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Volume 10, Revision 0, Davis-Besse, Unit 1 - Improved Technical Specifications Conversion, ITS Section 3.5 Emergency Core Cooling Systems.
	ML072200474
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Site:	Davis Besse
Issue date:	08/03/2007
From:	; FirstEnergy Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
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Attachment 1, Volume 10, Rev. 0, Page 1 of 98 ATTACHMENT 1 VOLUME 10 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

Revision 0 Attachment 1, Volume 10, Rev. 0, Page 1 of 98

Attachment 1, Volume 10, Rev. 0, Page 2 of 98 LIST OF ATTACHMENTS

1. ITS 3.5.1

2. ITS 3.5.2

3. ITS 3.5.3

4. ITS 3.5.4 Attachment 1, Volume 10, Rev. 0, Page 2 of 98

, Volume 10, Rev. 0, Page 3 of 98 ATTACHMENT 1 ITS 3.5.1, CORE FLOODING TANKS (CFTs) , Volume 10, Rev. 0, Page 3 of 98

, Volume 10, Rev. 0, Page 4 of 98 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 10, Rev. 0, Page 4 of 98

Attachment 1, Volume 10, Rev. 0, Page 5 of 98 ITS 3.5.1 ITS 314.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

CORE FLOODING TANKS LIMITING CONDITION FOR OPERATION LCO 3.5.1 3.5.1 gE hreactor coolant system core flooding tank (CFT) shall be OPERABLE with:

SR 3.5.1.1 a. The isolation valve open, > 7480 and 8078

b. A contained borated water volume between 7 and 8004gallons of SR 3.5.1.2 borated water, SR 3.5.1.4 c. Ž 2600 and : 3500 ppm of boron, and >'567and 633 I SR 3.5.1.3 d. A nitrogen cover-pressure of between 5 and 625 psig.

APPLICABILITY: MODES 1, 2 and 3*.

ACTION:

ACTION A a. With one CFT inoperable because of boron concentration not within limits, restore the inoperable CFT to OPERABLE status within 72 Foursrbe in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce the ACTION C ptCS-pressure to less than 800 psig within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ACTION B - . . With any CFT inoperable for reasons other -than boron concentration not within limits, restore the CFT to OPERABLE tus within one hour r be in HOT STANDBY -within the next 6 ACTION Cthe and reduce ACoursfollowing the RCS pressure to less than 800 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Dl AOO proposed AECT=ION -eA03 SIJlRVFTI IANrl: RFO1[7PFMFNT5 4.5.1 Each core flooding tank shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by:

SR 3.5.1.2, 1. Verifying the contained borated water volume and nitrogen SR 3.5.1.3 cover-pressure in the tanks, and SR 3.5.1.1 2. Verifying that each tank isolation valve is open.

Applicability With Reactor Coolant pressure > 800 psig.

DAVIS-BESSE, UNIT I 3/4 5-1 Amendment No. 49-.-, 207 Page 1 of 2 Attachment 1, Volume 10, Rev. 0, Page 5 of 98

Attachment 1, Volume 10, Rev. 0, Page 6 of 98 ITS 3.5.1 ITS EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REMUIREMENTS (Continued)

SR 3.5.1.4 b.. At least once per 31 days, and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of each solution volume increase of ! 80 gallons that is not the resul.t of addition from the borated water storage tank (BWST), by verifying the boron concentration of the CFT solution.

SR 3.5.1.5 c. At least once per 31 days by verifying that ower to the isolation valve operator is disconnected by loc ing the §reakersl lin fte open popitioni.

d. At least on*e per REFUELING INTERVAL by verifying that each core flooding ta@k isolation valve opens automaticall y and is interlockeq against closing whenever the Reactar Coolant System pressure e~ceeds 800 psig. t DAVIS-BESSE, UNIT I 3/4 5-2 Amendment No. +-94-r 218 Page 2 of 2 Attachment 1, Volume 10, Rev. 0, Page 6 of 98

Attachment 1, Volume 10, Rev. 0, Page 7 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.5.1 requires "each" reactor coolant system core flooding tank (CFT) to be OPERABLE. ITS LCO 3.5.1 requires "two" CFTs to be OPERABLE. This changes the CTS by specifying the exact number of ECCS CFTs required to be OPERABLE.

This change is acceptable because the total number of ECCS CFTs installed in the Davis-Besse design is two. This change is designated as administrative because it does not result in any technical changes to the CTS.

A03 CTS 3.5.1 does not contain a specific ACTION for two CFTs inoperable. With two CFTs inoperable, CTS 3.0.3 would be entered. ITS 3.5.1 ACTION D directs entry into LCO 3.0.3 when two CFTs are inoperable. This changes the CTS by specifically stating to enter LCO 3.0.3 in this System Specification.

This change is acceptable because the actions taken when two CFTs are inoperable are unchanged. Adding this ACTION is consistent with the ITS convention of directing entry into ITS LCO 3.0.3 when multiple ACTIONS are presented in the ITS, and entry into these multiple ACTIONS could result in a loss of safety function. This change is designated as administrative because it does not result in any technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.5.1 .c specifies that each CFT shall be demonstrated OPERABLE by verifying that the power to the isolation valve operator is disconnected "by locking the breaker in the open position" once per 31 days: ITS SR 3.5.1.5 requires the same verification, but does not specify the Davis-Besse Page 1 of 3 Attachment 1, Volume 10, Rev. 0, Page 7 of 98

Attachment 1, Volume 10, Rev. 0, Page 8 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs) manner in which to remove power. This changes the CTS by moving the procedural detail of power removal to the Bases.

The removal of this detail for performing a Surveillance Requirement for CFT isolation valve power removal from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement for verification that power is removed from each CFT isolation valve operator (ITS SR 3.5.1.5). Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Bases Control Program which is specified in Chapter 5 of the Technical Specifications. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 CTS LCO 3.5.1 .b requires each core flooding tank (CFT) contained water volume be between 7555 gallons and 8004 gallons of borated water. CTS LCO 3.5.1 .d requires each CFT nitrogen cover pressure be between 575 psig and 625 psig.

In the ITS, the CFT borated water volume is specified in ITS SR 3.5.1.2 and the CFT nitrogen cover pressure is specified in ITS SR 3.5.1.3. ITS SR 3.5.1.2 requires the borated water volume in each CFT to be > 7480 gallons and

< 8078 gallons and ITS SR 3.5.1.3 requires the nitrogen cover pressure in each CFT to be > 567 psig and < 633 psig. This changes the CTS by allowing a wider range for the CFT borated water volume and nitrogen cover pressure.

The OPERABILITY of each Reactor Coolant System (RCS) CFT ensures that a sufficient volume of borated water will beimmediately forced into the reactor vessel in the event the RCS pressure falls below the pressure of the tanks. This initial surge of water into the vessel provides the initial cooling mechanism during large RCS pipe ruptures. The CTS LCO limits on volume, boron concentration and nitrogen cover pressure ensure that the assumptions used for CFT injection in the safety analysis are met.

CTS LCO 3.5.1.b presently requires each RCS CFT to be OPERABLE with a contained borated water volume between 7555 and 8004 gallons of borated water. For ITS SR 3.5.1.2, this requirement would be modified to require

__7480 gallons and < 8078 gallons of borated water. CTS LCO 3.5.1 .d presently requires each RCS CFT to be OPERABLE with a nitrogen cover pressure of between 575 and 625 psig. For ITS SR 3.5.1.3, this requirement would be modified to require a nitrogen cover pressure of ->567 psig and -<633 psig.

The CFT borated water volume and nitrogen cover gas requirements specified in the CTS have not changed since the original issuance of the Technical Specifications, and are believed to be based on values that account for some instrument uncertainty. However, based on the most recent calculations, additional uncertainty is warranted. Rather than revise the values to include this Davis-Besse Page 2 of 3 Attachment 1, Volume 10, Rev. 0, Page 8 of 98

Attachment 1, Volume 10, Rev. 0, Page 9 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs) additional uncertainty, it is proposed to revise these values to be consistent with the analytical limits. The appropriate uncertainty is reflected in the surveillance procedure acceptance criteria, which is dependent upon the instrumentation (e.g., control panel indication or computer point) used to verify the value.

Furthermore, the ITS Bases will indicate that the values are analytical limits.

In summary, the proposed changes will result in ITS values that are consistent with the analytical limits for CFT borated water volume and nitrogen cover pressure. The appropriate instrument uncertainty is reflected in the surveillance procedure acceptance criteria, which verifies that the LCO requirements are met.

This acceptance criteria are dependent upon the instrumentation (e.g., control panel indication or computer point) used to verify the values. This approach will continue to provide confidence that the analytical limits will not be violated, such that the accident analyses will remain valid. Therefore, this change is acceptable because there will be no adverse effect on nuclear safety. This change is designated as less restrictive since a wider range for the CFT borated water volume and nitrogen cover pressure limits is allowed in the ITS than is allowed in the CTS.

L02 (Category5 - Deletion of Surveillance Requirement) CTS 4.5.1 .d requires verification that each CFT isolation valve opens automatically and is interlocked against closing whenever the Reactor Coolant System pressure exceeds 800 psig at least once per REFUELING INTERVAL. ITS 3.5.1 does not retain this requirement. This changes the CTS by deleting the Surveillance Requirement.

The purpose of CTS 4.5.1 .d is to verify that each CFT isolation valve opens automatically and is interlocked open when the RCS pressure is > 800 psig. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required function. ITS SR 3.5.1.1 requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that each CFT isolation valve is open and ITS SR 3.5.1.5 requires verification every 31 days that the power is removed from each CFT isolation valve. Removing power from the isolation valves, as required by ITS SR 3.5.1.5, effectively defeats the automatic feature being tested by CTS 4.5.1.d. Furthermore, since the LCO Applicability includes MODES 1 and 2 and MODE 3 with RCS pressure

> 800 psig, meeting ITS SR 3.5.1.1 and SR 3.5.1.5 prior to entering the Applicability (as required by ITS SR 3.0.4) and during operation in the Applicability (as required by ITS SR 3.0.1) will always ensure that the CFT isolation valves are locked open with power removed anytime the RCS pressure is > 800 psig. This will preclude the need for the automatic feature. In addition, the ability of the isolation valves to open automatically is not credited in the safety analysis - the analysis assumes the valves are open at the time the accident occurs. This change is designated as less restrictive because a Surveillance which is required in the CTS is not required in the ITS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 10, Rev. 0, Page 9 of 98

Attachment 1, Volume 10, Rev. 0, Page 10 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 10 of 98

Attachment 1, Volume 10, Rev. 0, Page 11 of 98 CFTs 3.5.1 CTS 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 ,Core o Tanks (CFTs) 0 LCO 3.5.1 LCO 3.5.1 Two CFTs shall be OPERABLE.

APPLICABILITY: MODES 1 and 2, MODE 3 with Reactor Coolant System (RCS) pressure > r psig. 0 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a A. One CFT inoperable due A.1 Restore boron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to boron concentration concentration to within not within limits, limits.

Action b B. One CFT inoperable for B.1 Restore CFT to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A.

Action a, C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action b associated Completion Time of Condition A or B AND not met.

C.2 Reduce RCS pressure to hour

<ý Eqng . 0 DOC A03 D. Two CFTs inoperable. D.1 Enter LCO 3.0.3. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY LCO3.5.1.a, SR 3.5.1.1 Verify each CFT isolation valve is fully open. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.5.1.a.2 BWOG STS 3.5.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 11 of 98

Attachment 1, Volume 10, Rev. 0, Page 12 of 98 CFTs 3.5.1 CTS SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY I

Verify borated water volume in each CFT is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO3.5.1.b, 4.5.1.a.1 SR 3.5.1.2

> **gallonsg[-t.

~

T[7481

~8078j 0

LCO 3.5.1 .d, 4.5.1 a.1 SR 3.5.1.3 Verify nitrogen cover pressure in each CFT is

>- ps and < s.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 0

LCO 3.5.1.c, SR 3.5.1.4 Verify boron concentration in each CFT is 31 days 4.5.1.b

>[7] ppm and _<350C0 ppm.

AND 0

/2600 NOTE -------- -

Only required to be performed for affected CFT Once within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of

>ŽM0 gallonsfthat is not the result of 0 addition from the borated water storage tank 4.5.1.c SR 3.5.1.5 Verify power is removed from each CFT isolation valve operatorjwhen-fRS pressure is -_'z2000] psig.

31 days 0

BWOG STS 3.5.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 12 of 98

Attachment 1, Volume 10, Rev. 0, Page 13 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.1, CORE FLOODING TANKS (CFTs)

1. The brackets have been removed and the proper plant specific information/value is provided.

2. The Davis-Besse current licensing basis requires the power to be removed from each CFT isolation valve operator whenever the CFTs are required OPERABLE (CTS 4.5.1 .c). Therefore the allowance to only remove it at a RCS pressure above the Applicability pressure of 800 psig is not needed and has been deleted.

3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 13 of 98

Attachment 1, Volume 10, Rev. 0, Page 14 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 14 of 98

Attachment 1, Volume 10, Rev. 0, Page 15 of 98 CFTs B 3.5.1 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.1 Core Fl od Tanks (CFTs)

BASES BACKGROUND The function of the ECCS CFFTs ýis to supply water to the reactor vessel during the blowdown phase of a loss of coolant accident (LOCA), to provide inventory to help accomplish the refill phase that follows thereafter, and to provide Reactor Coolant System (RCS) makeup for a small break LOCA. Two CFTs are provided for these functions.

The blowdown phase of a large break LOCA is the initial period of the transient during which the RCS departs from equilibrium conditions, and heat from fission product decay, hot internals, and the vessel continues to be transferred to the reactor coolant. The blowdown phase of the transient ends when the RCS pressure falls to a value approaching that of the containment atmosphere. large break In the refill phase of a LOCA, which follows immediately, reactor coolant inventory has vacated the core through steam flashing and ejection through the break. The core is essentially in adiabatic heatup. The balance of inventory is then available to help fill voids in the lower plenum and reactor vessel downcomer so as to establish a recovery level at the bottom of the core and ongoing reflood of the core with the addition of safety injection water.

The CFTs are pressure vessels partially filled with borated water and pressurized with nitrogen gas. The CFrs are passive components, since no operator or control actions are required for them to perform their function. Internal tank pressure is sufficient to discharge the contents of the CFTs to the RCS if RCS pressure decreases below the CFT pressure. Each CFT is piped separately into the reactor vessel downcomer. The CFT injection lines are also utilized by the Low Pressure Injection (LPI) System. Each CFTi isolated from the RCS by a 0 motor operated isolation valve and two check valves in series. `

The motor operated isolation valves are normally open, with power removed from the valve motor to prevent inadvertent closure prior to or during an accident.

BWOG STS B 3.5.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 15 of 98

Attachment 1, Volume 10, Rev. 0, Page 16 of 98 CFTs B 3.5.1 BASES BACKGROUND ;(continued)

The CFTs thus form a passive system for injection directly into the reactor vessel. Except for the core flood line break LOCA, a unique accident that also disables a portion of the injection system, both tanks are assumed to operate in the safety analyses for Design Basis Events. Because injection is directly into the reactor vessel downcomer, and because it is a passive system not subject to the single active failure criterion, all fluid injection is credited for core cooling.

The CFT gas/water volumes, gas pressure, and outlet pipe size are selected to provide core cooling for a large break LOCA prior to the injection of coolant by the LPI System.

APPLICABLE The CFTs are taken credit for in both the large and small break LOCA SAFETY analyses at full power (Ref. 1). These Design Basis Accident (DBA)

ANALYSES analyses establish the acceptance limits for the CFTs. Reference to the analyses for these DBAs is used to assess changes in the CFTs as they relate to the acceptance limits. In performing the LOCA calculations, conservative assumptions are made concerning the availability of emergency injection flow. The assumption of the loss of offsite power is required by regulations. In the early stages of a LOCA with the loss of offsite power, the CFTs provide the sole source of makeup water to the RCS.

This is because the LPI pumps and high pressure injection (HPI) pumps cannot deliver flow until the emergency diesel generators (EDGs) start, come to rated speed, and go through their timed loading sequence.

The limiting large break LOCA is a double ended guillotine cold leg break at the discharge of the reactor coolant pump.

During this event, the CFTs discharge to the RCS as soon as RCS pressure decreases below CFT pressure. As a cons ative estimate., no Jcredit is taken fio HPI for large break OAs. LPI is ot assumed to occur until 35 s conds after the RCS pressure decretae s to the ESFAS 0 I actuation press/ire. INo operator action is assumed during the blowdown stage of a large break LOCA.

In the LOCA analysis, HPI and LPI are not credited until 40 seconds after actuation of the associated Safety Features Actuation System (SFAS) signal.

BWOG STS B 3.5.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 16 of 98

Attachment 1, Volume 10, Rev. 0, Page 17 of 98 CFTs B 3.5.1 BASES APPLICABLE SAFETY ANALYSES (continued)

The small break LOCA analysis also assumes a time delay after RSFAS actuation before pumped flow reaches the core. For the larger range of small breaks, the rate of blowdown is such that the increase in fuel clad temperature is terminated by the CFTs, with pumped flow then providing continued cooling. As break.size decreases, the CFTs and HPI pumps both play a part in terminating the rise in clad temperature. As break size continues to decrease, the role of the CFTs continues to decrease until the tanks are not required and the HPI pumps become responsible for terminating the temperature increase.

This LCO helps to ensure that the following acceptance criteria for the ECCS established by 10 CFR 50.46 (Ref. 2) will be met following a LOCA:

a. Maximum fuel element cladding temperature of 22000°F--

b. Maximum cladding oxidation of -<0.17 times the total cladding thickness before oxidationQ

c. Maximum hydrogen generation from a zirconium water reaction of

--0.01 times the hypothetical amount that would be generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to reatand

d. Core maintained in a coolable geometry.

Since the CFTs discharge during the blowdown phase of a LOCA, they do not contribute to the long term cooling requirements of 10 CFR 50.46.

The limits for operation with a CFT that is inoperable for any reason other than the boron concentration not being within limits minimize the time that the plant is exposed to a LOCA event occurring along with failure of a CFT, which might result in unacceptable peak cladding temperatures. If a closed isolation valve cannot be opened, or the proper water volume or nitrogen cover pressure cannot be restored, the full capability of one CFT is not available and prompt action is required to place the reactor in a MODE in which this capability is not required.

In addition to L CA analyses, the C Ts have been ass med to operate to provide bor ted water for reactivy control for sever overcooling 0 events such /s a large steam lineibreak (SLB).

BWOG STS B 3.5.1-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 17 of 98

Attachment 1, Volume 10, Rev. 0, Page 18 of 98 CFTs B 3.5.1 BASES APPLICABLE SAFETY ANALYSES (continued)

The CFTs are part of the primary success path that functions or actuates to mitigate a DBA that either assumes the failure .of or presents a challenge to the integrity of a fission product barrier.

The minimum volume requirement .for the CFTs ensures that both CFTs can provide adequate inventory to reflood the core and downcomer following a LOCA. The downcomer then remains flooded until the H PI and LPI systems start to deliver flow.

The maximum volume limit is based upon the need to maintain adequate gas volume to ensure proper injection, ensure the ability of the CFTs to fully discharge, and limit the maximum amount of boron inventory in the are the analytical F7480 CFTs. Values otp 5gallons and [ It]allons are specified. These valuesallowfor instruyfent inaccuracies. Values *f other parameters areI 8

0 0

limits. Values for the reated similarlv.

also the analytical56 limit S. The minimum nitrogen cover pressure requirement of [55psig ensures 0

that the contained gas volume will generate discharge flow rates during injection that are consistent with those assumed in the safety analysis.

The maximum nitrogen cover pressure limit of A psi'gensures that the 0 amount of CFT inventory that is discharged while the RCS depressurizes, and is therefore lost through the break, will not be larger than that predicted by the safety analysis. The maximum allowable boron concentration of M3500C ppm in the CFTs ensures that the sump pH will be 0 maintained lbetwoen 7.0 ano 1*1.01following a LOCA.

[at a relatively high pH- 2600 The minimum boron requirement of [2 0] pm is selected to ensure that 0

5% o the reactor will remain subcritical duringg the reflood stage of a large break LOCA. During a large break LOCA, J control rod assemblies are 0 assumed not to insert into the core, and the initial reactor shutdown is accomplished by void formation during blowdown. Sufficient boron concentration must be maintained in the CFTs to prevent a return to criticality during reflood.

The CFT isolation valves are not single failure proof; therefore, whenever these valves are open, power shall be removed from them. This precaution ensures that both CFTs are available during an accident. With power supplied to the valves, a single active failure could result in a valve closure, which would render one CFT unavailable for injection. Both CFTs are required to function in the event of a large break LOCA.

The CFTs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.5.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 18 of 98

Attachment 1, Volume 10, Rev. 0, Page 19 of 98 CFTs B 3.5.1 BASES LCO The LCO establishes the minimum conditions required to ensure that the CFTs are available to accomplish their core cooling safety function following a LOCA. Both CFTs are required to function in the event of a large break LOCA. If the entire contents of both tanks are not injected during the iblowdown phase of a large break LOCA, the ECCS acceptance criteria of 10 CFR 50.46 (Ref. 2) could be violated. For a CFT to be considered OPERABLE, the isolation valve must be fully open-Ei power removed abo [200 sig, and the limits established in the SR for contained volume, boron concentration, and nitrogen cover pressure must be met APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS pressure >7, 0psig, the CFT OPERABILITY requirements are based on full power operation.

-0 0 Although cooling requirements may decrease as power decreases, the CFTs are still required to provide core cooling as long as elevated RCS pressures and temperatures exist. A5 8 0

This LCO is only applicable at pressures70psig. Be o_70psig, the rate of RCS blowdown is such that the safety injection pumps can provide adequate injection to ensure that peak clad temperature remains below the 10 CFR 50.46 (Ref. 2) limit of 2200°F.

0 In MODE 3 with RCS pressure _0ig, and in MODES 4, 5, and 6, the CFT motor operated isolation valves are closed to isolate the CFTs from the RCS. This allows RCS cooldown and depressurization without discharging the CFTs into the RCS or requiring depressurization of the CFTs.

ACTIONS A.1 If the boron concentration of one CFT is not within limits, it must be returned to within the limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this condition, ability to maintain subcriticality may be reduced, but the effects of reduced boron concentration on core subcriticality during reflood are minor. Boiling of the ECCS water in the core during reflood concentrates the boron in the saturated liquid that remains in the core. In addition, the volume of the CFT is still available for injection. Since the boron requirements are based on the average boron concentration of the total volume of two CFTs, the consequences are less severe than they would be if the contents of a CFT were not available for injection. Thus, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to return the boron concentration to within limits.

BWOG STS B 3.5.1-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 19 of 98

Attachment 1, Volume 10, Rev. 0, Page 20 of 98 CFTs B 3.5.1 BASES ACTIONS (continued)

B.1 If one CFT is inoperable for a reason other than boron concentration, the

,CFT must be returned to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition it cannot be assumed that the CFTwill perform its required function during a LOCA. Due to the severity of the consequences should a LOCA occur in these conditions, the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time to open the valve, remove power to the valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the inoperable CFT to OPERABLE status. The Completion Time minimizes the time the plant is potentially exposed to a LOCA in these conditions.

C.1 and C.2 If the CFT cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status., the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and RCS pressure reduced to -- M ---

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

D.1 If more than one CFT is inoperable, the unit is in a condition outside the accident analysis; therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that each CFT isolation valve is fully open, as indicated in the control room, ensures that the CFTs are available for injection and ensures timely discovery if a valve should be less than fully open. If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a motor operated valve position should not change with power removed, a closed valve could result in accident analysis assumptions not being met. A 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered reasonable in view of administrative controls that ensure that a mispositioned isolation valve is unlikely.

BWOG STS B 3.5.1-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 20 of 98

Attachment 1, Volume 10, Rev. 0, Page 21 of 98 CFTs B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.2 and SR 3.5.1.3 Verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of each CFT's nitrogen cover pressure and the borated water volume is sufficient to ensure adequate injection during a LOCA. Due to the static design of the CFTs, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency usually allows .the operator to identify changes before the limits are reached.

Operating experience has shown that this Frequency is appropriate for early detection and correction of off normal trends.

SR 3.5.1.4 Surveillance once every 31 days is reasonable to verify that the CFT boron concentration is within the required limits, because the static design of the CFT limits the ways in which the concentration can be changed.

The Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage. Sampling within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after an 80 gallon volume increase will identify whether inleakage from the RCS has caused a reduction in boron concentration to below the required limit. It is not necessary to verify boron concentration if the added water inventory is from the borated water storage tank (BWST),

because the water contained in the BWST is within CFT boron concentration requirements. This is consistent with the recommendations of NUREG-1366 (Ref. 3).

SR 3.5.1.5 Verification every 31 days that power is removed from each CFT isolation (by locking the breaker in the open position) valve operato [when h S pressu-res p-sg ensures that an active failure could not result in the undetected closure of a CFT motor 0

operated isolation valve coincident with a LOCA. If this closure were to occur and the postulated LOCA is a rupture of the redundant CFT inlet piping, CFT capability would .be rendered inoperable. The rupture would render the tank with the open valve inoperable, and a closed valve on the other CFT would likewise render it inoperable. This would cause a loss of function for the CFTs. Since power is removed under administrative control, the 31 day Frequency will provide adequate assurance that the power is removed.

BWVOG STS B 3.5.1-7 Rev. 3.0. 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 21 of 98

Attachment 1, Volume 10, Rev. 0, Page 22 of 98 CFTs B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modifieil by a Note that allows power to be s pplied to the motor :operated is lation valves when RCS pressure is [2000] psig, thus allowing operatiofhal flexibility by avoiding unnecessa delays to 0

manipulate the Ireakers during plant startups or shut owns.

REFERENCES 1 FSAR, Section M6.3].

2. 10CFR50.46.

0@

00

3. D- .NU.REG-1366,1Februa p-99( Decer1992 BWOG STS B 3.5.1-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 22 of 98

Attachment 1, Volume 10, Rev. 0, Page 23 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.1 BASES, CORE FLOODING TANKS (CFTs)

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

3. The brackets have been removed and the proper plant specific information/value has been provided.

4. Changes made to be consistent with changes made to the Specification.

5. Changes made to be consistent with the Specification. There is no Note to SR 3.5.1.5 in NUREG-1430, Rev. 3.1.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 23 of 98

Attachment 1, Volume 10, Rev. 0, Page 24 of 98 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 24 of 98

Attachment 1, Volume 10, Rev. 0, Page 25 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.1, CORE FLOODING TANKS (CFTs) 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGE L01 Davis-Besse is converting to the Improved Technical Specifications (ITS) as outlined in NUREG-1430, Rev. 3.1, "Standard Technical Specifications Babcock and Wilcox Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below is the description of this less restrictive change and the determination of No Significant Hazards Considerations for conversion to NUREG-1430.

The OPERABILITY of each Reactor Coolant System (RCS) core flooding tank (CFT) ensures that a sufficient volume of borated water will be immediately forced into the reactor vessel in the event the RCS pressure falls below the pressure of the tanks. This initial surge of water into the vessel provides the initial cooling mechanism during large RCS pipe ruptures. The CTS LCO limits on volume, boron concentration and nitrogen cover pressure ensure that the assumptions used for CFT injection in the safety analysis are met.

CTS LCO 3.5.1 .b presently requires each RCS CFT to be OPERABLE with a contained borated water volume between 7555 and 8004 gallons of borated water. For ITS SR 3.5.1.2, this requirement would be modified to require > 7480 and < 8078 gallons of borated water. CTS LCO 3.5.1.d presently requires each RCS CFT to be OPERABLE with a nitrogen cover pressure of between 575 and 625 psig. For ITS SR 3.5.1.3, this requirement would be modified to require a cover-pressure of > 567 and -<633 psig.

The CFT borated water volume and nitrogen cover gas requirements specified in the CTS have not changed since the original issuance of the Technical Specifications, and are believed to be based on values that account for some instrument uncertainty.

However, based on the most recent calculations, additional uncertainty is warranted.

Rather than revise the values to include this additional uncertainty, it is proposed to revise these values to be consistent with the analytical limits. The appropriate uncertainty is reflected in the surveillance procedure acceptance criteria, which is dependent upon the instrumentation (e.g., control panel indication or computer point) used to verify the value.

In summary, the proposed changes will result in ITS values that are consistent with the analytical limits for CFT borated water volume and nitrogen cover pressure. The appropriate instrument uncertainty is reflected in the surveillance procedure acceptance criteria which verify that the LCO requirements are met. This acceptance criteria are dependent upon the instrumentation (e.g., control panel indication or computer point) used to verify the value. This approach will continue to provide confidence that the analytical limits will not be violated, such that the accident analyses will remain valid.

Therefore, there will be no adverse effect on nuclear safety.

An evaluation has been performed to determine whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Davis-Besse Page 1 of 2 Attachment 1, Volume 10, Rev. 0, Page 25 of 98

Attachment 1, Volume 10, Rev. 0, Page 26 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.1, CORE FLOODING TANKS (CFTs)

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

Response: No.

The proposed ITS SR 3.5.1.2 borated water volume requirements and ITS SR 3.5.1.3 nitrogen cover-pressure requirements specified are consistent with the existing analytical limits. Accident initial conditions, probability, and assumptions remain as previously analyzed. The proposed changes do not invalidate the assumptions used in evaluating the radiological consequences of any accident. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed ITS SR 3.5.1.2 borated water volume requirements and ITS SR 3.5.1.3 nitrogen cover-pressure requirements specified are consistent with the existing analytical limits. Accident initial conditions and assumptions remain as previously analyzed, and the proposed changes do not introduce any new or different accident initiators. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed ITS SR 3.5.1.2 borated water volume requirements and ITS SR 3.5.1.3 nitrogen cover-pressure requirements specified are consistent with the existing analytical limits. Under the proposed changes, a sufficient margin of safety will continue to be provided. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, there is a finding of "no significant hazards consideration."

Davis-Besse Page 2 of 2 Attachment 1, Volume 10, Rev. 0, Page 26 of 98

Attachment 1, Volume 10, Rev. 0, Page 27 of 98 ATTACHMENT 2 ITS 3.5.2, ECCS - OPERATING , Volume 10, Rev. 0, Page 27 of 98

, Volume 10, Rev. 0, Page 28 of 98 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 28 of 98

Attachment 1, Volume 10, Rev. 0, Page 29 of 98 ITS 3.5.2 ITS EMERGENCY CORETCOOLINO SYTEMSN 0

Emc SUSYSTEMS - zus280 Fm LIMITI]NG CONDMTON FOR OPERATION 3.5.2 3.5.2 TwoliE~ 'i st subsystems shall be OPERABLE uFamp,'/ *Ath each sul sytncomprised of.

a. One OPERABL.E higb ressureinjec'tion (HPQ0 injection (LPI) pump,

b. One OPERABLE I*gpressure

c. One OPERAFBLE dky heat cooler, and/

d. An OPERABLE B path capable of aking sa from the bora water storage tank (BWST) on a safetyi signal and manually transferring suction to th containment sump during the APPLICABILITY: MODES 1, 2 and 3 S0 ACTI ON B WTth oae H W---_a. train inoperable. estore the inopiable HPI rain to OPERABLE status within 72 ACTION C h b'*iHOTSHUIT)WN with tena 121hurs. Add proposed Required Action C.1 ACTION A -__ b. -Wiý one LPI train or its associated decay heat cooler inoperable, restore the inoperable

-,,meat to OPERABLE status within 7 days ý-be in HOT SHUTDOWN within the next 12 ACTION C ou-rs.

Add proposed ACTION D A02 SURVEILANCE RU EMENTS 4.5.2 Each ECCS subsystem shll be demonstrated OPERABLE:

SR 3.5.2.1 a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise sec*ed in position, is in its correct position.

An exception applies the hFlpwnpsfr thepurpose of conducting Res Test Plan inspection atvlties. This craptan is valid during the ongoingThrteenth Refuelin* Outagefor entries into MODE 3from MOD. 4. Under this exception, neitherHPItrainis req-ed to be capable of taking A03e suctionfrom the LPI ains when alignedfor containment sump recircul ion. The BPI trains will otherwise be OPEABLE* Operationin MODE ) or MODE 2 while rlg upon the provisions of this erception isp, ,ieA/

DAVIS-BESSE, UNiT 1 3/4 5-3 Amendment No. 36,182, 253, 257 Page 1 of 4 Attachment 1, Volume 10, Rev. 0, Page 29 of 98

Attachment 1, Volume 10, Rev. 0, Page 30 of 98 ITS 3.5.2 ITS Revised by MRC Letter Dated SURVEILLANCE. RLOURENeS ,,,.eContsnuedl *, 1-- 8 SR 3.5.2.3 b. b. as once -"cR£MUI*

At least FU " KEVLFro (I a t ~rt

.t erati after aKTWL ro L0 IECS. piing h enran _b verifying that the .i .P s full ofv ater by vontng the pumsp-4aslngs n d s and LA02 "ippng high C. a visual I pection which verifies ny lthat no oose debris (rags, trash, clothi rý, etc.) is present net con lament Mhch could be transported to the containment emergency s and cause restriction o the pump suction during LOCA nditions. This visual I i* n shall be performed:

I. For all accessible areas of the conta* nt prior to establi hing CONTAIMIIENT INTEGRITY, a

2. For al areas of containment affected by an entry, at least once d ily while work Is ongoing and gain during the final exit a ter completion of work (contai nt closeou) when CONWTAI INTEGRITY is estab Ished.

d. At least once each REFUELING IKTERVAL by:

1. Verifying that the Interlocks:

a) Close DH-11 an DH-12 uddeen rIjze the preiiij zer

beatersIf either OHi-l or OH-12 S o simulated reactor coolant OVUMe-pressure IdAich Is greater. than the Allowable Vaue (4328. psig) is -*

applied. The Interlock to close ador DWI12 is 11fII.

ntrequired if the valve Is close -and 40V AC power

.is disconnected from Its motor operators. See ITS 3.4.14 b) Prevent the opening of OH-11 and OH-19 QM a siamulated or actual reactor coolant system pressur which Is greater than the Allowable Value (O8 psWe) is applied.

SR 3.5.2.7 2. a) A visual Inspection of the containment" emerpg .,

which verifies-that the subsystem sUctionihlets are not restricted by debris and that the suip components.

(trash racks streens, etc.) show no evidence of structural distress or corrosion.

SR 3.5.2.8 b) Verjf a ot aBorated Vater Storage Tank (K Fao .

I Low*-.L.w e'vel 191,erlock tripsI*tj'* the actor operatvr for me ST outlet isolation valves and the containment emergency s recirculation valves energized, the BMST OutleT ValvelY automatically close1 n ssecondsl after e peratar manually .pushes the control Mtch t *Ke --

Containment Emergency Sump Valvel HV-uu" YnM- RL which should be verified to open a11 !seo .

,3. Deleted DAVIS-SESSE, UNIT 1 3/4 S-4 Amendment o.

ne, 1,96, 196, 0-8, _-.41-216F218 Page 2 of 4 Attachment 1, Volume 10, Rev. 0, Page 30 of 98

Attachment 1, Volume 10, Rev. 0, Page 31 of 98 ITS 3.5.2 ITS 0 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continu.ed.

4. Verifying that a minimum of 290 cubic feet of trisodium phosphate dodecahydrate (TSP) is contained within the TSP storage baskets.

" See ITS 3.6.7

]

5. Deleted

6. Deleted ethat is not locked, sealed, or

e. At least once each REFUELING INTERVAL, by otherwise secured in oosition

Il Verif~ying that each automatic valve in the flow path 1ýtuats to j~ L04"x SR 3.5.2.4 its correct position on t]aey.l'folest signal,. *,,,o

[actuation JP SR 3.5.2.5 2. \ Verify~ing thaa~tea~ch B{PI and LPI pump starts automnattically upont

\receipt ofa[ - test signal.

f. Deleted SR 3.5.2.6 g. By verifying the correct position of each mechanical position stop for valves DH-14A and DH-14B.

I. Within 4 hojirs following completion of the op7ning of the valves to their me0hanical position stop or following *ompletion of LOS maintenance on the valve when the LPI systeri is required to be

]

OPERABUE. I

2. At least once each REFUELING INTERVAL.

DAVIS-BESSE, UNIT I 3/4 5-5 Amendment No. 20r,26,40, M.,207.25,26,263 Page 3 of 4 Attachment 1, Volume 10, Rev. 0, Page 31 of 98

Attachment 1, Volume 10, Rev. 0, Page 32 of 98 ITS 3.5.2 ITS EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

SR 3.5.2.2 h. By verifying each ECCS pump's developed head at the test flow point is greater than or equal to the required developed head, when tested pursuant to the requirements of Specification 4.0.5.

DAVIS-BESSE, UNIT 1 3/4 5-5a Amendment No. 256 Page 4 of 4 Attachment 1, Volume 10, Rev. 0, Page 32 of 98

Attachment 1, Volume 10, Rev. 0, Page 33 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.5.2 Action a states that when one High Pressure Injection (HPI) train is inoperable, it must be returned to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . CTS Action b states that when one Low Pressure Injection (LPI) train or it associated decay heat removal cooler is inoperable, it must be returned to OPERABLE status within 7 days. CTS 3.5.3 does not contain specific actions if there is less than 100% of the ECCS flow equivalent to a single OPERABLE train available (i.e., two HPI subsystems or two LPI subsystems inoperable). Thus a CTS 3.0.3 entry would be required. ITS 3.5.2 ACTION D directs entry into ITS LCO 3.0.3 when there is less than 100% of the ECCS flow equivalent to a single OPERABLE train available. This changes the CTS by specifically stating to enter ITS LCO 3.0.3 in this Specification.

This change is acceptable because the actions taken when there is less than 100% of the ECCS flow equivalent to a single OPERABLE train available are unchanged. Adding this ACTION is consistent with the ITS convention of directing entry into LCO 3.0.3 when multiple ACTIONS are presented in the ITS, and entry into these multiple ACTIONS could result in a loss of safety functions.

This change is designated as administrative because it does not result in any technical changes to the CTS.

A03 CTS LCO 3.5.2.a and Applicability footnote

states that an exception applies to the HPI pumps for the purpose of conducting Restart Test Plant inspection activities. This exception is valid during the ongoing Thirteenth Refueling Outage for entries into MODE 3 from MODE 4. Under this exception, neither HPI train is required to be capable of taking suction from the LPI trains when aligned for containment sump recirculation. The HPI trains will otherwise be OPERABLE.

Operation in MODE 1 or MODE 2 while relying upon the provisions of this exception is prohibited. ITS 3.5.2 does not retain this footnote. This changes the CTS by deleting this footnote, which applies only to the thirteenth refueling outage.

The CTS LCO 3.5.2.a and Applicability footnote is only valid for the thirteenth refueling outage. Currently, Davis-Besse is now past the thirteenth refueling outage cycle; thus there is no need to maintain this footnote in the Technical Specifications. This change is considered administrative because it does not result in any technical changes to the CTS.

Davis-Besse Page 1 of 8 Attachment 1, Volume 10, Rev. 0, Page 33 of 98

Attachment 1, Volume 10, Rev. 0, Page 34 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING MORE RESTRICTIVE CHANGES M01 CTS 3.5.2 Actions a and b requires that when one inoperable ECCS subsystem is not restored to OPERABLE status within the allowed Completion Times, the unit must be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In addition to maintaining the requirement for the unit to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (ITS 3.5.2 Required Action B.2) if the inoperable ECCS train is not restored to OPERABLE status within the allowed Completion Time, ITS 3.5.2 Required Action B.1 also requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This changes the CTS by requiring entry into MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when a shutdown is required.

This change is acceptable because the requirement to place the unit in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is based on operating experience and the need to reach the required conditions from full power in an orderly manner and without challenging unit systems. This change is designated as more restrictive because it imposes a time requirement on when the unit must be in MODE 3 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.2 states that two "independent" ECCS subsystems shall be OPERABLE and contains a description of what constitutes an OPERABLE subsystem. ITS 3.5.2 requires two ECCS trains to be OPERABLE, but the details of what constitutes an OPERABLE train are moved to the Bases.

This changes the CTS by moving the details of what constitutes an OPERABLE train to the Bases.

The removal of these details, which relate to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the CTS.

LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.5.2.b states, in part, to verify that the ECCS piping is full of water "by venting the ECCS pump casings and discharge piping high points." ITS SR 3.5.2.3 only requires verification that the ECCS piping is full of water. This changes the CTS by moving the details of how to verify the piping is full of water to the Bases.

Davis-Besse Page 2 of 8 Attachment 1, Volume 10, Rev. 0, Page 34 of 98

Attachment 1, Volume 10, Rev. 0, Page 35 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify the ECCS piping is full of water. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LA03 (Type 4 - Removal of LCO, SR, or other TS requirementto the TRM, UFSAR, ODCM, QAPM, /ST Program, or lIP) CTS 4.5.2.c requires a visual inspection for loose debris in containment for all accessible areas of containment prior to establishing containment integrity, and for all areas of containment affected by an entry, daily while work is ongoing and again during the final exit after completion of work when containment integrity is established. ITS 3.5.2 does not include this requirement. This changes the CTS by moving this requirement to the Technical Requirement Manual (TRM).

The removal of this Surveillance Requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS SR 3.5.2.7 still retains the requirement for an inspection of the containment sump for debris every 24 months. The purpose of CTS 4.5.2.c is to.

ensure that following a containment entry for maintenance or inspection, any debris is removed that could clog the containment sump following a LOCA. This is good housekeeping practice that should be part of any containment entry and is a detail not necessary to be included in the ITS to provide adequate protection of the public health and safety. Also this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a Surveillance Requirement is being removed from the Technical Specifications.

LA04 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.5.2.d.2.b) requires verification that on a Borated Water Storage Tank (BWST) Low - Low Level interlock trip, with the motor operators for the BWST outlet isolation valves and the containment emergency sump recirculation valves energized, the BWST Outlet Valve HV-DH7A (HV-DH7B) automatically close in < 75 seconds after the operator manually pushes the control switch to open the Containment Emergency Sump Valve HV-DH9A (HV-DH9B) which should be verified to open in < 75 seconds. ITS SR 3.5.2.8 only requires verification that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal. The SR is modified by a Note that states the SR is only required to be met when the motor operators for the BWST outlet valves and containment emergency sump valves are energized. This changes the CTS by Davis-Besse Page 3 of 8 Attachment 1, Volume 10, Rev. 0, Page 35 of 98

Attachment 1, Volume 10, Rev. 0, Page 36 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING moving the details of how to perform the verification to the Bases. The change to the time requirements for valve closure and opening is discussed in DOG LA05.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal when the motor operators for the valves are energized. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LA05 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.5.2.d.2.b) requires verification that on a Borated Water Storage Tank (BWST) Low - Low Level interlock trip, with the motor operators for the BWST outlet isolation valves and the containment emergency sump recirculation valves energized, the BWST Outlet Valve HV-DH7A (HV-DH7B) automatically close in < 75 seconds after the operator manually pushes the control switch to open the Containment Emergency Sump Valve HV-DH9A (HV-DH9B) which should be verified to open in < 75 seconds. ITS SR 3.5.2.8 only requires verification that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal when the motor operators for the valves are energized. This changes the CTS by moving the timing detail to the Inservice Testing (IST)

Program. The change to how the Surveillance is performed is discussed in DOC LA04.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal when the motor operators for the valves are energized. Also, this change is acceptable because these types of procedural details will be adequately controlled in the IST Program, which is controlled under 10 CFR 50.55a. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.

LA06 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.2.e.1 and 4.5.2.e.2 require verification of the automatic actuation of ECCS components on a "safety injection" test signal or "SFAS" test signal, respectively. ITS SR 3.5.2.4 and SR 3.5.2.5 do not state the specific type of signal, but only specify an actual or simulated "actuation" signal. This changes CTS by moving the type of actuation signal (i.e., SFAS) to the Bases. The Davis-Besse Page 4 of 8 Attachment 1, Volume 10, Rev. 0, Page 36 of 98

Attachment 1, Volume 10, Rev. 0, Page 37 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING change to replace "test" with "simulated" and allow both "actual or simulated actuation" signals to be used for these SRs is discussed in DOC L04.

The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that appropriate equipment actuates upon receipt of an actuation signal.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA07 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS 4.5.2.d.1.a) requires, in part, verifying the pressurizer heaters are de-energized on a Decay Heat Removal (DHR) System interlock signal. ITS 3.5.2 does not require verification that the pressurizer heaters are deenergized. This changes the CTS by moving the requirement to verify the pressurizer heaters are deenergized on a DHR System interlock signal to the Technical Requirements Manual (TRM).

If the RCS pressure exceeds the DHR System interlock setpoint (approximately 328 psig), the pressurizer heaters will de-energize unless both DHR System suction isolation valves (DH11 and DH12) are closed. This is to protect against over pressurizing the DHR System. However, the DHR System interlock signal also closes the two DHR System suction isolation valves. This feature of the DHR System interlock signal is being maintained and tested in the ITS, as shown in ITS LCO 3.4.14 and SR 3.4.14.4. Therefore, the pressurizer heater portion of the interlock, which provides a backup type signal is not necessary to be included in the ITS and is being moved to the TRM. The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Also this change is acceptable because the removed information will be adequately controlled in the TRM. The TRM is currently incorporated by reference into the UFSAR, thus any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information relating to meeting a Technical Specification requirement is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 8 - Deletion of Reporting Requirements) CTS 3.5.2 Action c requires that a Special Report be prepared and submitted to the NRC within 90 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to include the description of the circumstances of Davis-Besse Page 5 of 8 Attachment 1, Volume 10, Rev. 0, Page 37 of 98

Attachment 1, Volume 10, Rev. 0, Page 38 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING the event and the total accumulated actuation cycles to date. ITS 3.5.2 does not include this requirement.

The purpose of CTS 3.5.2 Action c is to provide information about the event to the NRC. This change is acceptable because the regulations provide adequate reporting requirements, and the reports do not affect continued plant operation.

A Licensee Event Report is required to be submitted by 10 CFR 50.73 (a)(2)(iv) describing any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF). Therefore, this report to the NRC is still required. However, 10 CFR 50.73 does not require that the report include the total accumulated actuation cycles to date. ITS 5.5.5, "Component Cyclic or Transient Limit," requires that controls are in place to track the cyclic and transient occurrences to ensure that components are maintained within the design limits. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

L02 (Category 5 - Deletion of Surveillance Requirement) CTS 4.5.2.b, in part, requires a verification that the ECCS piping is full of water prior to operation after ECCS piping has been drained. The ITS does not include this testing requirement. This changes the CTS by deleting a conditional Surveillance Requirement.

The purpose of CTS 4.5.2.b is to verify OPERABILITY of ECCS trains following draining of the piping. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is described in the Bases for ITS SR 3.0.1 and required under ITS SR 3.0.1. The OPERABILITY requirements for the ECCS subsystems are described in the Bases for ITS 3.5.2. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporates applicable acceptance criteria.

Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.5.2.e.1 requires verification that each ECCS automatic valve in the flow path actuates to its correct position. ITS SR 3.5.2.4 requires verification that each ECCS automatic valve in the flow path "that is not locked, sealed, or otherwise secured in position" actuates to the correct position. This changes the CTS by excluding those ECCS automatic valves that are locked, sealed, or otherwise secured in position from the verification.

Davis-Besse Page 6 of 8 Attachment 1, Volume 10, Rev. 0, Page 38 of 98

Attachment 1, Volume 10, Rev. 0, Page 39 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING The purpose of CTS 4.5.2.e.1 is to provide assurance that if an event occurred requiring the ECCS valves to be in their correct position, those requiring automatic actuation would actuate to their correct position. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Those automatic valves that are locked, sealed, or otherwise secured in position are not required to actuate on an ECCS actuation signal in order to perform their safety function because they are already in the required position. Testing such valves would not provide any additional assurance of OPERABILITY. Valves that are required to actuate will continue to be tested. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L04 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.5.2.e.1 and 4.5.2.e.2 require verification of the automatic actuation of ECCS components on a safety injection "test"signal or SFAS "test"signal, respectively. ITS SR 3.5.2.4 and SR 3.5.2.5 specify that the signal may be from either an actual or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test. The change to remove the specific type of actuation signal (i.e., safety injection and SFAS) to be used for these SRs is discussed in DOC LA07.

The purpose of CTS 4.5.2.e.1 and 4.5.2.e.2 is to ensure that the ECCS components operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L05 (Category5 - Deletion of Surveillance Requirement) CTS 4.5.2.g.1 describes a test that must be performed following repositioning of or maintenance to certain LPI System valves. The ITS does not include this testing requirement. This changes the CTS by deleting a conditional Surveillance Requirement.

The purpose of CTS 4.5.2.g.1 is to verify OPERABILITY of the LPI System following repositioning or maintenance on a valve that may alter subsystem flow characteristics. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is Davis-Besse Page 7 of 8 Attachment 1, Volume 10, Rev. 0, Page 39 of 98

Attachment 1, Volume 10, Rev. 0, Page 40 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS - OPERATING described in the Bases for ITS SR 3.0.1 and required under ITS SR 3.0.1. The OPERABILITY requirements for the ECCS trains are described in the Bases for ITS 3.5.2. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate control for test programs to ensure that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

Davis-Besse Page 8 of 8 Attachment 1, Volume 10, Rev. 0, Page 40 of 98

Attachment 1, Volume 10, Rev. 0, Page 41 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 41 of 98

Attachment 1, Volume 10, Rev. 0, Page 42 of 98 ECCS - Operating 3.5.2 CTS 3.5 EMERGENCY CORE COOLING SYSTEMS:(ECCS) 3.5.2 ECCS - Operating 3.5.2 LCO 3.5.2 Two ECCS trains shall be OPERABLE.

- -NOTE

['Operation in MODE/3 with high pressure injection,(H 1l)de-activated ýin accordance with LC 3.4.12, "Low Temperature Over ressure Protection (LTOP) System," is Ilowed for up to [4] hours.]

0 APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action b A. One low pressure injection (LPI)

A.1 Restore LPI subsystem to OPERABLE status.

N7Edays 0

subsystem inoperable.

Action a B. One or more trains B.1 Restore train(s) to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for reasons OPERABLE status.

other than Condition A.

Action a, C. Required Action and C.1 Be in MODE 3. .6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action b associated Completion Time not met. AND of Condition A or B 0

C.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months DOC A02 D. Less than 100% of the D.1 Enter LCO 3.0.3. Immediately ECCS flow equivalent to a single OPERABLE train available.

BVWOG STS 3.5.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 42 of 98

Attachment 1, Volume 10, Rev. 0, Page 43 of 98 CTS ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 [Veri the following valves are in the listed position 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with ower to the valve operator removed.

Valv Number Position Function

[1

[

[1

[]

1]

0

[I [1 [1 4.5.2.a SR 3.5.2.2 L-D Verify each ECCS manual, power operated, and automatic valve in the flow path, that is not locked, 31 days 0 sealed, or otherwise secured in position, is in the correct position.

4.5.2.b SR 3.5.2.3 [Verify ECCS piping is full of water.

A,4monmoths 0 4.5.2.h SIR3.20 Verify each ECCS pump's developed head at the In accordance 0

test flow point is greater than or equal to the with the Inservice required developed head. Testing Program 4.5.2.e.1 S R 3.5.2 4 ~ Verify each ECCS automatic valve in the flow path [ 8] months that is not locked, sealed, or otherwise secured in 00 position, actuates to the correct position on an actual or simulated actuation signal.

4.5.2.e.2 SR 3.5.2.1] Verify each ECCS pump starts automatically on an 8] months 00 actual or simulated actuation signal.

SR 3.5.2.7 [Veri the correct settings of stops for the following [18] months]

HPI top check valves:

a. MUV-2],

0

b. MUV-6], and

c. [MUV-1O].

BV\OG STS 3.5.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 43 of 98

Attachment 1, Volume 10, Rev. 0, Page 44 of 98 CTS ECCS - Operating 3.5.2

[correct position of each mechanical stop for the following valves SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.5.2.g SR 3.5.2. Verify the flo controllers fort e following LPII Ithrottle valveg operate pr operly months

-E 00

a. [DH -11O]and

b. [DH \-111].

DH-14B 4.5.2.d.2.a) SR 35.2.1 Verify, by visual inspection, each ECCS train months containment sump suction inlet is not restricted by debris and suction inlet trash racks and screens 00 show no evidence of structural distress or abnormal corrosion.

INET1 BWOG STS 3.5.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 44 of 98

Attachment 1, Volume 10, Rev. 0, Page 45 of 98 3.5.2 CTS O INSERT 1 4.5.2.d.2.b) SR 3.5.2.8 --------------

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

Only required to be met when the motor operators for the borated water storage tank (BWST) outlet valves and containment emergency sump valves are energized.

Verify each BWST outlet valve and containment 24 months emergency sump valve actuate to the correct position on a manual actuation signal.

Insert Page 3.5.2-3 Attachment 1, Volume 10, Rev. 0, Page 45 of 98

Attachment 1, Volume 10, Rev. 0, Page 46 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.2, ECCS - OPERATING

1. The brackets are removed and the proper plant specific information/value is provided.

2. This change is made consistent with the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.6.i.5.ii.

3. ISTS SR 3.5.2.1 and ISTS SR 3.5.2.7, which are bracketed Surveillance Requirements, have not been included in the Davis-Besse ITS. This is consistent with current licensing basis. The remaining SRs have been renumbered, as necessary, due to these deletions.

4. ITS SR 3.5.2.8, which requires a verification that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal, has been added consistent with current licensing basis. These valves do not receive an automatic signal from the Safety Features Actuation System (SFAS) instrumentation to place the valves in the containment recirculation mode.

Thus, they are not part of the testing required by ISTS SR 3.5.2.5 (ITS SR 3.5.2.4),

and a specific Surveillance is required for these valves.

5. The ISTS 3.5.2 LCO Note has been deleted since ITS 3.4.12 does not require the high pressure injection pumps to be de-activated.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 46 of 98

Attachment 1, Volume 10, Rev. 0, Page 47 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 47 of 98

Attachment 1, Volume 10, Rev. 0, Page 48 of 98 ECCS - Operating B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.2 ECCS - Operating BASES BACKGROUND The function of the ECCS is to provide core cooling to ensure that the reactor core is protected after .any of the following accidents:

a. Loss of coolant accident (LOCA)

b. Rod ejection accident (REA) f 0"*

c. Steam generator tube rupture (SGTR) and ZII.~~ ýteam line rea ýLB).0 There are two phases of ECCS operation: injection and recirculation. In the injection phase, all injection is initially added to the Reactor Coolant System (RCS) via the cold legs and to the reactor vessel. After the borated water storage tank (BWST) has been depleted, the ECCS recirculation phase is entered as the ECCS suction is transferred to the containment sump.

Two redundant, 100% capacity trains are provided. In MODES 1, 2, and 3, each train consists of high pressure injection (HPI) and low pressure injection (LPI) subsystems. In MODES 1, 2, and 3, both trains must be OPERABLE. This ensures that 100% of the core cooling requirements can be provided even in the event of a single active failure.

A suction header supplies water from the BWST or the containment sump to the ECCS pumps. Separate piping supplies each train. HPI discharges into each of the four RCS cold legs between the reactor coolant pump and the reactor vessel. LPI discharges into each of the two core flood nozzles on the reactor vessel that discharge into the vessel downcomer area. IControl valves are set to I~lance the HPI flow to the RCS. This flow 1alance directs sufficient flI* to the core to meet the analysis assu ptions following a small br 'ak LOCA in one of the RCS cold legs ne r an HPI nozzle. a to the RCS at an RCS The H PI pumps are capable of discharging pressure la bove the oj#ening setpoint Fhe pressurize safety valves.

The LPI pumps are capable of discharging to the RCS at an RCS pressure of approximately 20OpGb. When the BWST has been nearly 0 emptied, the suction for the LPI pumps is manually transferred to the BVWOG STS B 3.5.2-1 Rev. 3.1, 12/01105 Attachment 1, Volume 10, Rev. 0, Page 48 of 98

Attachment 1, Volume 10, Rev. 0, Page 49 of 98 ECCS - Operating B 3.5.2 BASES BACKGROUND :(continued) containment sump. The HPI pumps cannot take suction directly from the sump. If HPI is still needed, a cross connect from the discharge side of the LPI pump to the suction of the HPI pumpswould be opened. This is known as "piggy backing" HPI to LPI and enables continued HPI to the RCS, if needed, after the BWST is emptied.

In the long term cooling period, flow paths in .the LPI System are reaching an to established preclude thehigh unacceptably possibility of boric acid concentration. One inflow the path core is/from region the/

INSERT 1 hot leg through the decay heat suctiqh line from the hot leg an then in a0

ýreverse diregtion through the conta~hment sump outlet line in/t the sump./

The other flow path is through the pressurizer auxiliary spray line trom pump 2 in piggy back HPI with one LPI tra into the pressurizer4nd through the hot leg ir to the top LPI pump 2. J Iregion rfte core.

The HPI subsystem also functions to supply borated water to the reactor core following increased heat removal events, such as largeS-Bs* .

During low temperatL re conditions in the RCS, limitati s are placed on the maximum numb r of ECCS pumps that may be OfEERABLE. Refer to the Bases for LCO *.4.12, "Low Temperature Overpr ssure Protection (LTOP) System," foj the basis of these requirements./

During a large break LOCA, RCS pressure will decrease to < 200 psia in S< 20 seconds. The ECCS is actuated upon receipt of an Engineered Safety _ Safety FeatureiActuation System (SFAS) signal. The actuation of Features (ESF) ar loads is accomplished in a programmed time sequence. If LEottsite power is available, th~pafeguardj loads start immediately i programm quence . If offsite power is not available, the eafe e buses shed normal operating loads and are ----- __S emergency connected to the diesel generators. ISafe2ard loads are then actuated in the programmed time sequence. The time delay associated with diesel starting, sequenced loading, and pump starting determines the time required before pumped flow is available to the core following a LOCA.

The active ECCS components, along with the passive core flood (CFTs) and the BWST covered in LCO 3.5.1, "Core Flood Tanks (CFTs).,"

and LCO 3.5.4, "Borated Water Storage Tank (BWST)," provide te n cooling water necessary to meet 10 CFR 50.46 (Ref. 1).

BWOG STS B 3.5.2-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 49_of 98

Attachment 1, Volume 10, Rev. 0, Page 50 of 98 B 3.5.2 O INSERT 1 uses the discharge of LPI pump 1 through a line that bypasses the RCS to Decay Heat Removal (DHR) System suction line and allows reverse flow into the DHR System drop line.

Insert Page B 3.5.2-2 Attachment 1, Volume 10, Rev. 0, Page 50 of 98

Attachment 1, Volume 10, Rev. 0, Page 51 of 98 ECCS - Operating B 3.5.2 BASES APPLICABLE The LCO helps to ensure that the following acceptance criteria for the SAFETY ECCS, established by 10 CFR 50.46 (Ref. 1), will be met following a ANALYSES LOCA:

2 20 0

a. Maximum fuel element cladding temperature is < °F LD

b. Maximum cladding oxidation is s 0.17 times the total cladding thickness before oxidatio

c. Maximum hydrogen generation from a zirconium water reaction is (7*

__0.01 times the hypothetical amount generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to reac

d. Core is maintained in a coolable geometry and

e. Adequate long term core cooling capability is maintained.

The LCO also helps ensure that containment temperature limits are met.

Both HPI and LPI subsystems are assumed to be OPERABLE in the large break LOCA analysis at full power (Ref. 2). This analysis establishes a minimum required flow for the HPI and LPI pumps, as well as the minimum required response time for their actuation. The H PI pump is credited in the small break LOCA analysis. This analysis establishes the flow and discharge head requirements at the design point for the HPI pump. The SGTR and L,_B analyses also credit the HPI pump but are not limiting in their design. M---4m The large break LOCA event with a loss of offsite power and a single failure (disabling one ECCS train) establishes the OPERABILITY requirements for the ECCS. During the blowdown stage of a LOCA, the RCS depressurizes as primary coolant is ejected through the break into the containment. The nuclear reaction is terminated either by moderator voiding during large breaks or CONTROL ROD assembly insertion for small breaks. Following depressurization, emergency cooling water is injected into the reactor vessel core flood nozzles, then flows into the downcomer, fills the lower plenum, and refloods the core.

The LCO ensures that an ECCS train will deliver sufficient water to match decay hea[ rates soon enough to minimize core uncovery for a large break LOCA. It also ensures that the HPI pump will deliver sufficient water for a small break LOCA and provide sufficient boron to maintain the core subcritical.

BWOG STS B 3.5.2-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 51 of 98

Attachment 1, Volume 10, Rev. 0, Page 52 of 98 ECCS - Operating B 3.5.2 BASES APPLICABLE SAFETY ANALYSES (continued)

In the LOCA analyses, HPI and LPI are not credited until seconds after actuation of.the SFAS signal. This is.based on a loss of offsite power and the associated time delays in startup and loading of the emergency diesel generator (EDG). Further, LPI flow is not credited until RCS pressure drops below the pump's shutoff head. For a )rge break L CA, HP Ijýn ot c red ited a-t all.

The ECCS trains satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO In MODES 1, 2, and 3, two independent .(and redundant) ECCS trains are required to ensure that at least one is available, assuming a single failure in the other train. Additionally, individual components within the ECCS trains may be called upon to mitigate the consequences of other transients and accidents.

In MODES 1, 2, and 3, an ECCS train consists of an HPI subsystem and an LPI subsystem. Each train includes the piping, instruments, and the decay heat removal controls to ensure an OPERABLE flow path capable of taking suction from the BWST upon an [SFAS signal and manually transferring suction 0

cooler (for signal manuallyesuction the LPI to the containment sump.

subsystem o During an event requiring ECCS actuation, a flow path is provided to ensure an abundant supply of water from the BWST to the RCS via the HPI and LPI pumps and their respective discharge flow paths to each of the four cold leg injection nozzles and the reactor vessel. In the long term, this flow path may be manually transferred to take its supply from the containment sump and to supply its flow to the RCS via two paths, as described in the Background section.

The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains.

As indicated in the N e, operation in MODE 3 with E CS trains de-activated pursuant to LCO 3.4.12 is necessary for pla ts with an LTOP System arming temp rature at or near the MODE 3 oundary temperature of [350 F. LCO 3.4.12 requires that ce ain components be de-activated at and elow the LTOP System armin temperature. When this temperature is t or near the MODE 3 bounda temperature, time is needed to restore e systems to OPERABLE stat s.

BVVOG STS B 3.5.2-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 52 of 98

Attachment 1, Volume 10, Rev. 0, Page 53 of 98 ECCS - Operating B 3.5.2 BASES APPLICABILITY In MODES 1, 2, and 3, the ECCS train OPERABILITY requirements for the limiting Design Basis Accident, a large break LOCA, are based on full power operation. Although reduced power would not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The HPI pump performance is based on the small break LOCA, which establishes the pump performance curve and is less dependent on power. HPI pump Iperformance, ueoirements are based on a simaIlreak LOCAJ MODES 2 and 3 requirements are bounded by the MODE 1 analysis.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops -

MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "Decay Heat Removal (DHR) and Coolant Circulation - High Water Level," and LCO 3.9.5, "Decay Heat Removal (DHR) and Coolant Circulation - Low Water Level."

ACTIONS A.1 With one LPI subsystem inoperable, action must be taken to restore it to OPERABLE status within 7 days. In this condition, the remaining OPERABLE ECCS train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure to the remaining LPI subsystem could result in loss of ECCS function. TheF7]day Completion Time is reasonable to perform corrective maintenance on the inoperable LPI subsystem. The[7day Completion Time is based on the findings of the deterministic and probabilistic analysis in Reference 3. Reference 3 concluded that extending the Completion Time to M7]days for an inoperable LPI Em subsystemfproves plant operational flexibility while simultaneously (

reducing overall plant risk. This is because the risks incurred by having the LPI subsystem unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during plant shutdown operations.

B.1 inoperable With one or more trains ýj e nd at least 100% of the injection flow equivalent to a single OPERABLE ECCS train available, components inoperable for reasons other than Condition A must be returned to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on NRC recommendations (Ref. 4) that are based on a risk evaluation and is a reasonable time for many repairs.

BWOG STS B 3.5.2-5 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 53 of 98

Attachment 1, Volume 10, Rev. 0, Page 54 of 98 ECCS - Operating B 3.5.2 BASES ACTIONS (continued)

An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS.

The LCO requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. This allows increased flexibility in plant operations under circumstances when components in opposite trains are inoperable.

An event accompanied by a loss of offsite power and the failure of an EDG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown the risk of having one full ECCS train inoperable to be sufficiently low to justify continued operation for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

With one or more componentnoperable such that 100% of the flow equivalent to a single OPERABL ECCS train is not available, the facility is in a condition outside the acciden nalyses. Therefore, LCO 3.0.3 must be immediately entered.i 0

C.1 and C.2 If the inoperable components cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.1 Conditiongis applicable with one or more trains inoperable. The allowed Completion Time is based on the assumption that at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available.

With less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, the facility is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

BWOG STS B 3.5.2-6 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 54 of 98

Attachment 1, Volume 10, Rev. 0, Page 55 of 98 ECCS - Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 REQUIREMENTS Verification of proper alve position ensures that the f ow path from the ECCS pumps to the CS is maintained. Misalignme t of these valves could render both E CS trains inoperable. Securing these valves in position by removal f power or by key locking the c ntrol in the correct position ensures tha the valves cannot change posi ion as the result of 0 an active failure. Tlese valves are of the type desc ibed in Reference 5, which can disable t e function of both ECCS trains nd invalidate the accident analyses. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is cons dered reasonable in view of other admi istrative controls that will ensur the unlikelihood of a mispositioned valv .

SR 3.5.2 --- 0 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. The 31 day Frequency is appropriate because the valves are operated under administrative control, and an inoperable valve position would only affect a single train. This Frequency has been shown to be f acceptable through operating experience.

Mo'v ve SR 3.5.2.2 '-Iby venting the from Page ECCS pump B 3. 5.2-8 to here SR 3.5.2.3 casings and discharge piping high With the exception of systems in operation, the ECCS pumps are points, )

normally in a standby, nonoperating mode. As such, the flow path piping r- i has the potential to develop voids and pockets of entrained gases.

T

Aaintaining the piping from the ECCS pumps to the RCS full of water ensure@ that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an ISFAS signal or during 24 month shutdown cooling. The 31 y-requency takes into consideration the gradual .nature of gas accumulation in the ECCS pipinga the existence of procedural controls governing system operation and the fact that some venting points are not accessible during normal operation.

BWOG STS B 3.5.2-7 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 55 of 98

Attachment 1, Volume 10, Rev. 0, Page 56 of 98 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2. - 0 Periodic surveillance -testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other ihydraulic component problems is required by the ASME Code (Ref. %. This type of testing

__.E 0 Move to Page may be accomplished by measuring the pump's developed head at only B 3.5.2-7 before __ one point of the pump's characteristic curve. This verifies both that the SR 3.5.2.3 measured performance is within an acceptable -tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the plant accident analysis. SRs are specified in the Inservice Testing Program of the ASME Code. The ASME Code provides the activities and Frequencies necessary to satisfy the requirements.

SR 3.5.2.an-d SR 3 .5 .2 U/'

.- 1 0 These SRs demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated ESFAS signal and that each ECCS pump starts on receipt of an actual or simulated MSFAS signal.

This SR is not required for valves that are locked, sealed, or otherwise 24 secured in position under administrative controls. The Ornonth Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reator at power. The fg'honth Frequency is also acceptable based on <2 consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of the IESFAS testing, and equipment performance is monitored as part of the Inservice Testing Program.

SR 3.5.2.7 This Surveillance ery!ures that these valves are in th proper position to prevent the HFPI purp from exceeding its runout limt. This 18 month Frequency is base* on the same reasons as those stated for SR 3.5.2.5 and SR 3.5.2.6. /

BWOG STS B 3.5.2-8 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 56 of 98

Attachment 1, Volume 10, Rev. 0, Page 57 of 98 ECCS - Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

S SRR. ... F-- DH-14Aofand position DH-14B is correct to ensure ]

each mecha ical stop for valves D This Surveillance nsues atthe Iflow contro ler *the LPI t rott e 2 Nvalves will auto6ically control th LPI flow rate he desired is maintained within range and prevent LPlpump runout as RCS pressure decreases after a LOCA. The Tjfgionth Frequency is justified by the same reasons as those stated for SR 3.5.2.* 1 SR 3.5.2r SR 35.

In addition, the Periodic inspections of the containment sump suction inlet ensure that it screen components is unrestricted and stays in proper operating condition.*The Fnnt k00 include the Frequency is based on the need to perform this Surveillance under the vertical strainers. conditions that apply during a plant outage, on the need to preserve access to the location, and on the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This Frequency has been found to be sufficient to detect abnormal degradation and has been confirmed by operating experience. N 2 REFERENCES 1. 10CFR50.46.

2J'FSAR, Section N6.31 00Q

3. BAW-2295-A, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray System.

4. NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

5. IE Information Notice 87,-Qi, "RHR Valve Misalignment Causes Degradation of ECCS in PVVRs-,January 6, 1987. 0 ASME Code for Operation and Maintenance of Nuclear Power Plants.

0

6. NRC letter from J.B. Hopkins (NRC) to D.C. Shelton, Administrative Changes to Technical 7.

Specifications Bases, dated October 21, 1992.

NRC letter from J.B. Hopkins (NRC) to L.F. Storz, Issuance of Amendment 182, dated 0

December 16. 1993.

BWVOG STS B 3.5.2-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 0, Page 57 of 98

Attachment 1, Volume 10, Rev. 0, Page 58 of 98 B 3.5.2 (O INSERT 2 SR 3.5.2.8 This Surveillance verifies that on a Borated Water Storage Tank Level -

Low Low signal, the BWST outlet valve (HV-DH7A and HV-DH7B) automatically closes after the operator manually pushes the control switch to open the containment emergency sump valve (HV-DH9A and HV-DH9B), and the containment emergency sump valve opens. As Noted, the SR is only required to be met when the motor operators for the BWST outlet valves and the containment emergency sump valves are energized. The motor operators are normally de-energized to prevent spurious closing of the BWST outlet valves and opening of the containment emergency sump valves in the event of a control room fire.

This allowance was originally approved by the NRC in References 6 and 7. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage.

Insert Page B 3.5.2-9 Attachment 1, Volume 10, Rev. 0, Page 58 of 98

Attachment 1, Volume 10, Rev. 0, Page 59 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.2 BASES, ECCS - OPERATING

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Changes are made to reflect those changes made to the Specification.

4. ISTS Applicable Safety Analyses has been changed to reflect the Davis-Besse LOCA analyses time for when HPI and LPI are credited after actuation of the SFAS signal.

5. The brackets have been removed and the proper plant specific information/value has been provided.

6. The last paragraph in ACTIONS B.1 Bases is discussing the actions to take if less than 100% of the flow equivalent to a single OPERABLE ECCS train is not available.

This is describing ACTION D, and the ACTIONS D.1 Bases adequately discusses the actions to take in this condition. Therefore, the paragraph has been deleted.

7. Changes have been made to be consistent with the Specification.

8. Typographical error corrected.

9. Editorial change for clarity.

10. Duplicate sentence deleted.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 59 of 98

Attachment 1, Volume 10, Rev. 0, Page 60 of 98 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 60 of 98

Attachment 1, Volume 10, Rev. 0, Page 61 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.2, ECCS - OPERATING There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 61 of 98

Attachment 1, Volume 10, Rev. 0, Page 62 of 98 ATTACHMENT 3 ITS 3.5.3, ECCS - SHUTDOWN , Volume 10, Rev. 0, Page 62 of 98

, Volume 10, Rev. 0, Page 63 of 98 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 63 of 98

Attachment 1, Volume 10, Rev. 0, Page 64 of 98 ITS 3.5.3 ITS EMERGENCY CORE COOLING STSTEKS ECCS SULSYSTEY - T < DSO'F LIMITING COMTTTON FOR OPERATION LCO 3.5.3 3.5.3 As a minimm. one EC.CS subsystem m=prlsed of the folloing &hall be OPERABLE:

a. One OPERABLE deca heat_ (DH) pump,--

b. One OPERABLE 4. oler, and

c. An OPERABLE flow/path capable of taking suctno frbo the bor ted water storagetak (BST) and manually tronsfe ring suction containment emer ency sump during the recSrcusateon phase of opera tion. a APPLI-TUBLITY: MODE: 4.

ACTI ON- Add proposed ACTION Note A02

a. With no ECS susse PEPABLE Ibecause of tbeýinoperabil ity A0 ACTION A the5n Du.

iof f oolro n* thp flow-crath fromg theBTI restore at' least one ECCS subsystem to OPERA£BLE status within I-ont hour or ,maintain the Reactor Coolant System Tavq less thanl 2B0"F by use of alternate beat removal methodsl In the event toe ECCS is actuated and inJec~s water into the reactor coolart system, a Special Report s~all be prepared and

b. submitted to &he Commission pursuant to Spzclflcation 6.9.2 [

within 90 days describing the circumstances of the actuation and the totzi accumulated actuation cycle" to date.

SURVETLLANCE R!OUIRflOHT SR 3.5.3.1 4.5.3 The EM~S ;ubsystem shall be de~nstritaed OPERABLE per5e I oplicable Srveilliance Require nts of 4.iZ OAVIS-EESSZ. UNIT I 3/4 S-6 Amendment No.-a 57 SR 3.5.2.1. SR 3.5.2.2, SR 3.5.2.3.

SR 3.5.2.4, SR 3.5.2.5, SR 3.5.2.6, S0 SR 3.5.2.7, SR 3.5.2.8 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 64 of 98

Attachment 1, Volume 10, Rev. 0, Page 65 of 98 DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 The ITS 3.5.3 ACTIONS include a Note that states LCO 3.0.4.b is not applicable to the ECCS low pressure injection (LPI) subsystem. CTS 3.5.3 does not include this Note. This changes the CTS by including the ACTION Note.

The purpose of the ITS 3.5.3 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.5.3 with an inoperable ECCS LPI subsystem. Currently, CTS 3.5.3 precludes entering MODE 4 when the ECCS subsystem is inoperable.

ITS LCO 3.0.4 has been added in accordance with the Discussion for Changes for ITS Section 3.0, DOC L01. This LCO allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable. ITS LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability of a Specification if a risk assessment is performed and determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. This addition of this restriction (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable ECCS LPI subsystem, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.5.3 does not currently allow this option. This change is considered administrative because it does not result in technical changes to the CTS.

A03 CTS 4.5.3 states that ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2. ITS SR 3.5.3.1 states the specific Surveillances of ITS 3.5.2 that must be performed. This changes the CTS by clearly stating the SRs to perform.

This change is acceptable because the change is editorial. The Surveillances listed in ITS SR 3.5.3.1 are those that are considered "applicable" under the CTS. All ITS 3.5.2 Surveillances are included in ITS SR 3.5.3.1. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.5.3 Action a requires that when the ECCS subsystem is inoperable, the ECCS subsystem must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the RCS Tavg must be maintained < 2801F by use of alternate heat removal methods.

ITS 3.5.3 ACTION A requires the immediate initiation of action to restore the Davis-Besse Page 1 of 3 Attachment 1, Volume 10, Rev. 0, Page 65 of 98

Attachment 1, Volume 10, Rev. 0, Page 66 of 98 DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN required ECCS LPI subsystem to OPERABLE status. This changes the CTS by specifically stating that action to restore the ECCS LPI subsystem to OPERABLE status must be initiated immediately, and does not allow alternate decay heat methods to be used in lieu of restoring the subsystem.

The purpose of CTS 3.5.3 Action a is to provide compensatory measures for when the required ECCS LPI subsystem is inoperable. While CTS Action a appears to provide a finite completion time to restore the LPI subsystem, it does not. Maintaining the Reactor Coolant System Tavg less than 280°F is the same as remaining in MODE 4. This would allow the unit to not meet the restoration requirement of CTS 3.5.3 Action a, but still remain in the Applicability of the LCO.

Therefore, this new ITS 3.5.3 ACTION is acceptable because it ensures that action is immediately initiated to restore the ECCS LPI subsystem to OPERABLE status and continues to be taken until the LPI subsystem is restored to OPERABLE status. This change is designated as more restrictive because it ensures that action is taken to restore the ECCS LPI subsystem to OPERABLE status.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type I - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.5.3 states that one ECCS subsystem shall be OPERABLE and contains a description of what constitutes an OPERABLE subsystem. In addition, CTS 3.5.3 Action a also describes what constitutes an inoperable ECCS subsystem. ITS 3.5.3 requires an ECCS LPI subsystem to be OPERABLE, but the details of what constitutes an OPERABLE LPI subsystem are moved to the Bases.

The removal of these details, which relate to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for one ECCS LPI subsystem to be OPERABLE and provides proper Conditions to identify the various allowed inoperabilities. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5 of the ITS. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is removed from the Technical Specifications.

Davis-Besse Page 2 of 3 Attachment 1, Volume 10, Rev. 0, Page 66 of 98

Attachment 1, Volume 10, Rev. 0, Page 67 of 98 DISCUSSION OF CHANGES ITS 3.5.3, ECCS - SHUTDOWN LESS RESTRICTIVE CHANGES L01 (Category 8 - Deletion of Reporting Requirements) CTS 3.5.3 Action b requires that a Special Report be prepared and submitted to the NRC within 90 days following an ECCS actuation that results in water being injected into the Reactor Coolant System. The report is to include the description of the circumstances of the actuation and the total accumulated actuation cycles to date. ITS 3.5.3 does not include this requirement.

The purpose of CTS 3.5.3 Action b is to provide information about the event to the NRC. This change is acceptable because the regulations provide adequate reporting requirements, and the reports do not affect continued plant operation.

A Licensee Event Report is required to be submitted by 10 CFR 50.73(a)(2)(iv) describing any event or condition that results in manual or automatic actuation of any Engineered Safety Feature (ESF). Therefore, a report to the NRC is still required. However, 10 CFR 50.73 does not require that the report include the total accumulated actuation cycles to date. ITS 5.5.5, "Component Cyclic or Transient Limit," requires that controls are in place to track the cyclic and transient occurrences to ensure that components are maintained within the design limits. This change is designated as less restrictive because reports that would be submitted under the CTS will not be required under the ITS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 10, Rev. 0, Page 67 of 98

Attachment 1, Volume 10, Rev. 0, Page 68 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 68 of 98

Attachment 1, Volume 10, Rev. 0, Page 69 of 98 CTS ECCS - Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS - Shutdown low pressure injection (LPI) subsystem 3.5.3 LCO 3.5.3 One ECCS -tr-i-n shall be OPERABLE. 00

/ Kif-%'.r b.*

I JE

1. A DHR train fray be considered OPERABLE durin* alignment and operation fof DHR, if capable of being manually re ligned to the ECCS mod of operation. I 2--

2. High pressur* injection (HPI) may be de-activated 6 accordance with LCO 3..12. "Low Temperature Overpressure/Protection (LTOP) System." /

APPLICABILITY: MODE 4.

ACTIONS LPI subsystem 0 LC....4......... not applicabe is- - ---

DOC A02 LCO 3.0.4.b is not applicable to ECCSI H -lop*

CONDITION LPI subsystem REQUIRED ACTION COMPLETION TIME Action a A. Required ECCS dey A.1 Initiate action to restore Immediately I heaVemoval (DH inoperable.

loop required ECCS Dop to OPERABLE status.

0 B. Required ECCS HP/

subsystem inopera 7le. B.1 Restore required ECCS H PI subsystem to OPERABLE status.

/hour 1- .1. 4-I ____

Q C. Required Action a d C.1 Be in MODE 5.

associated Compl tion Time of Condition B not *24hours met.

BWOG STS 3.5.3-1 Rev. 3.0. 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 69 of 98

Attachment 1, Volume 10, Rev. 0, Page 70 of 98 CTS ECCS - Shutdown 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.5.3 SR 3.5.3.1 For all equipment required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs

[SR 3.5.2.1M SR 3.5.2.6 SR 3.5.2.2 IR 3.5.2.71 MIR SR 3.5.2.3M 3.5.2.4 R3.5.2.8* 00 SR 3.5.2.5 BWOG STS 3.5.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 70 of 98

Attachment 1, Volume 10, Rev. 0, Page 71 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.3, ECCS - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature.

2. The ISTS LCO 3.5.3 Note 1 allowance that an LPI subsystem can be placed in the decay heat removal mode and not be considered inoperable for the ECCS function has not been adopted in the Davis-Besse ITS. The current licensing basis for Davis-Besse only requires one LPI subsystem to be OPERABLE. Therefore, it is not appropriate to allow this one required ECCS subsystem to be in a condition such that it cannot be automatically aligned to the ECCS mode. Davis-Besse will continue to consider the LPI subsystem inoperable for the ECCS function if it is aligned in the decay heat removal mode.

3. The ISTS 3.5.3 requirements for the ECCS subsystem to include a high pressure injection (HPI) subsystem have not been adopted in the Davis-Besse ITS, consistent with current licensing basis. The HPI subsystem requirements were deleted as part of Amendment 57, dated May 5, 1983.

4. Changes have been made to SR 3.5.3.1 due to changes made to the SRs of ITS 3.5.2.

5. The brackets have been removed and the proper plant specific information/value is provided.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 71 of 98

Attachment 1, Volume 10, Rev. 0, Page 72 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 72 of 98

Attachment 1, Volume 10, Rev. 0, Page 73 of 98 ECCS - Shutdown B 3.5.3 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.3 ECCS - Shutdown BASES BACKGROUND The Background section for Bases B 3.5.2, "ECCS - Operating," is applicable to these Bases, with the following modifications.

aplcbl otEse [by~st~e:WJ-:> 03 In MODE 4, the required ECOS! consists oftwo leparate a single low subsystems: high ressure injection (H P1) and low p essure injection pressure injection 2 (LPI), each consisting of two redundant, 100% capaoit train . (LPI) subsystem (i.e., decay D The ECCS flow patt-consist~of piping, valves, heat exchangerg, and heat cooler) pump:, such that water from the borated water storage tank (BWST) can be injected into the Reactor Coolant System (RCS) following the accidents described in Bases 3.5.2.

APPLICABLE The Applicable Safety Analyses section of Bases 3.5-2 is applicable to SAFETY these Bases.

ANALYSES Due to the stable conditions associated with operation in MODE 4 and the reduced probability of occurrence of a Design Basis Accident (DBA), the ECCS operational requirements are reduced. Th d in theseActuation reductions isoat certain automatic Engineered at existem (,%,FAS) actuation is not available.

In thiý'MODE Feature sufficient time 0 of the required ECCS/to mitigate the exitsfor/anual actuation consengera;:~ of a DIBA.I bsystemn I sut! ubsystem 0 Only one ECCS~triTis required for MODE 4. This requirement dictate_

that single failures are not considered during this MODE. The ECCS t

- fsliutin satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). 0 LCO In MODE 4, one of the two independent (and redundant) ECCS 5is P..

1subsystems}

bsstem In MODE 4, an ECCS consists of Ian HPI su s-stem andlan LPI An LPI subsystem Isubsystem. Idarainrcludesthe piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the BWST and transferring suction to the containment sump.

INSERTc2 During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the BWST to the RCS, via the LPI pumpgand0 t spective supply headers, to each of the~f--!

cold LI ctonl nozzles. In the long term, this flow path may be witched to take its supply from the containment sump land to ipts Iflow to the B -h a-nd cold leqs.

[emergency BWOG STS B 3.5.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 73 of 98

Attachment 1, Volume 10, Rev. 0, Page 74 of 98 B 3.5.3 (O INSERT 1 an LPI pump, a decay heat cooler, and (O INSERT 2 during the recirculation phase of operation Insert Page B 3.5.3-1 Attachment 1, Volume 10, Rev. 0, Page 74 of 98

Attachment 1, Volume 10, Rev. 0, Page 75 of 98 ECCS - Shutdown B 3.5.3 BASES LCO (continued)

This LCO is modified by two Notes. The first allows DHR train to be considered OPERA LE during alignment and opera on for decay heat removal, if capable f being manually realigned (re ote or local) to the ECCS mode of ope ation and not otherwise inopera le. This allows operation in the D mode during MODE 4. The s cond Note states that Q HPI actuation may be deactivated in accordance h LCO 3.4.12, 'Low Temperature Ove ressure Protection (LTOP) Sy em." Operator action is then required t initiate H PI. In the event of a I s of coolant accident (LOCA) requiring HPI actuation, the time required for operator action has been shown by a alysis to be acceptable.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for the ECCS are covered by LCO 3.5.2.

In MODE 4 with the RCS temperature below 280'F, one OPERABLE

_subsyste SLPI subsystem ECCmi is acceptable without single failure consideration, on the basis of the stable reactivity condition of the reactor and the limited core cooling 0

requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7. "RCS Loops -

MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by I *(fl "* Q A fI-IPH *nr C'.nt~l~nt C.irr'alItinn - I-irnh WA~f~r I vtl"nr LCO 3.9.5, "DHR and Coolant Circulation - Low Water Level."

ACTIONS A Note prohibits the application of LCO 3.0.4.b t inoperable ECCS[] R* LPI subsystem 1!~ when entering MODE 4 from MODE 5. There is an increased risk associated with entering MODE 4 from MODE 5 with D"moperable 2

and2 the provisions of LCO 3.0.4.b, which allow entry into a MODE or other the LPI subsystem specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components should not be applied in this circumstance.

erovision BWOG STS B 3.5.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 75 of 98

Attachment 1, Volume 10, Rev. 0, Page 76 of 98 ECCS - Shutdown B 3.5.3 BASES ACTIONS (continued)

A.1 If no LPI subsystemtr n is OPERABLE, the unit is not prepared to respond to a LOCA or to continue cooldown using the LPI pumps and decay heat exchangers. The Completion Time of immediately, which would initiate action to restore at least one ECCS LPI subsystem to OPERABLE status, ensures that prompt action is taken to restore the required cooling capacity. Normally, in MODE 4, reactor decay heat must sym] removed by an LPtr, noperating with suction from the RCS. If no 0 ,1.be u LI_trn is OPERABLE for this function, reactor decay heat must be removed by some alternate method, such as use of the steam generator(s). The alternate means of heat removal must continue until the inoperable ECCS LPI subsystem can be restored to operation so that LI continuation of decay heat removalF(ýD ) is provided.

With both- Dg pumps and heat exchangers inoperable, it would be unwise to require the plant to go to MODE 5, where the only available 0

_____heat removal system is the LPI operating in the P _.ode. eremar O Ieý Therefore, the appropriate action is to initiate measures to restore one ECCS LPI subsystem and to continue the actions until the subsystem is restored to OPERABLE status.

B.1 If no ECCS HPI sub ystem is OPERABLE, due to th inoperability of the HPI pump or flow p th from the BWST, the plant is ot prepared to provide high press re response to Design Basis Ev nts requiring ESFAS.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Compl tion Time to restore at least on ECCS HPI subsystem 0 to OPERABLE s us ensures that prompt action i taken to provide the required cooling apacity or to initiate actions to pl ce the plant in MODE 5, where n ECCS train is not required.

C.1 When the Required ction of Condition B cannot be mpleted within the required Completio Time, a controlled shutdown s uld be initiated. The allowed Completio Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable based on operating 0

experience, to rea h MODE 5 from full power cond ions in an orderly manner and with t challenging plant systems.

BWOG STS B 3.5.3-3 Rev. 3.0, 03131/04 Attachment 1, Volume 10, Rev. 0, Page 76 of 98

Attachment 1, Volume 10, Rev. 0, Page 77 of 98 ECCS - Shutdown B 3.5.3 BASES SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The applicable. Surveillance descriptions from Bases 3.5.2 apply.

REFERENCES The applicable references from Bases 3.5.2 apply.

BVOG STS B 3.5.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 77 of 98

Attachment 1, Volume 10, Rev. 0, Page 78 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.3 BASES, ECCS - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. Changes are made to reflect changes made to the Specification.

3. Typographical error corrected.

4. Editorial change for clarity.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 78 of 98

Attachment 1, Volume 10, Rev. 0, Page 79 of 98 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 79 of 98

Attachment 1, Volume 10, Rev. 0, Page 80 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.3, ECCS - SHUTDOWN There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 80 of 98

Attachment 1, Volume 10, Rev. 0, Page 81 of 98 ATTACHMENT 4 ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)

Attachment 1, Volume 10, Rev. 0, Page 81 of 98

, Volume 10, Rev. 0, Page 82 of 98 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 10, Rev. 0, Page 82 of 98

Attachment 1, Volume 10, Rev. 0, Page 83 of 98 ITS @ITS 3.5.4 EMERGENCY CORE COOLING SYSTEMS BORATED WATER STORAGE TANK LIMITING CONDITION FOR OPERATION LCO 3.5.4 3.5.4 The borated water storage tank (BWST) shall be OPERABLE with:

SR 3.5.4.2 a. An available borated water volume of between 500,100 and 550,000 gallons, SR 3.5.4.3 b. >Ž2600 and

2800 ppm of boron, and SR 3.5.4.1 c. A minimum water temperature ofAdd proposed maximum water temperatu APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

ACTION A a. With the BWST inoperable because of boron concentration or temperature. not ALwthin limits, restore the BWST to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at ACTION C least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWAN

',within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION B b. [With the BWST inoperable for reasons other than boron concentration or temperature not within limits, restore the BWST to OPERABLE status within one our'6orbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD ACTION C [SH-fUTDO)WN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.5.4 The BWST shall be demonstrated OPERABLE:

a. At least once per 7 days by:

SR 3.5.4.2 1. Verifying the available borated water volume in the tank, SR 3.5.4.3 2. Verifying the boron concentration of the water.

SR 3.5.4.1 b. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by verifying the water temperature when outside air temperature <35°F.

DAVIS-BESSE, UNIT 1 3/4 5-7 Amendment No. 36, 123, 191, 207, 24]

Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 83 of 98

Attachment 1, Volume 10, Rev. 0, Page 84 of 98 DISCUSSION OF CHANGES ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS LCO 3.5.4.c provides a minimum BWST water temperature limit but does not provide a maximum water temperature limit. ITS SR 3.5.4.1 includes both a minimum and a maximum BWST water temperature limit. In addition, the ITS SR 3.5.4.1 Note only requires the BWST water temperature to be verified within the maximum limit ifthe ambient air temperature is greater than new maximum BWST water temperature limit. This changes the CTS by adding a new maximum BWST water temperature limit and requires it checked every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless the ambient air temperature is less than or equal to the maximum BWST water temperature limit.

The purpose of LCO 3.5.4.c is to ensure the BWST water temperature is within the limits assumed in the accident analysis. However, the CTS only provides the minimum BWST water temperature limit. This change adds a maximum BWST water temperature limit of 901F. This change is acceptable since the BWST maximum water temperature limit of 90°F is consistent with the maximum injection water temperature assumed in the LOCA analysis. This change is designated as more restrictive because it adds a new maximum BWST water temperature limit RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 84 of 98

Attachment 1, Volume 10, Rev. 0, Page 85 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 85 of 98

Attachment 1, Volume 10, Rev. 0, Page 86 of 98 OCTS BWST 3.5A4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Borated W~ater Storage Tank (BWST)

LCO 3.5.4 LCO 3.5.4 The BWST shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action a A. BVST boron A.1 Restore BWST to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months concentration not within OPERABLE status.

limits.

OR BVST water temperature not within limits.

Action b B. B\AST inoperable for B.1 Restore BWST to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A.

Actions a and b C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months BWOG STS 3.5.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 86 of 98

Attachment 1, Volume 10, Rev. 0, Page 87 of 98 CTS BWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.5.4.c, SR 3.5.4.1 ... ---- -.------ -

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

4.5.4.b Only required to be performed when ambient air F3 5 t~empera~ture is <_,[ F or >

0 Verify BWST borated water temperature 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 0

and tt [

A 1__

90 I _

3.5.4.a, 4.5.4.a.1 SR 3.5.4.2 Verif B T borated water volume is

>1[41 000gallons Iftand!

449 00 gallonsM 7 days 0

FE". ~

500100550,0ý00 3.5.4.b, SR 3.5.4.3 Verify BWST boron concentration is > [ ] ppm 7 days 0 4.5.4.a.2 and _5M* rpip2600 C-42800 _M BWVOG STS 3.5.4-2 Rev. 3.0. 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 87 of 98

Attachment 1, Volume 10, Rev. 0, Page 88 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)

1. The brackets have been removed and the proper plant specific information/value is provided.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 88 of 98

Attachment 1, Volume 10, Rev. 0, Page 89 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 89 of 98

Attachment 1, Volume 10, Rev. 0, Page 90 of 98 BWST B 3.5.4 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.4 Borated Water Storage Tank (BWST)

BASES BACKGROUND The BWST supports the ECCS and the Containment Spray System by providing a source of borated water for ECCS and containment spray pump operation. In addition, the BWST supplies borated water to the Yrefuelin-olfor refueling operations.

The BWST supplies two ECCS trains, each by a separate, redundant supply header. Each header also supplies one train of the Containment Spray System. A normally open, motor operated isolation valve is provided in each header to allow the operator to isolate the BWST from the ECCS after the ECCS pump suction has beenftransferred to the containment sump following depletion of the BWST during a loss of coolant accident (LOCA). Use of a single BWST to supply both ECCS trains is acceptable because the BWST is a passive component, and passive failures are not assumed in the analysis of Design Basis Events (DBEs) to occur coincidentally with the Design Basis Accident (DBA).

The ECCS and c ntainment spray pumps are providd with recirculation lines that ens

each pump can maintain minim flow requirements when oper ng at shutoff head conditions.

This LCO ensures that:

a. The BWST contains sufficient borated water to support the ECCS during the injection phase,

b. Sufficient water volume exists inJe containment sump to support continued operation of the ECCS and containment spray pumps at the time of transfer to the recirculation mode of cooling and

c. The reactor remains subcritical following a LOCA.

Insufficient water inventory in the BWST could result in insufficient cooling capacity of the ECCS when the transfer to the recirculation mode occurs.

Improper boron concentrations could result in a reduction of SDM or lex eeboric acid precipitation in the core following a LOCA, as well as excessive caustic stress corrosion of mechanical components and systems inside containment.

BWAOG STS B 3.5.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 90 of 98

Attachment 1, Volume 10, Rev. 0, Page 91 of 98 BWST B 3.5.4 BASES APPLIC ,ABLE During accident conditions, the BWST provides a source of borated SAFET water to the high pressure injection (HPI), low pressure injection (LPI),

ANALY*SES and containment spray pumps. As such, it provides containment cooling and depressurization, core cooling, and replacement inventory and is a source of negative reactivity for reactor shutdown. The design basis transients and applicable safety analyses concerning each of these systems are discussed in the Applicable Safety Analyses section of 4--- 6sesof FLCO ) ecifions B13.5.2, "ECCS - Operating," and ED.6.6, "Containment L Spray andooling Systems." These analyses are used to assess Echanges to the BVT in order to evaluate their effects in relation to the acceptance limits.

The limits on volume ofŽ a j lo ns and 5 44-90galons ,al are C2 Per NUREG- based on several factors. Pufficient deliverable volume must be available 0800, Section 6.3 (Ref. 1), to provide at least 20 minutes of full flow of all ECCS pumps prior to t transfer to the containment sump for recirculationtg-ives_

c 0 0D (D

the operator adequate time to prepare for switchover to containment sump recirculation. ý

/ A second factor that affects the minimum required BWST volume is the The minimum required volume provides ability to support continued ECCS pump operation after the manual

[a volume in excess of 20 minutes of fullI transfer to recirculation occurs. When ECCS pump suction is transferred flow of all ECCS pumps. J to the sump, there must be sufficient water in the sump to ensure adequate net positive suction head (NPSH) for the LPI and containment .f2 spray pumps. This NPSH calculation is described in the FSAR (Ref and the amount of water that enters the sump from the BWST and other 0 sources is one of the input assumptions. Since the BWST is the main source that contributes to the amount of water in the sump following a LOCA, the calculation does not take credit for more than the minimum volume of usable water from the BWST.

The third factor is that the volume of water in the BVWST must be within a range that will ensure the solution in the sump following a LOCA is within a specified pH range that will minimize the evolution of iodine and the effect of chloride and caustic stress corrosion cracking on the mechanical systems and components.

The volume range ensures that refueling requirements are met and that the capacity of the BWST is not exceeded. Note that the volume limits refer to total, rather than usable, volume required to be in the BWST; a certain amount of water is unusable because of tank discharge line location or other physical characteristics.

BVWOG STS B 3.5.4-2 Rev. 3.0, 03/31104 Attachment 1, Volume 10, Rev. 0, Page 91 of 98

Attachment 1, Volume 10, Rev. 0, Page 92 of 98 BWST B 3.5ý4 BASES APPLICABLE SAFETY ANALYSES (continued)

The [2 0] ppm limit for minimum boron concentration was established to ensure that, following a LOCA, with a minimum BWST level, the reactor will remain subcritical in the cold condition following mixing of the BWST and Reactor Coolant System (RCS) water volumes. Large break LOCAs assume that oý.ýf the control rods remain withdrawn from the core. 0 The minimum and maximum concentration limits both ensure that the solution in the sump following a LOCA is within a specified pH range that will minimize the evolution of iodine and the effect of chloride and caustic stress corrosion cracking on the mechanical systems and components.

The 2 0 ppmmximum limit for boron concentration in the BWST is also based on the potential for boron precipitation in the core during the long term cooling period following a LOCA. For a cold leg break, the core dissipates heat by pool nucleate boiling. Because of this boiling phenomenon in the core, the boric acid concentration will increase in this region. If allowed to proceed in this manner, a point may be reached where boron precipitation will occur in the core. Post LOCA emergency procedures direct the operator to establish dilution flow paths in the LPI System to prevent this condition by establishing a forced flow path through the core regardless of break location. These procedures are based on the minimum time in which precipitation could occur, assuming that maximum boron concentrations exist in the borated water sources used for injection following a LOCA.

boric acid precipitation Imeasures, which are --

Boron concentrations in the BWST re pitonhnas m .

in excess e nlyi.

of the limit couldr tosolubility avoid reaching limit the The gF limit on the temperature of the solution in the BWSTFT*

i assumed is as d oro fr the t lestablishe to ffe that the soluo :-'ý: 5 not freez&.-" This temperature containment also helps prevent boron precipitation and ensures thF5 water injection in vessel vacuum the reactor vess 11not be colder than the Ioweskemperature assumed 0 breaker sizing in reactor v el stress analysis, mThe[ F"upper limit on the ,>

temperature of the BWST contents is consistent with the maximum injection water temperature assumed in the LOCA analysis.

The numerical values of the parameters stated in the SR are actual values and do not include allowance for instrument errors.

The BVVST satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

BWOG STS B 3.5.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 92 of 98

Attachment 1, Volume 10, Rev. 0, Page 93 of 98 BWST B 3.5.4 BASES LCO The BWST exists to ensure thatan adequate supply of borated water is available to cool and depressurize the containment in the event of a DBA; to cool and cover the core in the event of a LOCA, thereby ensuring the reactor remains subcritical following a DBA; and to ensure an adequate level exists in the containment sump to support ECCS and containment spray pump operation in the recirculation ,ODý. To be considered OPERABLE, the BWST must meet the limits for water volume, boron 0

concentration, and temperature established in the SRs.

APPLICABILITY In MODES 1, 2, 3, and 4, the BWST OPERABILITY requirements are dictated by the ECCS and Containment Spray System OPERABILITY requirements. Since both the ECCS and Containment Spray System must be OPERABLE in MODES 1, 2, 3, and 4, the BVVST must be OPERABLE to support their operation.

Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops -

MODE 5, Loops Not Filled," respectively. MODE 6 core cooling requirements are addressed by LCO 3.9.4, "DHR and Coolant Circulation

- High Water Level," and LCO 3.9.5, "DHR and Coolant Circulation - Low Water Level."

ACTIONS A.1 With either the BWST boron concentration or borated water temperature not within limits, the condition must be corrected within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In thisCnme condition, neither the ECCS nor the Rearctor Bu(Win pray System can perform its design functions. Therefore, prompt action must be taken to 0

restore the tank to OPERABLE status or to place the plant in a MODE in which these systems are not required. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit to restore the temperature or boron concentration to within limits was developed considering the time required to change boron concentration or temperature and assuming that the contents of the tank are still available for injection.

B. 1 OPERABLE status With the BWST inoperable for reason ther than Condition A (e.g., water volume* Le must be restored to wit reluire within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, neither the ECCS nor the Containment Spray System can D Sperform its design functions. Therefore, prompt action must be taken to restore thereto OPERABLE status or to place the plant in a MODE in which the BWST is not required. The allowed Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the BWST to OPERABLE status is based on this condition simultaneously affecting multiple redundant trains.

BWOG STS B 3.5.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 93 of 98

Attachment 1, Volume 10, Rev. 0, Page 94 of 98 BWST B 3.5.4 BASES ACTIONS (continued)

C.1 and C.2 If the BVWST cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.5.4.1 REQUIREMENTS Verification every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the BWST water temperature is within the specified temperature band ensures that the boron will not precipitate; the fluid will not freeze; the fluid temperature entering the reactor vessel will not be colder than assumed in the reactor vessel stress analysis; and the fluid temperature entering the reactor vessel will not be hotter than assumed in the LOCA analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is sufficient to identify a temperature change that would approach either temperature limit and has been shown to be acceptable through operating experience.

The SR is modified by a Note that requires the Surveillance to be performed only when ambient air temperatures are outside the operating temperature limits of the BVVST. With ambient temperatures within this band, the BWST temperature should not exceed the limits.

SR 3.5.4.2 Verification every 7 days that the BWST contained volume is within the required range ensures that a sufficient initial supply is available for injection and to support continued ECCS pump operation on recirculation.

Since the BWST volume is normally stable and provided with a low level alarm, a 7 day Frequency has been shown to be appropriate through operating experience.

BWOG STS B 3.5.4-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 0, Page 94 of 98

Attachment 1, Volume 10, Rev. 0, Page 95 of 98 BWNST B 3.5.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3-5.4-3 Verification every 7 days that the boron concentration of the BWST fluid is within the required band ensures that the reactor will remain subcritical following a LOCA. Since the BWST volume is normally stable, a 7 day sampling Frequency is appropriate and has been shown to be acceptable through operating experience.

REFERENCES [ t-- 4FSAR, Section M.MI } I 1. NUREG-0800, Section 6.3.

00 BWOG STS B 3.5.4-6 Rev. 3.0, 03131104 Attachment 1, Volume 10, Rev. 0, Page 95 of 98

Attachment 1, Volume 10, Rev. 0, Page 96 of 98 JUSTIFICATION FOR DEVIATIONS ITS 3.5.4 BASES, BORATED WATER STORAGE TANK (BWST)

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. The brackets have been removed and the proper plant specific information/value has been provided.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. Changes made to be consistent with the Specification.

5. Typographical error corrected.

6. Editorial change for consistency.

7. Change made to be consistent with the LCO title.

8. This information is not necessary in this ITS Bases. This Specification concerns the BWST requirements, and this information describes minimum flow protection for the ECCS and containment spray pumps. Therefore, the information has been deleted.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 96 of 98

Attachment 1, Volume 10, Rev. 0, Page 97 of 98 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 97 of 98

Attachment 1, Volume 10, Rev. 0, Page 98 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 98 of 98

ML072200474

Text

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