF can be In accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 212 0 F, while the ASME system hydrostatic test itself requires the safety/relief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures < 212 0 F, RCS temperatures may drift above 212 0 F during the performance of Inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed In conjunction with inservice leak and hydrostatic testing.

While this Special Operations LCO Is provided for Inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections Is not precluded.

If it Is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide

.(continued)

HATCH UNIT 1 B 3.10-3 Amendment No. 251

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO sufficient protection for operations at reactor coolant temperatures (continued) > 212°F for the purpose of performing an inservice leak or hydrostatic test, and for control rod scram time testing initiated In conjunction with an inservice leak or hydrostatic test.

This LCO allows primary containment to be open for frequent unobstructed access to perform Inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements. I APPLICABILITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing Initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as in MODE 4, even though the reactor coolant temperature is > 212°F. The additional requirement for secondary containment OPERABILITY according to the Imposed MODE 3 requirements provides conservatism In the response of the unit to any event that may occur. Operations Inall other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on Initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met. As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

A.1 If an LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered immediately and complied with.

Required Action A.1 has been modified by a Note that clarifies the Intent of another LCO's Required Action to be in MODE 4 Includes reducing the average reactor coolant temperature to : 212 0 F.

(continued)

HATCH UNIT 1 B 3.10-4 Amendment No. 251

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS A.2.1 and A.2.2 (continued)

Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation LCO's Applicability. Activities that could further increase reactor coolant temperature or pressure are suspended Immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to < 212°F with normal cooldown procedures. The Completion Time Is also consistent with the time provided In LCO 3.0.3 to reach MODE 4 from MODE 3.

SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO Is being met. A discussion of the applicable SRs Is provided in their respective Bases.

REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.

2. FSAR, Section 14.4.5.

HATCH UNIT I B 3.10-5 Amendment No. 251 1

.4-(6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

.0. This renewed license shall be deemed to contain, and Is subject to, the conditions specified In the following Commission regulations In 10 CFR Chapter I: Part 20, Section 80.84 of Part 80, Section 40.41 of Part 40, Section 50.64 of Part 50, and Section 70.82 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter In effect and the additional conditions' specified or Incorporated below:

(1) Maximum Power Level Southern Nuclear Is authorized to operate the facility at steady stale reactor core power levels not In excess of 2,804 megawatts thermal, In accordance with the conditions specified herein.

(2) Technical Sgecfficatlons The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No..195 are hereby Incorporated In the renewed license. Southem Nuclear shan operate the facility In accordance ,dth the Technical Specifications and the Environmental Protection Plan.

(3) Additional Conditions The matters specifled In the following conditions shall be completed to the satisfaction of the CornmLsson w~thln the stated time periods following the Issuance of the renewed license or within the operational restrictions Indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commlsslon.

(a) Fi'e Protection Southern Nuclear shall Implement and maintain In effect all provisons of the fire protection program, which Is referenced In the the Updated Final Safety Analysis Report for the facility, as contained 2The original licensee authorized to possess, use, and operate the facility was Georgia Power Company (GPC). Consequently, certain historical references to GPC remain In certain license conditions.

Renewed Ucense No. NPF-5 Amendment No.195

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA,* and operation considered not to be In MODE 3; and the requirements of LCO 3.4.8, 'Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown,* may be suspended to allow reactor coolant temperature > 212°F:

  • For performance of an inservice leak or hydrostatic test,
  • As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or
  • As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an Inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:
a. LCO 3.3.6.2, *Secondary Containment Isolation Instrumentation,"

Functions 1, 3, and 4 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment;
c. LCO 3.6.4.2, 'Secondary Containment Isolation Valves (SCIVs)*;

and

d. LCO 3.6.4.3, 'Standby Gas Treatment (SGT) System.*

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212°F.

HATCH UNIT 2 3.10-1 Amendment No. 195

Inservice Leak and Hydrostatic Testing Operation 3.10.1 ACTIONS


---- *---~-----PLLJ I Separate Condition entry is allowed for each requirement of the LCO.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more of the above A.i1 requirements not met. Required Actions to be in MODE 4 include reducing average reactor coolant temperature to < 212 0 F.

Enter the applicable Immediately Condition of the affected LCO.

OR A.2.1 Suspend activities that Immediately could increase the average reactor coolant temperature or pressure.

AND A.2.2 Reduce average reactor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coolant temperature to

< 212OF.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.1.1 Perform the applicable SRs for the required According to the MODE 3 LCOs. applicable SRs HATCH UNIT 2 3.10-2 Amendment No. 1951

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LCO Is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 212*F (normally corresponding to MODE 3) or to allow completing these reactor coolant pressure tests when the Initial conditions do not require temperatures > 212 0F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212OF when the control rod scram time testing is initiated In conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed In accordance with LCO 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown,* during MODE 4 operation.

System hydrostatic testing and system leakage (same as inservice leakage tests) pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Inservice system leakage tests are performed at the end of each refueling outage with the system set for normal power operation. Some parts of the Class 1 boundary are not pressurized during these system tests. System hydrostatic tests are required once per interval and include all the Class I boundary unless the test Is broken into smaller portions. Recirculation pump operation and a water solid RPV (except for an air bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (PIT) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits."

These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

The hydrostatic test requires increasing pressure to approximately 1139 psig. The system leakage test requires increasing pressure to approximately 1045 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures :>800 psig. I With Increased reactor vessel fluence over time, the minimum allowable vessel temperature increases at a given pressure. Periodic (continued)

HATCH UNIT 2 B 3.10-1 Amendment No. 195

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES BACKGROUND updates to the RCS P/T limit curves are performed as necessary, (continued) based upon the results of analyses of irradiated surveillance specimens removed from the vessel. However, hydrostatic and leak testing may still be required with minimum reactor coolant temperatures > 212 0 F. However, even with required minimum reactor coolant temperatures < 2120F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rod scram time tests.

APPLICABLE Allowing the reactor to be considered in MODE 4 when the reactor SAFETY ANALYSES coolant temperature is > 212=F, during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, effectively provides an exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems.

Since the tests are performed nearly water solid (except for an air I bubble for pressure control), at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent Increase in coolant activity above the LCO 3.4.6, "RCS Specific Activity," limits are minimized. In addition, the secondary containment will be OPERABLE, In accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in Reference 2. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, (continued)

HATCH UNIT 2 B 3.10-2 Amendment No. 195

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE "ECCS - Shutdown," would be more than adequate to keep the core SAFETY ANALYSES flooded under this low decay heat load condition. Small system leaks (continued) would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal hydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of the NRC Policy Statement apply. Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs.

A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described In LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required due to P/T limits, however, which require testing at temperatures > 212 0F, while the ASME system hydrostatic test itself requires the safety/relief valves to be gagged, preventing their OPERABILITY. Additionally, even with required minimum reactor coolant temperatures < 212 0F, RCS temperatures may drift above 212°F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with Inservice leak and hydrostatic testing.

While this Special Operations LCO Is provided for Inservice leak and hydrostatic testing, and for scram time testing initiated In conjunction with an Inservice leak or hydrostatic test, parallel performance of other tests and Inspections is not precluded.

Ifit Is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to 'NA" and suspending the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown.' The additional requirements for secondary containment LCOs to be met will provide (continued)

HATCH UNIT 2 B 3.10-3 Amendment No. 195

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO sufficient protection for operations at reactor coolant temperatures (continued) > 212°F for the purpose of performing an inservice leak or hydrostatic test, and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable requirements. I APPLICABILITY The MODE 4 requirements may only be modified for the performance of, or as a consequence of, Inservice leak or hydrostatic tests, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, so that these operations can be considered as In MODE 4, even though the reactor coolant temperature is > 212 0 F. The additional requirement for secondary containment OPERABIUTY according to the Imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur. Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be Inoperable or not within limits, will not result In separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for each requirement of the LCO not met provide appropriate compensatory measures for separate requirements that are not met As such, a Note has been provided that allows separate Condition entry for each requirement of the LCO.

Ifan LCO specified in LCO 3.10.1 is not met, the ACTIONS applicable to the stated requirements are entered Immediately and complied with.

Required Action A.1 has been modified by a Note that clarifies the Intent of another LCO's Required Action to be in MODE 4 includes reducing the average reactor coolant temperature to < 212 0F.

(continued)

HATCH UNIT 2 B 3.10-4 Amendrment No. 195

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES ACTIONS A.2.1 and A.2.2 (continued)

Required Action A.2.1 and Required Action A.2.2 are alternate Required Actions that can be taken instead of Required Action A.1 to restore compliance with the normal MODE 4 requirements, and thereby exit this Special Operation ICO's Applicability. Activities that could further Increase reactor coolant temperature or pressure are suspended immediately, in accordance with Required Action A.2.1, and the reactor coolant temperature Is reduced to establish normal MODE 4 requirements. The allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Required Action A.2.2 Is based on engineering judgment and provides sufficient time to reduce the average reactor coolant temperature from the highest expected value to S 212°F with normal cooldown procedures. The Completion Time is also consistent with the time provided In LCO 3.0.3 to reach MODE 4 from MODE 3.

SURVEILLANCE SR 3.10.1.1 REQUIREMENTS The LCOs made applicable are required to have their Surveillances met to establish that this LCO is being met. A discussion of the applicable SRs is provided In their respective Bases.

REFERENCES 1. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI.

2. FSAR, Section 15.1.40.

HATCH UNIT 2 B 3.10-5 Amendment No. 195 I