Text

Improved Technical Specification Conversion License Amendment Request, Volume 10, Revision 1, ITS Section 3.5, Emergency Core Cooling Systems
	ML082270666
Person / Time
Site:	Davis Besse
Issue date:	08/07/2008
From:	; FirstEnergy Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
References
	L-08-240, TAC MD6398
	Download: ML082270666 (100)
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{{#Wiki_filter:DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST VOLUME 10 (Rev. 1)SECTION 3.5 -EMERGENCY CORE COOLING SYSTEMS (ECCS)"i 'N"'77 411, Attachment 1, Volume 10, Rev. 1, Page i of i Summary of Changes ITS Section 3.5 Change Description Affected Pages The changes described in the Davis-Besse Pages 5, 7, 8, 9, 12, 18, 25, and 26.response to Question 200710032123 have been made. The contained borated water volume and the nitrogen cover pressure have been changed to reflect the site specific calculations, including instrument uncertainty. The changes described in the Davis-Besse Page 18 response to Question 200802140950 have been made. The relationship between core flooding tanks volume and gallons at the analytical limits has been added.The changes described in the Davis-Besse Pages 30, 35, 38, 42, and 54 response to Question 200801311241 and continued in 200806230912 have been made.The changes described in the Davis-Besse Pages 30, 33, 34, 36, 41, 44, 45, 51, 57, 63, 64, 65, response to Question 200801021633 have been 6,70, 74, 82, 83, 84, 91, 92; 94, and 96 made. The allowance to de-energize 'certain 'Valves has been moved to the ITS 3.5.2 and 3,5.3 LCO Note versus the SR. Also the word available (in ITS 3.5.4) has been moved to the Bases.The changes described in the Davis-Besse Page 34 response to Question 200801151549 have been made. An editorial correction was made to Discussion of Change (DOC) M01.The changes described in the Davis-Besse Page 35 response to Question 200801151626 have been made. Additional clarification was added to DOC LAO 1.The changes described in the Davis-Besse Pages 72 and 73 response to Question 200802151005 have been made. An editorial change has been made to the LCO Bases section.The changes described in the Davis-Besse Page 83 response to Question 200802111514 have been made. Information pertaining to CTS 4.5.4.b has been added to the D00.The changes described in the Davis-Besse Page 94 response to Question 200802121126 have been made. A minor change has been made to the SR 3.5.4.1 Bases to be consistent with the ASA Section of the Bases.Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page i of Attachment 1, Volume 10, Rev. 1, Page 1 of 98 ATTACHMENT 1 VOLUME 10 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)Revision 1 S 0 Attachment 1, Volume 10, Rev. 1, Page 1 of 98 Attachment 1, Volume 10, Rev. 1 , Page 2 of 98 O LIST OF ATTACHMENTS

1. ITS 3.5.1 2. ITS 3.5.2 3. ITS 3.5.3 4. ITS 3.5.4 0 0 Attachment 1, Volume 10, Rev. 1, Page 2 of 98 Attachment 1, Volume 10, Rev. 1, Page 3 of 98 ATTACHMENT I ITS 3.5.1, CORE FLOODING TANKS (CFTs)Attachment 1, Volume 10, Rev. 1, Page 3 of 98 Attachment 1, Volume 10, Rev. 1, Page 4 of 98 W Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1,'Volume 10, Rev. 1, Page 4 of 98 Attachment 1, Volume 10, Rev. 1, Page 5 of 98 ITS 3.5.1 S ITTS0.314.5 EMERGENCY CORE COOLING SYSTEMS fECCS)CORE FLOODING TANKS LIMITING CONDITION FOR OPERATION OPERABLE with: 0 b SR3.5.1.1

a. The isolation valve:Topen, _ >12.6 feet and SR 3.5.1.2 b. A contained borated water volume between .755 d 8004 gallons of'borated water, SR 3.5.1.4 c. > 2600:and 53500 ppm of boron, and >_58o and <_620 SR 3.5.1.3 d. A nitrogen cover-pressure of between 5 and 6250 sig.APPLICABILITY:.

MODES 1, 2 and-31%ACTION: ACTION A a. [With one CFT Ainoperable because of boron concentration not.within -l]Imits, restore the inoperable CFT to OPERABLE status within 7Z'ursor be in HOT STANDBY within the ,next 6 hours and reduce the ACTION C pressure to. less than 800 psig the following

12 hours, ACTION B b.ý ith any CFT inoperable for reasons other-than-boron-concentatiOn not within limits, restore the CFT to OPERABLE Lstatus..withln one hour 'be in HOT STANDBY within the next 6 ACTION C ours an reduce RCS pressuret to less thane 800 psig within L~b. flloin 12 Add proposed ACTION D A0 SURVEILLANCE REQUI REMENTS 4.5.1, Each core flooding.tank shall be demonstrated OPERABLE: a. 'At leastý once-per 12 hours 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 1 3/4 5-I Amendment No., 91-, -207.Page 1 of 2 Attachment 1, Volume 10, Rev. 1, Page 5 of 98 Attachment 1, Volume 10, Rev. 1, Page 6 of 98 ITS 3.5.1.ITS EMERGENCY CORE COOLING SYSTEMSi SR 3.5.1.4 SR 3.5.1.5:SURVEILLANCE REQUIREMENTS (Continued)

b. At. least once per 31 days, and within 6 hours of each SolUtion.:volume increase of ý 80 gallons that is not the result of addittion from the borated water storage tank (BWST), by-verifying the boron concentration of the CFTsolution.

c. At least once per 31. days by verifying that'power to the i sol ation valve operator'jis d1 sconnectedl~by;Iozn1he raes lin t~e open*po~ition.:,...

d. At lejast on e per REFUELING.INTERVAL by 4erifyi g that each core.floodingqta

'k isolation valve opens automaticalfl y.and is-interlocked/against closing whenever the React r:Cooant System pressure e ceeds 800.psiqg. he...... Co.l.nt.S I0 DAVIS-BESSE, UNIT I 3/4 5-2 Amendment No. 4-r- 218 0 Page 2 of 2 Attachment 1, Volume 10, Rev. 1, Page 6 of 98 Attachment 1,Volume 10, Rev. 1, Page 7 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs)0 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 M01 CTS LCO 3.5.1.b requires each core flooding tank (CFT) contained water volume to be between 7555 gallons and 8004 gallons of borated water. CTS LCO 3.5.1.d requires each CFT nitrogen cover pressure to 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 the ITS SR 3.5.1.3. ITS SR 3.5.1.2 requires the borated water volume in CFT to be> 12.6 feet and < 13.3 feet and ITS SR 3.5.1.3 requires the nitrogen cover pressure in each CFT to be > 580 psig and < 620 psig. This changes the CTS by specifying a narrower range for the CFT borated water volume and nitrogen cover pressure.The OPERABILITY of each Reactor Coolant System (RCS) CFT ensures that 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 0 large RCS pipe ruptures. The CTS LCO limits on volume, boron concentration, Davis-Besse Page 1 of 3 Attachment 1, Volume 10, Rev. 1, Page 7 of 98 Attachment 1, Volume 10, Rev. 1, Page 8 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs)and nitrogen cover pressure ensures 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 combined water volume between 7555 and 8004 gallons of borated water. For ITS SR 3.5.1.2, this requirement is modified to require > 12.6 feet and < 13.3 feet 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 is modified to require a nitrogen cover pressure of > 580 psig and < 620 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 Specification 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. The new specified values allow for instrument inaccuracies in maintaining the analytical limits. In the case of CFT volume, the new value is also specified in feet (which is the readout of the available indication). The values specified for volume and pressure are based on the most accurate available indications (i.e., computer points).In summary, the proposed changes will result in ITS values that are more restrictive than the CTS values for CFT borated water volume and nitrogen cover pressure. These values allow for instrument inaccuracies in maintaining the analytical limits. The ITS values specified for volume and pressure will provide confidence that the analytical limits will not be violated. Therefore, there will be no adverse effect on nuclear safety. This change is designated as more restrictive since a narrower range for the CFT borated water volume and nitrogen cover pressure limits is specified in the ITS than is allowed in the CTS.RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 -Removing Procedural Details 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 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 0 safety. The ITS retains the requirement for verification that power is removed Davis-Besse Page 2 of 3 Attachment 1, Volume 10, Rev. 1, Page 8 of 98 Attachment 1, Volume 10, Rev. 1, Page 9 of 98 DISCUSSION OF CHANGES ITS 3.5.1, CORE FLOODING TANKS (CFTs)0 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 Not used.L02 (Category 5 -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 hours 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.0 Davis-Besse Page 3 of 3 Attachment 1, Volume 10, Rev. 1, Page 9 of 98 Attachment 1, Volume 10, Rev. 1, Page 10 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 10, Rev. 1, Page 10 of 98 Attachment 1, Volume 10, Rev. 1, Page 11 of 98 CFTs* 3.5.1 CTS 3.'5 EMERGENCYCORE COOLING SYSTEMS (ECCS)3.5.1.Core FoTanks (CFTs)0 LCO 3.5.1 LCO 3.5.1 APPLICABILITY: Two CFTs shall be OPERABLE.MODES 1 and 2,.MODE 3 with Reactor Coolant System (RCS) pressure >j psig.0 ACTIONS Action a CONDITION REQUIRED ACTION COMPLETION TIME A. One CFT inoperable due A.1. Restore boron 72 hours to boron concentration concentration to within notwithin

limits. limits.B. One CFT inoperable for B.1 Restore CFT to 1 hour reasons other than OPERABLE status.Condition A.Action b 0 Action a, C. Required Action and.Action b associated Completion Time of Condition A or B hot met.C.1 Be in MODE 3.6 hours AND C.2 Reduce RCS pressure to<( M]psig healours Im mediate~ly 0 DOC A03 D.Two CFTs inoperable.

D.1 Enter LCO 3.0.3.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY LCO3.5.1.a, ;SR 3.5.1.1 4.5.1 a.2 Verify each CFT isolationvalve is fully open.12 hours 0 BVWOG STS 3.5.1-1 Rev. 3.0',03/31104 Attachment 1, Volume 10, Rev. 1, Page 11 of 98 Attachment 1, Volume 10, Rev. 1, Page 12 of 98 O CTS CFTs 3.5.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY LCO 3.5.1.b, 4.5.1 .a.1 LCO 3.5.1 .d, 4.5.1 .a.1 LCO 3.5.1.c, 4.5.1.b SR 3.5"..2 Verify borated water volume in each CFT is_> 555,gUonS, []lftand[13.3 T-"L----[ 13.3 1 12 hours SR 3.5.1.3 Verify nitrogen cover pressure in each CFT is>_ psigand 5 < psig.12 hours 0 0 0 SR 35.1.41 Verify boron concentration in each CFT is> 2 7ppm~and,<_ M350d ppm.31 days AND-------- NO TE-------- Only required to be performed for affected OFT Once within 6 ho urs'after each solution volume increase of MB0gallons] that is; not the result of addition from the borated water storage .tank 0 0 4.5.1.c SR' 3.5,:15 Verify, power is removed from each OFT isolation valve operatorjwhen-"R-: S pressure is--... 000] psiql.31 days 0 BWOAGST:3.5.1-2 Rev. 3.0,03/311/04 Attachment 1, Volume 10, Rev. 1, Page 12 of 98 Attachment 1, Volume 10, Rev. 1, Page 13 of 98 0 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. 0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 13 of 98 Attachment 1, Volume 10, Rev. 1, Page 14 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 10, Rev. 1, Page 14 of 98 Attachment 1, Volume 10, Rev. 1, Page 15 of 98 CFTs B 3.5 EMERGENCY CORE COOLING SYSTEMSý (ECCS)B13.5.1 Core Tanks (CFTs), BASES: BACKGROUND The functionmof the ECCS CFT s s to supply :wa, .ter to the-reactor vessel during the blowdown phase of a los's ofcoolant accident (LOCA), to.provide inventory to help:accomplish the refill phase that follows thereafter, and, to provide Reactor Coolant System (RCS) makeup fora small break LOCA. Two CFTs~are provided for these.functions, The blowdown phase of a large break LOCA isthe 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 toa value approaching that of the containment atmosphere. In the refill phase of a OCA, which follows immediately, reactor coolant inventory has vacated'the core:through ,steam flashihg'.and ejection through the break. The core is essentially in adiabatic heatup. The ,balance of inventory is.then available tohelp 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 theaddition of safety. injection water, The CFTs are pressure vessels partially filled with borated water and pressurized with nitrogen gas. The CFTs are passive components, since no operator or conterol 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 Lutilized by the Low , Pressure Injection (LPI) System. Each CFT[].so1ated from the RCS by a ,motor operated~isolation valve and two check valves in series. cn The motor operated isolation valves are, normally open, with power*removed .from the valve motor to prevent inadvertent closure priortoe or during an:accident. BWOG STS B 3.5.1 -1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 15 of 98 Attachment 1, Volume 10, Rev. 1, Page 16 of 98 CFTs.B 3.5.1 BASES BACKGROU N D :(continued), The bCFTs thus form a passimvesystem for injection directly into the reactor,'vessel. Except for the coreflpood line break, LOCA, a unique accident that also disables a portioh of the injection system, both tanks are. assumedd to0 operate in the safety analyses for Design Basis Events. Because injection is :directlyinto the reactr vessel downcomer, and ,because it is. a passive system not subject to -the single active failure criterion, all fluid injection is credited forcore 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 LPIlSystem. APPLICABLE SAFETY ANALYSES The CFTs are taken credit for in.both the large and small break LOCA analYses at full power.(Ref., 1). These Design Basis Accident (DBA)analyses establish the a6ceptance 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 calculatilons, conservative assumptions are made, concerning the availability of emergency injection flow. The assumption of thelAoss 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 (HP!),,pumps cannot deliver flow until the emergency diesel generators (EDGs) start, come to rated speed, and go through their timed loading sequence.The lifniting larged break LOCA is a, double ended guillotine cold leg .break at the discharge-of the reactor coolant pump..Duringthis event, the CFTs discharge to the RCSas Soon as RCS pressure decreases below CFT pressure., JAs a .conse ative e~stimate,..no ,credit is. taken Jfe , H Pl-fr large .break COCAs. LPI is I ot assumnedtounti!'35.s conds after the RCS Dressure decrerses to the ESFAS I actuation pr~ess/ure. No operator~actionlis.'assumned during the blqwdown.stage er~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.0 0 BWOG STS B 3.5.1-2 Rev. 3.0, :03/31/04 Attachment 1, Volume 10, Rev. 1, Page 16 of 98 Attachment 1, Volume 10, Rev.. 1, Page 17 of 98 CFTs* B 3.5.1 BASES.APPLICABLE SAFETY ANALYSES' (continued). The small break LOCA analysis also assumes .a time de lay after ISFAS 0 actuation before pumped flow reaches the core. For the, larger range of small'breaks, the rate of'blowdowh is such ,thatthe 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 50.464(Ref.

2) will be m etfollowing a LOCA: a. Maximum fuel element.cladding temperature of 2200'F b. Maximum'cladding oxidation of -0.17 times, the tota cladding:0 thickness before oxidatio.c. Maximum hydrogen generation from azirconium water reaction of:_ 0.01 times the hypothetical amount that would be generated'if allof the metal in the cladding cylinders surrounding the fuel, excluding.

the cladding surrounding the plenum volume, were to.racand d. Core-maintained in acoolable: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 temnperatures.

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. CTs have been ass~ med to: operate to provide bor ted water for reactivF* control for overcooling events such 's a large steam line reak (SLB).BWOG STS B 3.5.1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 17 of 98 Attachment 1, Volume 10, Rev. 1, Page 18 of 98 C FTs 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 ensuresthat 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 startto deliver flow.rThe analytical limits forTu CFT volume are The maximum Volume limit is based upon the needa to maintairadequate 7480 gallons (12.412 ft) >26 gas volume to ensure proper injection, ensure the ability of the CFTs to and 8078 gallons 6 fully discharge, and limitthe maximum amount of boron inventory in the (13.588 ft). ful a i u m uto oo iv noyi h 1__t 113.588 _ Values of-[7555a1allons and [8005 16allons~rdaspebified. These" ' 0 allow for instrument inaccuracies in maintaining the analytical limits.These values allow for instrument inaccuracies in maintaining the analytical limits. The values specified for volume and pressure are based in the most accurate available indications (i.e., computer points). Additional allowances for instrument inaccuracies are included in the implementing procedures when less accurate indications are used.71=vaueallowfor i nstrlu ment. inaccurfacies..Values f- ,te aranete rs arel re tdsimilarlyT/ " *..580 The minimum nitrogen:cover pressure, requirementof M[5, ] psig ensures that the contained gas volumewill generate discharge flow rates during injection'that are, consistent with those assumed in the safety analysis.The maximum nitrogen cover pressure limit of[ Ii psig ensures that the amount of CFT inventory that is discharged while the RCS depressurizes, ,and istherefore lost through the break, will:not be larger than that predicted by the safety analysis.4The maximum allowable boron concentration of M35005 ppm in the:CFTs ensures that the sump pH will be maintained between 7.0 and 11.0 following a LOCA.0 0 0 2600 The minimum bdron requirement of [2 7] ppm is selected to ensure that the reactor will remain subcritical durjig the reflood stage of a large break 5%of the LOCA. During a large break LOCA,7_ control rod assemblies are 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 resultfin 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 C FTs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). (0 BWOG STS B 3.5.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 10,.Rev. 1, Page 18 of 98 Attachment 1, Volume 10, Rev. 1, Page 19 of 98 0 CFTs B 35.1 BASES LCO The LCQ establishes The minimum conditions ,required to ensure, that the CF.Ts are availableto 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 arenot injected.during the blowdown phase of a large break LOCA, the ECCS.acceptance criteria of 1.0 CFR 50.46 (Ref. 2),could be violated..For a CFT to 'be, considered OPERABLE, the isolation valve must be fully opdno-a=power removed labo, [2 , 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 MODE3 With RCS pressure, > the 800 CFT OPERABILITY requirements are based on full power operation; Although cooling requirements

may decrease as power decreases, the*CFTs ale still required to provide core cooling as long as elevated RCS, pressures and temperatures exist. At *FR This LCO is only applicable at pressuresJ

'7 0sig. B 7[B psig, the rate of RCS blowdown is such that the safety injection pumps can provide adequate:injectiornto ensurethat peak clad temperature remains below%the 10 CFR 50.46 (Ref. 2)1limit of 2200°F.In MODE 3with RCS pressure ig, and in MODES 4, 5, and 6,.the CFT motor operated isolation valves areclosed to isolate the CFTs from.the RCS. This allows RCS cooldown and depressurization without discharging tIheCFTs into the:RCS or requiring depressurizatio.n of the CFTs.0 0 0 ACTIONS A.1 If the boron concentration of one CF.T is not within limits, it must be returned to within the limits within 72 hours. In this condition, ability, to'maintain subcriticality may be reduced, but the effects of reduced 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 stillavailable for injection. Since the boron requirements are based on theaverage 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 hours is allowed to return, the boron concentration to within limits.0 BWOG STS B 3.5.1-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 19 of 98 Attachment 1, Volume 10, Rev. 1, Page 20 of 98 CFTs B 3.5.1 BASES ACTIONS (continued) B.i If one CFT 'is inoperable for a reason other than boron concentration, the.CFT must be returned to OPERABLE status within 1 hour,. In tthis condition it cannot be assumed that the CFT will perform its required function during a LOCA. Due to'the severityof the consequences-should a LOCA.occur inthese conditionsi the 1, hour 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 returnthe inoperable CFTto'OPERABLE status. The Completion Time minimizes the time the plant is potentially exposed to a LOCA in these conditions. C01 and C.2 If the COFT 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,hours and' RCS pressure reduced to:- W (i withinhours. The allowed Completion Times are reasonable,'based on operating experience, to reach the required plant conditions from full power conditions in an orderly mann'er and without challenging plant systems.D:A If more than one CFT is inoperable,-the unit is in a condition. outside the accident analysis; therefore, LOGo 3.0.3 must be entered immediately. SURVEILLANCE SR 3.5.1A1 REQUIREMENTS Verification every 12 hours, 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 hour Frequency is considered reasonable in view of administrative controls, that ensure that a mispositioned isolation valve is unlikely.. 0 BWOG STS B 3.5.1-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 20 of 98 Attachment 1, Volume 10, Rev. 1, Page 21 of 98 0 CFTs B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.5.1.2'and SR, 3.5.1.3 Verification every 12 hours ofeichCFT's nitrogen cover pressure and the.borated water volume ýis sufficient to ensure adequate injection during a LOCA. Due to the static design of the CFTs, a 12 hour Frequency Usually allows the operator to identifychanges 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, Surveillanceonce every31 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 inhwhich the concentration can be changed.The Frequency is adequate to identify changes thaticould occur from mechanisms such as stratification or inleakage. Samplingwithin 6, hours 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 inventoryis 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-1I366,(Ref. 3).SR 3.5.1.5 Verification every 31 days that power is removed from each CFT isolation in the open position)be valveoperatowhen he pressure 00]. psg gensures that an active failure could not result in the.undetected closure: of a CFT motor operated isolation valve coincident with a LOCA,- If this closure wereto ,occur and.the postulated LOCA is a rupture of the redundant CFT inlet piping, CFT capability would.be rendered inoperable. The rupture would renderthe tank with the open valve inoperable, and a closed valve on the other CFT would likewise render it inoperable. Thiswould 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.0 BWDG STS B 3.5.1-7 Rev. 3.0,; 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 21 of 98 Attachment 1, Volume 10, Rev. 1, Page 22 of 98 CFTs B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) This SR is modifie4i by a Note that allows power to be sopplied to the motor operated isb lation valves when RCS pressure is, [2000] psig, thus ,allowing 0peratiojbal.flexibility by avoiding unnecessa delays to manipulate the. plant:startups or shut owns..0 REFERENCES 1.FSAR, Section M64- (D 0'2. 10CFR 50.46.3. [D fNUREG-1366,DFebrue99 .ber g92 0 0 0 BWOG STS: B 3.5.1-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 22 of 98 Attachment 1, Volume 10, Rev. 1, 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. 3.1.0 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 23 of 98 Attachment 1, Volume 10, Rev. 1, Page 24 of 98* Specific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 10, Rev. 1, Page 24 of 98 Attachment 1, Volume 10, Rev. 1, Page 25 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.1, CORE FLOODING TANKS (CFTs)10 CFR 50.92 EVALUATION FOR MORE RESTRICTIVE CHANGE M01 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) more restrictive. Below is the description of this more 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 to be between 7555 and 8004 gallons of borated water. For ITS SR 3.5.1.2, this requirement is modified to require > 12.6 and < 13.3 feet 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 is modified to require a cover-pressure of > 580 and __ 620 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. The new specified values allow for instrument inaccuracies in maintaining the analytical limits. In the case of CFT, the new values is also specified in feet (which is the readout of the available indication). The values specified for volume and pressure are based on the most accurate available indications (i.e., computer points).In summary, the proposed changes will result in ITS values that are more restrictive than the CTS values for CFT borated water volume and nitrogen cover pressure. These values allow for instrument inaccuracies in maintaining the analytical limits. The ITS values specified for volume and pressure will provide confidence that the analytical limits will not be violated. 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: 0 Davis-Besse Page 1 of 2 Attachment 1, Volume 10, Rev. 1, Page 25 of 98 Attachment 1, Volume 10, Rev. 1, 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. 1, Page26 of 98 Attachment 1, Volume 10, Rev. 1, Page 27 of 98 VATTACHMENT 2 ITS 3.5.2, ECCS -OPERATING 0 0 Attachment 1, Volume 10, Rev. 1, Page 27 of 98 Attachment 1, Volume 10, Rev. 1, Page 28 of 98 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 Attachment 1, Volume 10, Rev. 1, Page 28 of 98 0 ITS Attachment 1, Volume 10, Rev. 1, Page 29 of 98 JfIMRGBNCY CORE COOLING MSM EM SUBSYSTIMS -280P ITS 3.5.2 LIM1TrNG CONDITION FOR OPERATION 3.5.2'35.2 Two ~~ECCS subsystems shall'be OPERABLE theach su system comprised of: a. One OPERABLE high injection (HPI) pumnp, d. An OPERABLERfi path capable of taking suction from the boras water storage tank (BWST)on a saietyi signal and manually transfenring suction to containment sump during the A reci lation M ofDES and 3 MODES 1, 2 wAd 3 S0 AflON: ACTION B .-L ith one HPI train inoperable, restore the inoperable HPI train to OPERABLE status within 72 L b e"m- i HOT SHUTDOWNwithinthenett 12 hours f....ACTION C H H 1 o Add proposed Required Action 0.1 ACTION A b. .With on LPI a orits assocated decay heat coole inoperableirestore the inoperable -pm~t to OPERABLE status within 7 days *-be in HOT SHUTDOWN within'the nostd2 ACTION C hom\L MOl 90 days desMibl tbig cftuStance of the actuation and the total

ted actuation cycles S VE311A CE REQ REK Add proposed ' ACTION D A02 4-S2 Each ECCS wbsysem shall be demonstrated OPERABLE: SR 3.5.2.1 a. At least once per31 days by verfying that'chb valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position., An wx.pon a the HP~pmpsforthe purpoe ofcondudingRes )I Tat plan inspection adttvi~d r. This e on Is valid during the ongoing Thirteenth Refuiein Outagefor entries into MODE3 from MODK 4. Under this exception.

neither HPItraln is requredto be capable of taking suctionfrom the LPfraiins when alignedfor containment sump recircul~tom The HP! trains will otherwise be OPER4iLs. Operation in MODE ) orYMODE 2 while ieytng upon theprovisions of this exception isp tited A03s DAVIS-BESSE, UNIT I 3/4 5-3 Amendment No. 36,182, 253, 257 Page 1 of 4 Attachment 1, Volume 10, Rev. 1, Page 29 of 98 Attachment 1, Volume 10, Rev. 1, Page 30 of 98 ITS 3.5.2 ITS Revised by RC Letter Dated June 6o logo M1RVE1rj#,R1jr.r neAllineur"" a -.1 SR 3.5.2.3 bi At least once each iEFUELING INTERVAL, or prior to operation after ECCS piping has been drained by verifying that the ECCS piping is full of water by venting the ECCS punp casings: and dischare piping, high points.C. By a visual in pection which verifies that noloose ,debris (rags, trash, clothin, etc.) is present in the con vilnent which be transported to the contanme-nt emergency s and cause rstrict on o the pump suction during LOCA onditions. This visual inspec ion shal be performed:

. For all accessible areas of the contal ment prior to establi hing CONTAINMEN INTEGRIT, 2. For aI 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 (contii nt closeoat)

When COWTAI IKNEGRITY is ..d. At least once each REFUELING I-MTRVAL by: See ITS 3.4 .14 1. Verifying that the interlocks: a) Cl ose Mf-11 and D4-1.2-land deen6rdize .the prissurizeo .heatrs f OU-11 or 011-12 is open am a simulat-ed reactor Coolant syte-pressure..whic is greater, tha A llowable Value :(428, Oslo) is ... .ap lied. I interloc to close W-1s or -12 Is no .required If the valve ts 480 V 'power is disconnected from Its.'oto, operators. b) Prevent the opening of ON-11 and DH-Ig iMeaa simulated.or actul reactor coolant systea ( re which is Mrater than the Allomable -Value ((28 psig)Is a~pp tei , ... ....".I SR 3.5.2.7 SR 3.5.2.8 LCO 3.5.2 Note SR 3.5.2.8 2. a) A Visual inspection of the containment"emrgeMW, sump which. verifies-that the subsystem stctiolnblets are.not restricted by debris and that the t Coo ts ((trash hracks, s~reens, etc.) show no evidenceof structtl dtstress or corrosion. .3. Deleted DAVIS-BESSE, UWIT 1 3/4 &-4 Amendment no. ,!-t 01Af 0 Page 2 of 4 Attachment 1, Volume 10, Rev. 1, Page 30 of 98 Attachment 1, Volume 10, Rev. 1, Page 31 of 98 ITS 3.5.2 ITS EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continuecfl 4.Verifying that a minimum of 290 cubic feet of trisodium. See ITS phosphate dodecahydrate (TSP) is contained within the TSP 3.6.7 storage baskets.5. Deleted SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 6. Deleted that is not locked, sealed, or L03 e. At leastonce each REFUELING INTERVAL, by otherwise secured in Dosition 1. Verifying that each automatic valve in the flow path ttuates to its correct p sto ongsafeq rrýct ion 2. Verifying that'each UPI and LPi pump starts automatically upon L0\receipt of a S Stest signal.f, Deleted g. By verifying the correct position of each mechanical position stop for valves DH- 14A and DH-I4B.1-Within 4 hors following completion of the op~ning of the valves to their meranical position stop or following fompletion of L05 maintcnanqe on the valve when the LPI systerjt is required to be OPERAB E. E I[ l I F 2. At least once each REFUELING INTERVAL DAVIS-BESSE, UNIT I 3/45-5 Amendment No. 263 Page 3 of 4 Attachment 1, Volume 10, Rev. 1, Page 31 of 98 Attachment 1, Volume 10, Rev. 1, Page 32 of 98 ITS 3.5.2 ITS EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) SIR 3.5.2.2 h. By verifying each ECCS pump's developed head at the test flow point is greater than I or equa Ito the required developed head, when tested pursuant to the requirements of I Specification 4.0.5. 1 0 DAVIS-BESSE, UNIT 1 3/4 5-5a Amendment No. 256 0 Page 4 of 4 Attachment 1, Volume 10, Rev. 1, Page 32 of 98 Attachment 1, Volume 10, Rev. 1, 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 changesand 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 hours. CTS Action b states that when one Low Pressure Injection (LPI) train or it associated.decay heat removal cooler isinoperable, 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.A04 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 0 outlet isolation valves and the containment emergency sump recirculation valves Davis-Besse Page 1 of 7 Attachment 1, Volume 10, Rev. 1, Page 33 of 98 Attachment 1, Volume 10, Rev. 1, Page 34 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING 0 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 requires the same Surveillance, however the exception statement "with the motor operators for the BWST outlet isolation valves and the containment emergency sump recirculation valves energized" has been moved to the LCO as a Note. The LCO Note states "The borated water storage tank (BWST) outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable." This changes the CTS by moving the location of the exception from the specific Surveillance to the LCO statement. The purpose of the exception is to allow the valve motors to be de-energized in MODES 1, 2, 3, and 4 to meet 10 CFR 50 Appendix R requirements. This is documented in the NRC Safety Evaluation for Amendment 182, dated 12/21/1993. While the valves are de-energized for this reason only, they are still considered OPERABLE (i.e., the LCO is still being met). Thus, the change is acceptable since it is not changing the current requirement; it is only moving the exception to the LCO statement to be consistent with the format of the ISTS.This change is considered administrative because it does not result in any technical changes to the CTS.O 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 hours. In addition to maintaining the requirement for the unit to be in MODE 4 within 12 hours (ITS 3.5.2 Required Action C.2) if the inoperable ECCS train is not restored to OPERABLE status within the allowed Completion Time, ITS 3.5.2 Required Action C.1 also requires the unit to be in MODE 3 within 6 hours. This changes the CTS by requiring entry into MODE 3 within 6 hours when a shutdown is required.This change is acceptable because the requirement to place the unit in MODE 3 in 6 hours 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 Davis-Besse Page 2 of 7 Attachment 1, Volume 10, Rev. 1, Page 34 of 98 Attachment 1, Volume 10, Rev. 1, Page 35 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING* REMOVED DETAIL CHANGES LA01 (Type 1 -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. The ITS still retains the requirement that two ECCS trains shall be OPERABLE. 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 Not used.LA03 (Type 4 -Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAPM, IST 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. 0 Davis-Besse Page 3 of 7 Attachment 1, Volume 10, Rev. 1, Page 35 of 98 Attachment 1, Volume 10, Rev. 1, Page 36 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING LA04 (Type 3 -Removing Procedural Details 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.a only requires verification that each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation signal. This changes the CTS by moving the details of how to perform the verification to the Bases.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. 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 Not used.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 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. 0 Davis-Besse Page 4 of 7 Attachment 1, Volume 10, Rev. 1, Page 36 of 98 Attachment 1, Volume 10, Rev. 1, Page 37 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING 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 (DH1 1 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 O 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 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.0 Davis-Besse Page 5 of 7 Attachment 1, Volume 10, Rev. 1, Page 37 of 98 Attachment 1, Volume 10, Rev. 1, Page 38 of 98 DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING L02 Not used.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. 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 (Category 5 -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. 0 Davis-Besse Page 6 of 7 Attachment 1, Volume 10, Rev. 1, Page 38 of 98 Attachment 1, Volume 10, Rev. 1, Page 39 of 98.DISCUSSION OF CHANGES ITS 3.5.2, ECCS -OPERATING 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 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.0 0 Davis-Besse Page 7 of 7 Attachment 1, Volume 10, Rev. I, Page 39 of 98 Attachment 1, Volume 10, Rev. 1, Page 40 of 98 W Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 10, Rev. 1, Page 40 of 98 Attachment 1, Volume 10, Rev. 1, Page 41 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 4.5.2.d.2.b) Two ECCS trains shall be OPERABLE.------7--------- ---NOTE,-.---- --.............. ['Operation in MODE with high pressure injection ,(H i) de-activated in accordance with LC? 3.4'.12, "Low Temperature Over ressure: Protection (LTOP.) System," is llowed for up to [4] -hours.)0 (The borated water storage tank (BWST) outlet and containment emergency sump valves may be considered OPERABLE when the lassociated valve motors are de-energized, provided the valves are not]otherwise inoperable 0 APPLICABILITY: MODES !, 2, and 3.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure A.1 Restore LPI subsystem to M7]days injection (LPI) OPERABLE status.subsystem inoperable. Action b 0 0 Action a B. One or morettrains inoperable for reasons other than ConditionA. Action a, C. Required Action and Action b associated Completion Time ot met.(of Condition A or B DOCA02 D. Less than 100% of the ECCS flowequiva lent to a single OPERABLE train available. B.1 Restore train(s) to OPERABLE.status. 72 hours C..1 Be. in MODE 3 AND C.2 Be in MODE 4.16 hours 0)12 hours D. Enter LCO 3.'0.3.Immediately 0 BWVOG STS 3:5.2-1 Rev. 3.0,03/31/04 Attachment 1, Volume 10, Rev. 1, Page 41 of 98 Attachment 1, Volume 10, Rev. 1, Page 42 of 98 ECCS -Operating 3.5.2 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Veri .the-following valves are in the listed position 12 hours]with ower to the valve operator removed.Valv Number Position Function[ '] [I [I1] 1 ]0 4.5.2.a :SR 3.5.2:M 4.5.2.b SR 3.5.2.3 Verify each ECCS manual, power operated, and automatic valve. inthe flow path,,that is. not locked, sealed, or otherwise secured in position, is in the correct position.31 days 0 by venting the ECCS pump casings and discharge piping high points I 24 months AND Prior to declaring 31 yVS] IEGS OPERABLE after draining K>EccS piping In ac rdance.MVerify ECCS piping is full of Water*--4.5.2.h SIR 3.5.2.1~Verify each .ECCS pump's developed head atthe test flow point is greater than or equal to the required developed head.with the Inservice Testing Program 4.5.2.e.1 4.5.2.e.2 SR 3.5.2 Verify each ECCS automatic valve in the flow path 8]- months that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an2 actual or simulated actuation signal.SR Verify each ECCS. pump starts automatically on'an months actual or simulated actuation signal.SR 3.5.2.7 [1 Veri the correct settings:of stops for the following [18] months]HPI top check valves: a. MUV-2], b. MUV-6], and c. [MU.V-10]. 00 00 0 BWOG STS 3.5.2-2 Rev. 3.0, i03/31/04 Attachment 1, Volume 10, Rev. 1, Page 42 of 98 Attachment 1, Volume 10, Rev. 1, Page 43 of 98 CTS ECCS -Operating 3.5.2 I correct position of each mechanical stop for the following valves SURVEILLANCE REQUIREMENTS (continued) 4.5.2.g SURVEILLANCE FREQUENCY SR 3.5.24 Verify the Fflo controllers for)t le. following LPIh [s]L- Ithrottle valve/operate propery 24 a. [DH -I0]jand b. ~H-1 00 4.5.2.d.2.a) SR 3.5,2 Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by, debris and suction inlet trash racks and screens show no evidehce of structural distress or abnormal corrosion. T[1 ] months.724 00D INSERT 1 4-1 i 0 BWOG STS 3.5.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 43 of 98 Attachment 1, Volume 10, Rev. 1, Page 44 of 98 3.5.2 CTS O INSERT 1 4.5.2.d.2.b) SR 3.5.2.8 Verify the following: 24 months a) Each BWST outlet valve and containment emergency sump valve actuate to the correct position on a manual actuation of the containment emergency sump valve; and b) The actuation time of each BWST outlet valve and containment emergency sump valve is< 75 seconds.I Insert Page 3.5.2-3 Attachment 1, Volume 10, Rev. 1, Page 44 of 98 Attachment 1, Volume 10, Rev. 1, Page 45 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 and the valves actuate within the proper times, 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. Furthermore, the CTS allows the valves to be de-energized while in MODES 1, 2, 3, and 4 to meet the requirements of 10 CFR 50, Appendix R. This is documented in the NRC Safety Evaluation for Amendment 182, dated 12/21/1993.

While in the de-energized state, the valves are still considered OPERABLE. To be consistent with the format of the ITS, this Surveillance allowance has been placed into the LCO statement as a Note. The Note states "The borated water storage tank (BWST) outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable." The Note allowance and its format is consistent with a Note in NUREGs-1433 and -1434 for ITS 3.5.1, ECCS -Operating (the Note was needed since a different Technical Specification required ECCS valves to be in the non-accident position and incapable of automatically being positioned).

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.

0 Davis-Besse Page 1 of I Attachment 1, Volume 10, Rev. 1, Page 45 of 98 Attachment 1, Volume 10, Rev. 1, Page 46 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 10, Rev. 1, Page 46 of 98 Attachment 1, Volume 10, Rev. 1, Page 47 of 98 ECCS -Operating B 3.5.2" B 3.5 EMERGENCY CORE ýCOOLING, SYSTEMS (ECCS)B 3.5.2 ECCS -Operating BASES BACK-GR'OUND: The function of the ECCS is, to providle.core cooling to ensure that the reactor core is protected after any of the following accidents: a., Lossof ýcoolant-accident (LOCA)b.. Rod ejection accident (REA):c. Steam generator tube rupture (SGTR) :and d. "A 4 $tbam line break (!LB).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 phaseis 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 .injectin,.(H PI) 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 BWS'T 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. I Control Valves are set t0.b lance the HPI flowto-the RCS; This flow.alancedirects sufficient fI to the *core to meet the (lanaly~is ssimptions following a small bir ak LOCA in 0ne~of the RCS/cold legs neyr.,an HPI nozzle. F fapoxmtl* .! 1600 psig The HPi pumps are capable of discharging to the RCS at an RCS, I.pressure labove the §bfening setpoint qFthe pressurize safety valves{.The LPI pumps are capable of discharging to the RCS at.an RCS[IIpressure ofapproximately '200' .When the BWST has been nearly emptied, the.suction for the LPI pumps is manually transferred to the BWOG STS B 3.5.2-1 Rev. 3.1, 12/01/05.Attachment 1, Volume 10, Rev. 1, Page 47 of 98 Attachment 1, Volume 10, Rev. 1, Page 48 of 98 ECCS:- Operating B 3.5.2 BASES BACKGROURND (continued), containment sump,. The HPI pumps cannot take suction directly from the sumnp. IfHP is still ne~eded, a cross connect from the discharge sidebof'the LPI pumptothe suction of the: HPI pumps would be opened. This is known as "piggy backing" HPI ito, LPI and enables continued HPI to the RCS, if needed,;after the BMST isemptied. In the long term cooling period, flow paths in the LPI. System are, established to preclude'the possibility, of boric acid in the core region-reaching An'unaccepfably high..concentration,. One flow path is. frpm the INSERT 1 hot leg thro.ug the decay heat sucti h line from the hot leg abn 4then in a\lreverse direýý ion, through-the conta)hment sump outlet line int/ the,sump.The other flow path is through the:pressurizer auxiiary' spray line from HPI pump 2 in piggybak___ne LPI tra into the pressurizer nd through the. hot leg1 o.t etOp 0 with LPI pump 2. Iregion of te core. I The H P1subsystem also functions to supply borated water to the reactor core following increased. heat removal events, such as large§L.During low ternperat re conditions in the ROS, limitatios are placed on the maximum numb r of ECCS pumps that may be, 0I ERABLE. Refer to the Bases for LCO .4.412','!Low Temperature Overpr ssure.Protection (LTOP) System," fof the basis of these requirements.,During a large break-LOCA=, RCS pressure will decrease to <:200 psia in<. 20 seconds. The ECCS is, actuated upon receipt of an Engineered Safety Safety. Feature#Actuation System.ASFAS) signal.. The actuation of Features (ESF) -----sa e ar loads is accomplished in a programmed time sequence. If_E_. oltsite power is available., th ýsafegard loads start immediately Kifi programm quence .If offsite power is not available, the essential afet F e .buses shed normal operatihg loads and are emergency I connected to .the~diesel genetators. ISafe.gardlioads are thenactuated 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 C(IFTs), and'the BwST covered in LCO 3.5.1, "Core Flood T,.anks (CFTs)," and LCO 3.5.4, "Borated Water Storage Tank (BWST)," provide te n:cooling water necessary to meet, 1.0 CFR. 50.46 (Ref.. 1).BvvWG sTs ýB 3.5.2-2 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 1, Page 48 of 98 Attachment 1, Volume 10, Rev. 1, Page 49 of 98 B 3.5.2 O INSERT I 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.0 0-Insert Page B 3.5.2-2 Attachment 1, Volume 10, Rev. 1, Page 49 of 98 Attachment 1, Volume 10, Rev. 1, Page 50 of 98 ECCS -Operating B 3.5.2 BASES.APPLICABLE. The LOO helps to ensure thaf the following acceptancecriteria for the SAFETY ECCS, established by 10 CFR 50.46 (Ref. 1)j will be met followinga. ANALYSES LOCA: a. Maximu~mfuel elementcladding temperature is --;2200'F b. Maximumc:claddiing oxidation is __0.17 times the total cladding thickness before oxidatio c. Maximumn hydrogen generatioh-friom a zirconium water reaction is_ 0.01 times the hypothetical amnount generated if all.of the metal in, the cladding cylinders surrounding the fuel,, excluding the cladding surrounding 'the; plenum volume, were to reac d.- Coreis maintained in a coolableWgeometry Tand e., Adequate long termrncore cooling capability-is maintained. The LCO also helps.ensure that:containment itemperature limits are met.Both HPI and LPI subsystems are assumedto be OPERABLE in the large break LOCA analysis at.,ful 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 actuatiqn. The H.P1 pump is credited in'the small break LOCA analysis. This analysis establishesthe flow and discharge head requirements at the design point for the HPI pump. The SG.TR and* LBanalyses, also cre~dit the HPI pump but are not-limiting in their design. M (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 asz 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 reactorvessel core flood nozzles, thenflows into the downcomer, fills the.ower plenum, and refloods the core.The LCO ensures-that an ECCS train will deliver sufficient water to match bo decay heatboHf rates soon enough to minimizeýcore uncoveryfor a large break LOCA. It also ensures that the HPIpump will deliver sufficient water for a. small breakLOCA and provide sufficient boronto maintain the core subcritical. O BVOG STS B 3.5;2-3 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 1, Page 50 of 98 Attachment 1, Volume 10, Rev. 1, Page 51 of 98 ECCS -Operating B 3.5.2-BASES.APPLICABLE SAFETY ANALYSES (continued) In the LOCA analyses, H PI and LPI are not credited until Fseconds after i a actuation 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:/lrge break L CA, (IHPlAsnot credited at 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 traihs are required to ensure~that at least one isavailable, assuming a single. failure in the other train. Additionally, individual components; within. the ECCS: trains may be-called Upon to mitigatelthe consequences of other transients and accidents. In MODES 1 2, and 3, an ECCS train'consists of an HPI subsystem and an LPIsubsystem. Each train includes the piping instruments, and the decay controls to ensure an OPERABLE flow path capableiof taking suction0 heat removal from the BWST upon an [SFAS signal and manually transferring suction teLI tpo:th~e containment s~ump,. .. ....During an event requiring ECCS actuation, a flow path is provided to ensure ian abundant~supply, of waterfrom the BWST to the RCS via the, HPI and LPI pumps-and their respective discharge flow paths to each. of the four coldleg injection nozzles and the-reactor vessel. In the long term, this flowpath may be manually transferred to take its:supplyjfrom.the containment sump and to supply its flow to. the RCS via to paths, as described in the. Background Section.The flow path.for each train mustmaintain 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 tswith an LTOP System arming temp rature~at or near the MODE 3. !oundary temperature of [350 F. LCO 3.4.12 requires that c aincomponents be de-activated at and elow the LTOP System armin temperature., \hen this temperature is t or near the MODE 3 bounda temperature, time. is needed toxrestore e systems to OPERABLE stat s.'As Noted, the BWST outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable. This allowance is necessary since the motor operators are normally de-energized in MODES 1, 2, 3, and 4 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 (i.e., to meet the 10 CFR 50 Appendix R requirements). This allowance was originally approved by the NRC in References 6 and 7.BWOG STS B 3.5.2-4 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 1, Page 51 of 98 Attachment 1, Volume 10, Rev. 1, Page 52 of 98 ECCS -Operating O ~B 3.5.21 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 redluced power would not require the sa.me level ,of performance, the accident analysis does not provide for reduced cooling, requirements in the lower MODES. The.H PI pump performance i.s based on thefsmall break LOCA,which est.ablishes1the pump performance curve and is less dependent on power. TheHPI pumpJ performance uirements are based on a smal reak LOCA- 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 areaddressed by LCO 3.9.4 "Decay Heat R) and Coolant Circulation -High, Water Level," and LCO03.9.5, "Decayw Heat Removal (DH R) and Coolant Circulation -. Low Water:Level." ACTIONS A.1 With one LPI subsystem inoperable, action must be taken to restore .i to OPERABLE status within 7 days. In this conditionthe 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 subsystemrcould result in loss of ECCS function. The.7M3day-Completion Time is reasonable to perform corrective maintenance onthe inoperable. LPI subsystem. The[j7:day Cpmpletion Time is based on the findings of the deterministic and probabilistic analysis in Reference

3. Reference 3 concluded that extending the Completion Time to 7Fdays for an inoperable LPI subsystemprovies plant operatibnal flexibility While simultaneously reducing overall plant risk. This is because the risks incurred by having the LPI. subsystem unavailablefor a longer time at-power will be substantially offset by the benefits associated with avoiding.unnecessary plant transitions and by reducing risk during p!antshutdown operations.

B.1 inoperable ]ýWith one or more trains e eand at least 1.00% 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 hours. The 72 hour Completion Time is based on NRC recommendations (Ref. 4)that.are based on 6 risk evaluation and is a reasonable.time formany repairs.0 BWOG STS B 3.5.2-5 Rev. 3., 12/01/05 Attachment 1, Volume 10, Rev. 1, Page 52 of 98 Attachment 1, Volume 10, Rev. 1, Page 53 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 OPERABI!LITY of a number .of independent-subsystems.. Due to theredundancy.of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECGS incapable of performing its function. Neither doesuthe inoperability of two different components, each-in a different-train, necessarily result in a loss of function for the ECCS. This. allows.increased flexibilitylin plant operationsunder circumstances When components in opposite: trains are inoperable. An event accompanied byra loss of offSite powerand 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 ECGS train inoperable to be. sufficiently lowto~justify continued operationfor 72 hours.With one, or more component inoperable such thati00% of the flow equivalent to a single OPERABL ECCS train is not available, the facility is in a condition outside theaccidenanalyses. Therefore, LCO 3.0.3 must be immediatelyentered. 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.hours and at least MODE 4 Within 12 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_11 Condition jis 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. VWith less than 100.% of the ECCS flow equivalent to a single OPERABLE ECCS trainavailable, the facility is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must beentered immediately. BWOG STS B 3.5.2-6 Rev. 3.1, 12/01/05,.Attachment 1, Volume 10, Rev. 1, Page 53 of 98 Attachment 1, Volume 10, Rev. 1, Page 54 of 98 ECCS -Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS SR 3.5.2.1 Verificationof proper *alve position ensures that the f ow.path from the ECCS pumps to the is maintained. Misalignme t of these valvesýcould render both E CS trains. inoperable. Securing these valves in position by removal f power or by key locking the c ntrol inthe correct position ensuresth the valves cannot change posil ion as the result of an active failure. T ese 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 hour Frequency is. cons dered reasonable in view of other admi istrative controls that will ensur the .unlikelihood of a mispositioned valv 0 SR Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths:provides assurance that the properflow 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 thosevalves capable of being mispositioned are in-the correct position. The.,31 day Frequency is appropriate.because the valves are.operated under administrative control, and aninoperable valve poSition would only affect a single train. This Frequency has been shown to .be acceptable through operating experience. 0 el I Mov fron B 3.ge SR 3.5.2.2 .,by venting the 2Page to-here ECCS pump SR 3o5h2re casings and.-tR 3.52.3 discharge piping high _With the exception 6fsystemns in operation, the ECCS pumps are points, normally in a standby,, nonoperating mode. As such, the flow path piping This SR re the potential to develop voids and pockets of entrained gases.e aintaining the piping from the ECCS pumps to the RCS full..of water ensure@ that the system will perform properly, injecting its full capacity intothe 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 ani&SFAS signal or during 2mh shutdown cooling. The ýrequency.takes into considerationthe ,gradual nature of gas. accumulation in the ECcS piping a the existence. of procedural controls governing system operat ion. L Ci , and the fact that some venting points are not accessible during normal operation. The second Frequency is required to ensure the ECCS subsystem is refilled after draining prior to declaring the ECCS subsystem OPERABLE.0 0 BVWOG STS B 3.5.2-7 Rev. 3.1, 12/01/05ýAttachment 1, Volume 10, Rev. 1, Page 54 of 98 Attachment 1, Volume 10, Rev. 1, Page 55 of 98 ECCS -Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) Move to Page B 3.5.2-7 before SR 3.5.2.3 ,SR 3.5ý2.r Periodic surveillance testing of ECCS pumps: to:,detect grossdegradation. caused by impeller structural damage or-other hydraulic component problems is required by the ASM E Code (Ref. W. This type ofltestihg may. be accomplished by measuring the pump's developed head at only*one point of the pump's characteristic curve. This, verifies both that the.measured

performance is within an acceptable tolerance .ofthe original pump baseline performance and that the performance at the test flowis 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.rand SR 3.5.2.f/These :SRs:demonstrate&that each automatic ECCS'valve actuatesto the required position on an actual or simulated MSFAS signal and that each!ECCS pump starts on receipt of'an actual or'simulated IESFAS signal.This SR is not required for valves that are locked, sealed, or otherwise ,secured in position under administrative controls.. The Frequency is based on themneed toperform this Surveillanceunder:the conditions that apply during a plant outage and the potential for'an unplanned transient if the Surveillance were, perfbrmed with the reactor at ,power. The. Frequency is also acceptable basedon consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is te'stedas part of the IESFAS testing, and equipment performance is monitored as part of the Inservice Testing Program.0 0 0 0 0b 0b 0 0 S R 3.5.2.7 This. Surveillance e ures.thatthese valves are in th proper positionto prevent the HPI purp from.exceeding its runout lim t; This 18 month Frequency is base on the same reasons as those stated for-SR 3.:5.2.5, and SR 3.5.2.6.0 BWOG STS B 3.5.2-8 Rev. 3.1, 12/01105, Attachment 1, Volume 10, Rev. 1, Page 55 of 98 Attachment 1, Volume 10, Rev. 1, Page 56 of 98 ECCS- Operating B 3.5.2 BASES SURVE ILLANCE REQUIREMENTS (continued)" rpositionof each mechanicaltp~vle] (SR3.5:2 0'... .... and DH-1413 is corctoese J This Surveillance the flow controller -the LPI throttle] 2 yem alves-will auto i--:cally control th LIEý flOw rate Ihedesired is maintained within range and prevent LPI pump runout as RCS pressure decreases aftera-LOCA. The flhonth Frequency is justified by the same reasons as those stated for SR 13.52.%\7 1 SR 3*.5.2 0 SR 3.5.2 r-- U 0 In addition, the screen components include the vertical strainers. Periodic inspections of the containment sump suction inlet ensure that it'is unrestricted and stays in proper operating condition. The Mtii nth f (Frequency is based on the. need to perform'this Surveillance under the conditions that apply~during a plant outage,;on the need to preserve accessrto the location, and on thepotential for~an unplanned transient if the, Surveillance were performed withthe reactor at power. This Frequency has been found to besufficient to detect abnormal degradation and has been confirmed by operating experience.. INSERT2 1. 1O'CFR 50.46.REFERENCES

2. FSAR, SectionM6.2$

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,. 1975.00 1 .IE Information Notice 17-, "RHR Valve Misalignment Causes Degradation of ECCS in P "January 6, 1987. 1'ASME Code for Operation ahd Maintenance of Nuclear: Power Plants.'6. NRC letter from J.B. Hopkins (NRC) to D.C. Shelton, Administrative Changes to Technical Specifications Bases, dated October 21, 1992. I 0 0 0 7. NRC letter from J.. Hopkins (NRC) to L.F. Storz, Issuance of Amendment 182, dated December 16, 1993.1 0 BWOG STS B 3.5.2-9 Rev. 3.1, 12/01/05 Attachment 1, Volume 10, Rev. 1, Page 56 of 98 Attachment 1, Volume 10, Rev. 1, Page 57of 98 B 3.5.2INSERT 2 S R 3.5.2.8 This Surveillance verifies that 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, following receipt of a Borated Water Storage Tank Level -Low Low signal (i.e., Table 3.3.5-1, Function 5). This SR also verifies each valve's closure or opening time, as applicable, is < 75 seconds. The closure and opening times are measured from when the operator pushes the control switch for the associated containment emergency sump valve until the valve is either fully open or closed, as applicable.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage.0 Insert Page B 3.5.2-9 Attachment 1, Volume 10, Rev. 1, Page 57 of 98 Attachment 1, Volume 10, Rev. 1, Page 58 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 58 of 98 Attachment 1, Volume 10, Rev. 1, Page 59 of 98 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 10, Rev. 1, Page 59 of 98 Attachment 1, Volume 10, Rev. 1, Page 60 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.5.2, ECCS -OPERATING There are no specific NSHC discussions for this Specification.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 60 of 98 Attachment'1, Volume 10, Rev. 1, Page 61 of 98 O ATTACHMENT 3 ITS 3.5.3, ECCS -SHUTDOWN 0 0 Attachment 1, Volume 10, Rev. 1, Page 61 of 98 Attachment 1, Volume 10, Rev. 1, Page 62 of 98* Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs).0 Attachment 1, Volume 10, Rev. 1, Page 62 of 98 Attachment 1, Volume 10, Rev. 1, Page 63 of 98 ITS 3.5.3 ITS EMERGENCT CORE COOLING STSTE24 ECCS SU8BSYSTEKS- .80 LI~hITING COn(ITTON FO.R OPERATION, LCO 3.5.3 ACTION A SR 3.5.3.1 3'.5.3 As: a oneECC.subsjyteq Icomrized of the fo~l"dn9.4l! be OFEWLE: I/la. Onee OPERA BLE ddetaheat (OR) p wj, the.cý An OPERABLE flow path capable of taking from.:the borated LAn01 water storage ta k (BUST). and manually. transfe ing suction" toý thet I containffmnt eme genc~y sump during'the recircu a Ion phase of,.[ opera tion.( --' r Add proposo LA~~ei 01)ftt 4.ACT'0.. Add proposed ACTION Note f -A02)a'. Wth no EC0S susy ste OPRABLE (becaue of !th inoperabi l ity'oQf Ch PH RPR, DH cooePor te A+' M,.{h a restore al; least one EMCS subsystem to 0PERABLE status within lont hour, or maintain the. Reactor Coolant System Tavti less than Rol R280" by use oqf al lteriat~e ýheat removal :mefhodsý_ '[i b.In the event t~e ECf is actuated and Injecs water into the reactor coolaot system, a Special Report sHall-be prepared and'submitted to he Commission pursuant to Sp/ecifcation

6.9.2 within

90 days describing the circuitancos of the actuation and the-totaA accumulated actuation cyclo# to' date.~IIW/tIflAR~f ~!0tflREM!NTS SURMLLANCE REOUIRDCM 1-91 The FM~ tubsvstams thill be de,~rstrated OPERA3LE Der Ft~e1 11applic~able S~rveillance Require:*nts of 4.5.; .i DA ~VISBSE UNT I 3/4 S-6 Amendment No. 57* f SR 3.5.2.1, SR 3.5.2.2, SR 3.5.2.3,l SR 3.5.2.4, SR 3.5.2.5, SR 3.5.2.6, SR 3.5.2.7, SR 3.5.2.8 S0 0 Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 63 of 98 Attachment 1, Volume 10, Rev. 1, Page 64 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.A04 CTS 4.5.3 states that ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2. One of the Surveillance Requirements is CTS 4.5.2.d.2.b), which 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 Davis-Besse Page 1 of 3 Attachment 1, Volume 10, Rev. 1, Page 64 of 98 Attachment 1, Volume 10, Rev. 1, Page 65 of 98 DISCUSSION OF CHANGES ITS 3.5.3, ECCS -SHUTDOWN 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 requires the same Surveillance, and is now specified in ITS SR 3.5.3.1, as justified in Discussion of Change (DOC), A03. However the exception statement"with the motor operators for the BWST outlet isolation valves and the containment emergency sump recirculation valves energized" is not included in ITS SR 3.5.2.8, and has been moved to LCO 3.5.2 as a Note. This is justified in ITS 3.5.2 DOC A04. Thus, the same Note needs to be included in ITS 3.5.3.The LCO 3.5.3 Note states "The borated water storage tank (BWST) outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable.". This changes the CTS by moving the location of the exception from the specific Surveillance to the LCO statement. The purpose of the exception is to allow the valve motors to be de-energized in MODES 1, 2, 3, and 4 to meet 10 CFR 50 Appendix R requirements. This is documented in the NRC Safety Evaluation for Amendment 182, dated 12/21/1993. While the valves are de-energized for this reason only, they are still considered OPERABLE (i.e.,the LCO is still being met). Thus, the change is acceptable since it is not changing the current requirement; it is only moving the'exception to the LCO statement to be consistent with the format of the ISTS.This change is considered administrative because it does not result in any technical changes 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 hour 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 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 280OF 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.0 Davis-Besse Page 2 of 3 Attachment 1, Volume 10, Rev. 1, Page 65 of 98 Attachment 1, Volume 10, Rev. 1, Page 66 of 98 DISCUSSION OF CHANGES ITS 3.5.3, ECCS -SHUTDOWN* 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. 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.0 Davis-Besse Page 3 of 3 Attachment 1, Volume 10, Rev. 1, Page 66 of 98 Attachment 1, Volume 10, Rev. 1, Page 67 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 10, Rev. 1, Page 67 of 98 Attachment 1, Volume 10, Rev. 1, Page 68 of 98 ECCS -Shutdown 3.5.3 CTS 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)3.5.3 ECCS -Shutdown r-dlow pressure injection (LPI) subsystem One ECCStrfin shall be OPERABLE.3.5.3 LCO 3.5.3 A UI-HK train "/ay ýe Considered O KERABLEdurinj alignment and operation foV/DHR, if capable of~being manually reA !igned to the ECCS ModO of operation. /JIV 4.5.2.d.2.b) S 2, High pressur) injection. (HPi) may be de-activate~d i,!accordance l I~ ~ ~ ~ ý 2 Tempe~rature Overpressur 7rtetq" The borated water storage tank (BWST) outlet and containment I ~emergency sump valves may be considered OPERABLE whenlI ~the associated valve motors are de-energized, provided the TY: MO E 4!. valves are not otherwise inoperable. .APPLICABILI LPI subsystem O DOC A02 Action a ACTIONS-C 304: i otaplca- ----- LCO' 3.0.4.b i's not applicable to ECCS~.CONDITION [LP subsystem REQUIRED ACTION 1 COMPLETION TIME A. Required ECCS dýo A.1 lnitiate actionto restore. Immediately heaVemoval (DH 10 required ECCS DH oop inoperable, to OPERABLE status.B. Required ECCS HP B.1 Restore required ECCS 1 hour subsystem inopera le. HPI subsystem to OPERABLE status.C. Required Action a d CAt Be in MODE 5. 24 hours associated Compl tion Time of Condition B not met.(DO-.0_0 0 0 3 8WVOG.STS 35.3-1 Rev. 310, 03/31104 Attachment 1, Volume 10, Rev. 1, Page 68 of 98 Attachment 1, Volume 10, Rev. 1, Page 69 of 98 ECCS -Shutdown 315.3 CTS ISURVEILLANCE REQUIREMENTS

SURVEILLANCE SR 3.5.3.1 For all equipment required to be OPERABLE, the following SRs are applicable

'FREQUENCY ...t ................... ... --............. .. ....... ." .........In accordance 'with ýapplicable SRS 4.5.3 SR 3,5.2,2 SR 35.24 SR .15.2.5ýSR'3.15.2.6 SR 352.7 R 1+5.2.8 TSR ;3/.2.9l 00 BWAOG STS 13513ý2 Rev. 3.0, 03131/04 0 Attachment 1, Volume 10, Rev. 1, Page 69 of 98 Attachment 1, Volume 10, Rev. 1, Page 70 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.6. CTS 4.5.3 states that EccS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2. One of the Surveillance Requirements is CTS 4.5.2.d.2.b), which 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 contr6l 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 requires the same Surveillance, and is now specified in ITS SR 3.5.3.1, as justified in Discussion of Change (DOC) A03. However the exemption statement "with the motor operators for the BWST outlet isolation valves and the containment emergency sump recirculation valves energized" is not included in ITS SR 3.5.2.8, and has been moved to LCO 3.5.2 as a Note. Thus, the same Note needs to be included in ITS 3.5.3. The LCO 3.5.3 Note states "The borated water storage tank (BWST) outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable." The justification for adding the Note is more fully described in ITS 3.5.2 Justification for Deviation 4.Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 70of 98 Attachment 1, Volume 10, Rev. 1, Page 71 of 98 VImproved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)0 0 Attachment 1, Volume 10, Rev. 1, Page 71 of 98 Attachment 1, Volume 10, Rev. 1, Page 72 of 98 ECCS -Shutdown B3.5.3 B.3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)ýB 3.5.3 .ECCS -.Shutdown BASES: BACKGROUND The B.ackground section for: Bases. B 3.5.2, "ECCS -Operating,"' is applicableto these Bases, withlthe folloing modifications. wi modifecatdecay Tn ODEC .rqS p ngashts of a hooe bubsystein c high he ssureainjection (H PI) and low p 3 es 1ue!ing th eressue iecion eaide nsislna ofINwo resundani,.00% cap : te i~E such thaf vmter,.from th borated vite toragetank' BWS ~can hetor10 b.. .... .. ...eR aco C oat yte ,(CS:f6~vhg h APPLICABLE SAFETY'ANALYSES The Applicable safetyiAnalysessection of Bases35.2 is applicable to these Bases.Dueqto the stable'conditionsi associated with operation in MODE 4 and the, reduced probability of occurrence of a Design Basis Accident (DBA), the ECOnSoperational requi red reduced. Isnclu eed inthese reductionsis stfat:6ertain automhatic Engineered sa WtFeature Actuation Syteý(E £eS), actuation Is no0 available: ]n~thi /MODE~suftiienttirne ,exists frranl a ntua ftfi~note~requii~ed.ECCS.t mitigaeth conse__encs -of, a DBAI that single failures are not considered during this MODE. The ECCStn.lsatisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

' " LPI subsystems LCO In MODE 4, one of the two independent (and redundant)

ECCSt sIis required to ensure sufficient ECCS flow is available to the core following a DBA.00 00 I subsstem In MODE 4, an ECCSýgn consists of an HPIlsu stemand an LPI NSERT 1 .the piping, instruments, and controls: to An LPI*ensure an OPERABLE flow path capable of takingasuction from the BVVST and transferring suction tothe. containment sump...{ ~ene~ecy 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 (q J-Ni pumpI: andtil~espective supply headers, to each of the [i old.~0 IJ ction nozzles. In the long term, thisflow path may be witched to take its supply from the.containmen sump a Iflowto~the. --and coldle emergency subsystem 0 0©0 BWOG STS: B 3.5.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 72 of 98 Attachment 1, Volume 10, Rev. 1, Page 73 of 98 B 3.5.3 (O INSERT I an LPI pump, a decay heat cooler, and 0 Insert Page B 3.5.3-1 Attachment 1, Volume 10, Rev. 1, Page 73 of 98 Attachment 1, Volume 10, Rev. 1, Page 74 of 98 0 As Noted, the BWST outlet and containment emergency sump valves may be considered OPERABLE when the associated valve motors are de-energized, provided the valves are not otherwise inoperable. This allowance is necessary since the motor operators are normally de-energized in MODES 1, 2, 3, and 4 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 (i.e., to meet 10 CFR 50 Appendix R requirements). This allowance was originally approved by the NRC in References 6 and 7.ECCS -,Shutdown B 3.5;3 BASES LCO (continued) Thisý LC , is modifie by two Notes, The first allows DHR train to be, considered OPERA LE during alignment anId:operat 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 lew This allows, operation inlthe mode during'MODE

4. T.he s Icond Note statesthat HPI actuation may be deactivated in accordanice thLCO 3r4.12, Low Temperature Qve ressure Protection

!(LTOP) Sy em." Operator action is then required t initiate HPI. In the event of a I s of coolant accident (LOCA) requiring P1, actuation, the time equi4red1for operator action has, been:shown by alysis to be acceptable. 0 APPLICABILITY In MODES 1, 2, and 3,the OPERAB.LItY' requirements.for the ECCS are: covered by, LCO 3.5.2.in MODE 4 with'the RCSltemperaturelbelow 280*F, ono.OPERABLEr LPI subsystem ECC is acceptable without single failure consideration -on the basis of the stab reactivity co.ndition of the-reactor[and the limited core cooling require ments.Q In MODES5 and.6, plant conditions.are such that the probability ofan...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 3.418, 'RCS Loops -MODE,5,; Loops No tFilled." MODE 6 coremcooling ýrequirements are addressed.'by LCO 3.9.4, "DHR and Coolant.,irculation -High Water Level,," and LCO 3.9.5, DHR and Coolant Circulation -LowWater Levei." V~ eae _ý_ ýLPI subsystem ACTIONS:; A Note prohibits the application of LCO,3.0.4.b to inoperable ECCS[ LPI sbsyste f---R when entering MODE 4 from MODEE5. There is an increased risky 2 associated with entering MODE 4 from MODE:5 with po erable and the provisions of LCO 310.4.b, which allow entry into a MODE or other the LPI subsystem specified condition in the Applicabilitywith-the. LCO not met.after performance of a risk assessment addressing inoperable systems and component shouild not be-applied in this circumstance. {.The provision 0 BWOG STS B3.5.3-2 Rev. 3.0,03131/04 Attachment 1, Volume 10, Rev. 1, Page 74 of 98 Attachment 1, Volume 10, Rev. 1, Page 75 of 98 ECCS -Shutdown B.315:3 BASES ACTIONS (continued) A.1 If no LPI subsystet ntrn 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 t be removed by an Ltr n operating.with suction from theý R1S. If no sy LPI tr n isOPERABLE 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 continuation of decay heat removal (D ) is provided.With both-Kzg pumps and heat exchangers inoperable, it.would be unwise to require the plant to go. to MODE 5, where the only available ubsystems heat removal system is the LPI r s operating in the 9- eCmoval 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.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 hour Compl tion Time to restore at least on ECCS HPI subsystem to OPERABLE st us ensures that prompt action i taken to provide the required cooling pacity or to initiate actions to pl ce the plant in MODE 5, where n ECCS train is not required.0 0 PA.Whnen 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 hours is reasonable based on operating experience, to rea h MODE 5 from full power cond tions in an orderly manner and with ut challenging plant systems.0 BWOG STS B 3.5.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 75 of 98 Attachment 1, Volume 10, Rev. 1, Page 76 of 98 ECCS -Shutdown B 35.3 BASES SURVEILLANCE REQUIREMENTS SR 3.5.3.1 The applicable Surveillanwcedescriptions from Bases 3.5.2 app ly.The applicable references from Bases.3.5.2:apply. REFERENCES 0 0 BWOG STS B 3.53-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 76 of 98 Attachment 1, Volume 10, Rev. 1, Page 77, 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.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 77 of 98 Attachment 1, Volume 10, Rev. 1, Page 78 of 98 Specific No Significant Hazards Considerations (NSHCs)0 Attachment 1, Volume 10, Rev. 1, Page 78 of 98 Attachment 1, Volume 10, Rev. 1, Page 79 of 98 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS.

ITS 3.5.3, ECCS -SHUTDOWN There are no specific NSHC discussions for this Specification. 0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 79 of 98 Attachment 1, Volume 10, Rev. 1, Page 80 of 98 1W ATTACHMENT 4 ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)0J 0 Attachment 1, Volume 10, Rev. 1, Page 80 of 98 Attachment 1, Volume 10, Rev. 1, Page 81 of 98*Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)0 0 Attachment 1, Volume 10, Rev. 1., Page 81 of 98 Attachment 1, Volume 10, Rev. 1, Page 82 of 98 ITS 3.5.4 ITS EMERGENCY CORE COOLING SYSTEMS BORATED WATER STORAGETANK LIMITING CONDITION FOR OPERATION LCO 3.5.4 135.4 The borated water storage tank (BWST) shall be OPERABLE with: SR 3.5.4.2. a. An borated water volume of between 500,100 and 550,000 gallons,5 I SR 3.5.4.3 b, 2j60O:and 2800"ppm otfboron, and SR Add proposed maximum water temperature Mot SR 3.5.4.1 ,. A minimum water tem perature of 35'F.,APiLTCABiLTY: MODES 1,2'3. and'4.:.ACTION: ACTION A a.With the.BWST inoperable because of boron concentration or temperature not iOLwthin limits, restore the BWST to OPERABLE status within 8 hours or be in at ACTION C east T within the next 6 hours and in COLD SHUTDOWN within~the following 30 hours.ACTION B b. With the BWST inoperable for reasons.other than boron concentration or temperature not-within limitsi restore the BWST to OPERABLE status within one hour/ore in at least HOT STANDBY within the next 6 hours and i h COLD ACTION C SHUTDOWN within thefollowing 30.hours: SURVEILLANCE REQUIREMENTS 4.5.4 The BWST shall be demonstrated.OPERABLE:

a. At least onceper 7 days by: SR 3.5.4.2 1. Verifying the 4Iborated water volume in the tank, L.0 SR 3.5.4:3 2. Verifying the boron concentration of the water.SR 3.5.4.1 b. At least once per 24 hours by verifying the watertemperature when outside air, temperature

<35 °F DAVIS-BESSE, UNIT I 314 5-7 Amendment No. 36, 123, 191, 207, 241 Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 82 of 98 Attachment 1, Volume 10, Rev. 1, Page 83 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 and CTS 4.5.4.b verifies the minimum limit every 24 hours when air temperature is < 35 0 F. 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 limits if the ambient air temperature is greater than new maximum BWST water temperature limit or less than the current minimum BWST water temperature limit. This changes the CTS by adding a new maximum BWST water temperature limit and requires it checked every 24 hours unless the ambient air temperature is less than or equal to the maximum BWST water* temperature limit.The purpose of CTS LCO 3.5.4.c and CTS 4.5.4.b is to ensure the BWSF 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 LA01 (Type 3 -Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.5.4.a requires an available borated water volume of between 500,100 and 550,000 gallons and CTS 4.5.4.a.1 requires verification that the available borated water volume in the BWST is within limits.ITS SR 3.5.4.2 requires verification of the BWST borated water volume, but does not specify that it is the available volume. This changes the CTS by moving the detail of what constitutes the borated water volume to the Bases.The removal of this detail 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 that the borated water volume is between 500,100 and 550,000 gallons and that it is periodically verified. Also, this type of change is acceptable because these types Davis-Besse Page 1 of 2 Attachment 1, Volume 10, Rev. 1, Page 83 of 98 Attachment 1, Volume 10, Rev. 1, Page 84 of 98 0 DISCUSSION OF CHANGES ITS 3.5.4, BORATED WATER STORAGE TANK (BWST)of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications 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 because procedural details for meeting Technical Specification requirements are being removed from the CTS.REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES None Davis-Besse Page 2 of 2 Attachment 1, Volume 10, Rev. 1, Page 84 of 98 Attachment 1, Volume 10, Rev. 1, Page 85 of 98 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)0 Attachment 1, Volume 10, Rev. 1, Page 85 of 98 Attachment 1, Volume 10, Rev. 1, Page 86 of 98 BWST 3,5.4 3,5 EMERGENCY CORE COOLING SYSTEMS (ECCS)3.5.4 Borated Water Storage Tank (BWST)LCO 3.5.4 LCO 3.5i4: The BWST shall be OPERABLE.APPLICABILITY: MODES 1, 2, 3, and 4.ACTIONS Action a 0 Action b.CONDITION. REQUIRED ACTION COMPLETIQN TIME A. BVVST boron A.1 Restore BWST to '8 hours concentration not within OPERABLE status.limits.OR B\ST water temperature not within limits.B. BVST inoperable for B.1 Restore BWST to 1 hour reasons other than OPERABLE status.Condition A.Actions a and b C. Required Action and associated Completion Time not met.C.1 Be in MODE 3.AND C.2 6 hours 36 hours Be in MODE 5.BWOG STS 3.5.4-1 Rev, 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 86 of 98 Attachment 1, Volume 10, Rev. 1, Page 87 of 98 CTS BWST 3.5.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.3.5.4.c, 4.5.4.b SR 3.5.4.1--------------.-- NOTE ------Only required.to beperformed when ambient air F3j,2_t!rperatlureis s.EF or > Lo 0 0 Verify BWVST borated water tmeauei >and! ff%'V 24 hours 3.5.4.a, 4.5.4.a.1 3.5.4.b, 4.5.4.a.2 SR 35.4.2 Verif BWT borated water volume is> [[41, OýgqaIhons!4Tj]Mand[ Oagallonsml 500,100 55000 7 days 0 0 SIR 1.5.4.3 Verify BWSIT boron concentration is*22 01ppm 7 days and < 990pm ___- 20 BVVOG STS 3.5A-2 Rev. 3.0; 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 87 of 98 Attachment 1, Volume 10, Rev. 1, 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.i Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 88 of 98 Attachment 1, Volume 10, Rev. 1, Page 89 of 98 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)Attachment 1, Volume 10, Rev. 1, Page 89 of 98 Attachment 1, Volume 10, Rev. 1, 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 BV\ST 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 Frefueling[-Ffor refueling operations. 0 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 isolatethe BWST from (y the ECCS after the ECCS pump suction has been'transferred 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 ntainment spray pumps are, provi d with recirculation lines that ens e each pump can maintain minim flow requirements 0 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 phas 0 b. Sufficient water volume exists in e containment sump to support continued operation of the ECCS and containment spray pumps at the time of transfer to the recirculation mode of coolingand

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 jexce boric acid precipitation in the core following a LOCA, as well as excessive caustic stress corrosion of mechanical components and systems inside containment.

BW\OG STS B 3.5.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 90 of 98 Attachment 1, Volume 10, Rev. 1, Page 91 of 98 0 BWST B3.5.4 BASES APPLI(SAFET ANAL'Y CABLE During accident conditions, the BWST provides a source of borated.Y water to the high pressure injection (H PI), low pressure injection (LPI),'SES and containment spraypumps. 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 otf---thBses of (3)LCeif ions 3.5.2, 'ECCS -Operating," and 3.6.6, "Containment Air ýSrta .,and ooling.Systems.' These analyses are used to assess changes to the BWST in order to evaluate their effects 'in relation to the'acceptance limits. R j F_500,100Oý The, limits on volume of 15 gallons and S gallon are Per NUREGto based on several factors.,, $ufficient deliverablevolume must be available 0 080 Setion 6.3 (Ref. 1), -to. provide at least 20 minutes of full flow of all ECCS pumps prior to. th transfer tothe containment sump for recirculation Twentminute gives 'the operator adequate time to prepare for switchover to containment sump recirculation. / .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 full] transfer to recirculation occurs. When ECCS.pump* suction is tra nsferred flow of all ECCS pumps. 'to the sump, there must be sufficieht water in the sump to ensure: adequate net. positive suction head (NPSH).for the LPIland containme tL2 spray pumps. This NPSH calculation is described in the SR (Ref:and the amount of water.that enters the sump from the BVWST and other souricsiso bne.of input assumptions. Sincelthe BWST is the main so6rce that contributes to the 6amount-of water in the sump following a LOCA, the calculation does not take.credit for more than the, minimum ( I'volume of usa ble water the BwST.(i.e., water above the discharge line location) The thirdfactoris that the volume 'of water in the.BVVST 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 t0 ItotaL-eth-r thanl usa blem volume required to be in the BV\ST; a.certain amount of water is unusable becauseof tank discharge line locationIor othepracteristi 0 0 0 BWOG STS'B 3.5.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 91 of 98 Attachment 1, Volume 10, Rev. 1, Page 92 of 98 BWST B 3.5A4 BASES APPLICABLE SAFETY ANALYSES (continued).The -ppm ~iit for minimum boron concentration was established to ensure that, following a.LOCA, with a mininum BWST level, the reacdtIor will remain subcritical in the cold condition following mixing of the BWVST ,and Reactor Coolant System (RCS) water volumes. Large break LOCAs u control rods remain withdrawn from the core.The minimum and maximum concentration limits both ensure that the solution in'the sump.fo0lowing~a LOCAis within a specified pH range that will minimize the evolution of iodine and the effectof chloride and caustic:.stress corrosion cracking on themechanical systems and. components., The ppm maximum 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 followingaLOCA.. 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 inthiis 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 theoperator to establish dilution flow paths, in the LPI System to prevent thiscondition by establishing a forced flow path through the core regardless of .break location. These procedures are based on the minimum time in which precipitatibn could occur, assuming that maximum boron concentrations exist in the borated water. sources_ ,used for injection following a LOCAK 0 0 0 0 0 0 0 0 i r reduce the time available to 'initiate boric acid precipitation Boron'concentrations in'the BWST in excess of the limit couldr control measures, which are taken to avoid reaching the reci itation rethan assume e analysi Sol ubility limit 35 The lower limit on the temperature of thesolution in the BViTF is assumed for the I established t re that.the solu not freez. This temperature containment also helps prevent boron precipitation and ensures tht water injection in vessel vacuum the reactor Ves will not be colder than the. Iowes emperature assumed\breaker sizing ba sz in reactor l stress analy si .TheI El0O&t upper limit on the 90 temperature of the.BWST contents is consistent with the maximum irijection water temperatureassumed in the, LOCA analysis.The numerical values of the parameters stated in the SR are actual values and do not include allowance for instrument errorl The BWST satisfies:Criterion 3,of 10CFR 50.36(c)(2)(ii),with the exception of the BWST minimum volume of 500,100, This value is instrument error compensated to ensure the required minimum volume is available for injection into the core and containment. The remaining values are either instrument uncertainty adjusted in surveillance procedures or include sufficient analysis margin such that the ,instrument errors would be bounded by the margin. I 0 BWOG STS B 3.5.4-3 Rev. 3.0. 03/31/04 Attachment 1, Volume 10, Rev. 1, Page 92 of 98 Attachment 1, Volume 10, Rev. 1, Page 93 of 98 0 BWST B 3.5.4 BASES LCO The BWST exists to ensure that an 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 reactorremains 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 tODF. To be considered OPERABLE, the BWST must meet the limits for water Volume, boron 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 BWST 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 34.8, "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 andCoolant 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 hours. In this Containment condition', neither the ECCS nor the Rector Buold pray System can, (perform its design functions. Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which these systems are not required. The 8 hour 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 FOPERABLE status With the BWVST inoperable for reasonother than Condition A (e.g., water volumeg, must be restored to wit req uired mits within 1 hour. In this condition, neither the ECCS nor the Containment Spray System can BT,___ perform its design functions. Therefore, prompt action must be taken to restore th~iito OPERABLE status or to place the plant in a MODE in which the BWST is not required. The allowed Completion Time of 1 hour 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 0 Attachment 1, Volume 10, Rev. 1, Page 93 of 98 Attachment 1, Volume 10, Rev. 1, Page 94 of 98 BWST B 3.5.4 BASES ACTIONS (continued) iCA and C.2 If the.BVST cannot-be restored tWOPERABLE status within the ,associated Completion Time. the plant must be brought to a MODE in whichthe: LCO does not apply. To achieve this status, the plant must be brought.to at least MODE 3.within 6 hours and to MODE5 within 36 ho0urs., The allowed Completion Times are reasonable, based on operating'experience, to reach the ,required plant conditionsfrom full power conditions in an orderly manner and without'challenging plant.systerms SURVEILLANCE ZSR. 3.5.411.REQUIREMENTS Verification every 24 hours that the, BST water temperature is within the specified'temperature band ensures that the boron will not precipitate; theWill n/W. reeze; the fluid temperature enterin/gffhe% reactor vessel wil conaime breaker sizin not be Ider than assumed in'the reactor ve stress analysis;and the.vassumptekeizing is met fluid temperature entering the reactor vessel will not b;e _hotter than assumed in the'LOCA analysis. The 24 hour, Frequency is sufficient to identify atemperature change that would approach either' temperature limit and has been shown to. be acceptable through operating expeirience. The SRis modified by a Note that requires the Surveillance to be performed only when ambient air temperatures areoutside the operating temperature limits of the BWST. Wth ambient temperatures within this band, the BWST temperature Should not exceed the limits.SR 3.5ý.2 available, Verification every 7 days that the BWST ed volume is within the ()required range ensuresthat a sufficient initial supply is available for injection and to support continued ECCS pump operation on recirculation. Since the BVVT volume is normally stable and provided with a low level ablarm; a 7 day Frequency has been shown' to be.appropriate through opeiratihg ,experience.

The limits on water volume reflect the available volume since a portion of the contained volume of the BWST is not 0 available because of the tank discharge configuration.

0 BVOG STS B 3.5.4-5 Rev 3;0. 0/311t04 Attachment 1, Volume 10, Rev. 1, Page 94 of 98 Attachment 1, Volume 10, Rev. 1, Page 95 of 98 0 BWST B 35.4 BASES SURVEILLANCE REQUIREMENTS (continued) 'SR 315.4,3 Verification eveiy 7 days:that the boron cbncentratibn 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 throughoperating, experience. REFERENCES ffýM. ,FSAR, Section Mss-E I 1. NUREG-0800, Section 6.3. .00 0 0 BVVOGSTS B 3.5.4-6 Rev. 3.0,03131104 Attachment 1, Volume 10, Rev. 1, Page 95 of 98 Attachment 1, Volume 10, Rev. 1, 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.9. Changes have been made to explain that the minimum and maximum BWST volumes are the available volume.0 Davis-Besse Page 1 of 1 Attachment 1, Volume 10, Rev. 1, Page 96 of 98 Attachment 1, Volume 10, Rev. 1, Page 97 of 98 WSpecific No Significant Hazards Considerations (NSHCs)0 0 Attachment 1, Volume 10, Rev. 1, Page 97 of 98 Attachment 1, Volume 10, Rev. 1, 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.

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

v t e Letter Sequence Other
TAC:MD6398, Increase Flexibility in Mode Restraints, Addition of LCO 3.0.8, Inoperability of Snubbers, Deletion of E BAR Definition and Revision to RCS Specific Activity Tech Spec, Changes to Reflect Revision of 10 CFR 50.55A, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Correct Example 1.4-1, Containment Structural Integrity, TSTF-28, Correct LCO 3.0.6 Bases, Add Restriction for Lowest LOOP Tave During Mode 2 Physics Testing (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement Administration Meeting, Meeting, Meeting Questions 18 June 2008 20 June 2008 Answers 23 July 2008 3 September 2008 Results Approval Other: L-08-161, Copy of Applicable Portions of the NRC and Davis-Besse Improved Technical Specifications Conversion Website - Sections 3.0, 3.1, 3.2, 3.4, and 3.6 and Chapter 4.0, L-08-241, Attachment 1, Applicable Portions of the U.S. Nuclear Regulatory Commission (NRC) and Davis-Besse Nuclear Power Station (DBNPS) Improved. Technical Specification (ITS) Conversion Website, Section 3.5 RAIs, L-08-338, Copy of Improved Technical Specifications (ITS), L-08-378, Implementation of Improved Technical Specification Amendment No. 279, ML073531253, ML081350505, ML082000451, ML082270661, ML082270662, ML082270663, ML082270664, ML082270665, ML082270666, ML082270667, ML082270669, ML082270670, ML082600577, ML082840099, ML082900630, ML082900882, ML082910125
MONTHYEAR2008-02-04 [Table View]

ML082270666

Text

6.9.2 within

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