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Developmental Revision B - Technical Specifications Bases B 3.4 - Reactor Coolant System
	ML100550505
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Site:	Watts Bar
Issue date:	02/02/2010
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
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RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits BASES BACKGROUND These Bases address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses.

The safety analyses (Ref. 1) of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on RCS pressure, temperature, and flow rate ensure that the minimum departure from nucleate boiling ratio (DNBR) will be met for each of the transients analyzed.

The RCS pressure limit is consistent with operation within the nominal operational envelope. Pressurizer pressure indications are averaged to come up with a value for comparison to the limit. A lower pressure will cause the reactor core to approach DNB limits.

The RCS coolant average temperature limit is consistent with full power operation within the nominal operational envelope. Indications of temperature are averaged to determine a value for comparison to the limit. A higher average temperature will cause the core to approach DNB limits.

The RCS flow rate normally remains constant during an operational fuel cycle with all pumps running. The minimum RCS flow limit corresponds to that assumed for DNB analyses. Flow rate indications are averaged to come up with a value for comparison to the limit. A lower RCS flow will cause the core to approach DNB limits.

Operation for significant periods of time outside these DNB limits increases the likelihood of a fuel cladding failure in a DNB limited event.

(continued)

Watts Bar - Unit 2 B 3.4-1 (developmental) A

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES (continued)

APPLICABLE The requirements of this LCO represent the initial conditions for DNB SAFETY limited transients analyzed in the plant safety analyses (Ref. 1). The ANALYSES safety analyses have shown that transients initiated from the limits of this LCO will result in meeting the DNBR criterion. This is the acceptance limit for the RCS DNB parameters. Changes to the unit that could impact these parameters must be assessed for their impact on the DNBR criteria. The transients analyzed for include loss of coolant flow events and dropped or stuck rod events. A key assumption for the analysis of these events is that the core power distribution is within the limits of LCO 3.1.7, Control Bank Insertion Limits; LCO 3.2.3, AXIAL FLUX DIFFERENCE (AFD); and LCO 3.2.4, QUADRANT POWER TILT RATIO (QPTR).

The pressurizer pressure limit of 2214 psig and the RCS average temperature limit of 593.2°F correspond to analytical limits of 2185 psig and 594.2°F used in the safety analyses, with allowance for measurement uncertainty.

The RCS DNB parameters satisfy Criterion 2 of the NRC Policy Statement.

LCO This LCO specifies limits on the monitored process variables - pressurizer pressure, RCS average temperature, and RCS total flow rate - to ensure the core operates within the limits assumed in the safety analyses.

Operating within these limits will result in meeting the DNBR criterion in the event of a DNB limited transient.

RCS total flow rate contains a measurement error of 1.6% (process computer) or 1.8% (control board indication) based on performing a precision heat balance and using the result to calibrate the RCS flow rate indicators. Potential fouling of the feedwater venturi, which might not be detected, could bias the result from the precision heat balance in a nonconservative manner. Therefore, a penalty of 0.1% for undetected fouling of the feedwater venturi raises the nominal flow measurement allowance to 1.7% (process computer) or 1.9% (control board indication).

Any fouling that might bias the flow rate measurement greater than 0.1%

can be detected by monitoring and trending various plant performance parameters. If detected, either the effect of the fouling shall be quantified and compensated for in the RCS flow rate measurement or the venturi shall be cleaned to eliminate the fouling. The LCO numerical values for pressure, temperature, and flow rate are given for the measurement location and have been adjusted for instrument error.

(continued)

Watts Bar - Unit 2 B 3.4-2 (developmental) A

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES APPLICABILITY In MODE 1, the limits on pressurizer pressure, RCS coolant average temperature, and RCS flow rate must be maintained during steady state operation in order to ensure DNBR criteria will be met in the event of an unplanned loss of forced coolant flow or other DNB limited transient. In all other MODES, the power level is low enough that DNB is not a concern.

A Note has been added to indicate the limit on pressurizer pressure is not applicable during short term operational transients such as a THERMAL POWER ramp increase > 5% RTP per minute or a THERMAL POWER step increase > 10% RTP. These conditions represent short term perturbations where actions to control pressure variations might be counterproductive. Also, since they represent transients initiated from power levels < 100% RTP, an increased DNBR margin exists to offset the temporary pressure variations.

Another set of limits on DNB related parameters is provided in SL 2.1.1, Reactor Core SLs. Those limits are less restrictive than the limits of this LCO, but violation of a Safety Limit (SL) merits a stricter, more severe Required Action. Should a violation of this LCO occur, the operator must check whether or not an SL may have been exceeded.

ACTIONS A.1 RCS pressure and RCS average temperature are controllable and measurable parameters. With one or both of these parameters not within LCO limits, action must be taken to restore parameter(s).

(continued)

Watts Bar - Unit 2 B 3.4-3 (developmental) B

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES ACTIONS A.1 (continued)

RCS total flow rate is not a controllable parameter and is not expected to vary during steady state operation. If the indicated RCS total flow rate is below the LCO limit, power must be reduced, as required by Required Action B.1, to restore DNB margin and eliminate the potential for violation of the accident analysis bounds.

The 2-hour Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to determine the cause for the off normal condition, and to restore the readings within limits, and is based on plant operating experience.

B.1 If Required Action A.1 is not met 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 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable to reach the required plant conditions in an orderly manner.

SURVEILLANCE SR 3.4.1.1

REQUIREMENTS Since Required Action A.1 allows a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore parameters that are not within limits, the 12-hour Surveillance Frequency for verifying that the pressurizer pressure is sufficient to ensure the pressure can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12-hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions.

(continued)

Watts Bar - Unit 2 B 3.4-4 (developmental) A

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES SURVEILLANCE SR 3.4.1.2

REQUIREMENTS (continued) Since Required Action A.1 allows a Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore parameters that are not within limits, the 12-hour Surveillance Frequency for verifying RCS average temperature is sufficient to ensure the temperature can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions.

SR 3.4.1.3

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Surveillance Frequency to verify the RCS total flow rate is performed using the installed flow instrumentation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess potential degradation and to verify operation within safety analysis assumptions.

SR 3.4.1.4

Measurement of RCS total flow rate by performance of a precision calorimetric heat balance once every 18 months allows the installed RCS flow instrumentation to be calibrated and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate.

The Frequency of 18 months reflects the importance of verifying flow after a refueling outage when the core has been altered, which may have caused an alteration of flow resistance.

This SR is modified by a Note that allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 90% RTP. This exception is appropriate since the heat balance method requires the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies. The Surveillance shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching 90% RTP.

Note: The accuracy of the instruments used for monitoring RCS pressure, temperature and flow rate is discussed in this Bases section under LCO.

Watts Bar - Unit 2 B 3.4-5 (developmental) B

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES REFERENCES 1. Watts Bar FSAR, Section 15.0, Accident Analysis, Section 15.2, Condition II - Faults of Moderate Frequency, and Section 15.3.4, Complete Loss Of Forced Reactor Coolant Flow.

Watts Bar - Unit 2 B 3.4-6 (developmental) B

RCS Minimum Temperature for Criticality B 3.4.2 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.2 RCS Minimum Temperature for Criticality BASES BACKGROUND This LCO is based upon meeting several major considerations before the reactor can be made critical and while the reactor is critical.

The first consideration is moderator temperature coefficient (MTC),

LCO 3.1.4, "Moderator Temperature Coefficient (MTC)." In the transient and accident analyses, the MTC is assumed to be in a range from slightly positive to negative, and the operating temperature is assumed to be within the nominal operating envelope while the reactor is critical. The LCO on minimum temperature for criticality helps ensure the plant is operated consistent with these assumptions.

The second consideration is the protective instrumentation. Because certain protective instrumentation (e.g., excore neutron detectors) can be affected by moderator temperature, a temperature value within the nominal operating envelope is chosen to ensure proper indication and response while the reactor is critical.

The third consideration is the pressurizer operating characteristics. The transient and accident analyses assume that the pressurizer is within its normal startup and operating range (i.e., saturated conditions and steam bubble present). It is also assumed that the RCS temperature is within its normal expected range for startup and power operation. Since the density of the water, and hence the response of the pressurizer to transients, depends upon the initial temperature of the moderator, a minimum value for moderator temperature within the nominal operating envelope is chosen.

The fourth consideration is that the reactor vessel is above its minimum nil ductility reference temperature when the reactor is critical.

(continued)

Watts Bar - Unit 2 B 3.4-7 (developmental) A

RCS Minimum Temperature for Criticality B 3.4.2 BASES (continued)

APPLICABLE Although the RCS minimum temperature for criticality is not itself an initial SAFETY condition assumed in Design Basis Accidents (DBAs), the closely aligned ANALYSES temperature for hot zero power (HZP) is a process variable that is an initial condition of DBAs, such as the rod cluster control assembly (RCCA) withdrawal, RCCA ejection, and main steam line break accidents performed at zero power that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.

All low power safety analyses assume initial RCS loop temperatures the HZP temperature of 557°F (Ref. 1). The minimum temperature for criticality limitation provides a small band, 6°F, for critical operation below HZP. This band allows critical operation below HZP during plant startup and does not adversely affect any safety analyses since the MTC is not significantly affected by the small temperature difference between HZP and the minimum temperature for criticality.

The RCS minimum temperature for criticality satisfies Criterion 2 of the NRC Policy Statement.

LCO Compliance with the LCO ensures that the reactor will not be made or maintained critical (keff 1.0) at a temperature less than a small band below the HZP temperature, which is assumed in the safety analysis.

Failure to meet the requirements of this LCO may produce initial conditions inconsistent with the initial conditions assumed in the safety analysis.

APPLICABILITY In MODE 1 and MODE 2, with keff 1.0, LCO 3.4.2 is applicable since the reactor can only be critical (keff 1.0) in these MODES.

The special test exception of LCO 3.1.10, "PHYSICS TESTS Exceptions

- MODE 2," permits PHYSICS TESTS to be performed at 5% RTP with RCS loop average temperatures slightly lower than normally allowed so that fundamental nuclear characteristics of the core can be verified. In order for nuclear characteristics to be accurately measured, it may be necessary to operate outside the normal restrictions of this LCO. For example, to measure the MTC at beginning of cycle, it is necessary to allow RCS loop average temperatures to fall below Tno load, which may cause RCS loop average temperatures to fall below the temperature limit of this LCO.

(continued)

Watts Bar - Unit 2 B 3.4-8 (developmental) A

RCS Minimum Temperature for Criticality B 3.4.2 BASES (continued)

ACTIONS A.1 If the parameters that are outside the limit cannot be restored, 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 MODE 3 within 30 minutes. Rapid reactor shutdown can be readily and practically achieved within a 30-minute period. The allowed time is reasonable, based on operating experience, to reach MODE 3 in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.2.1 REQUIREMENTS RCS loop average temperature is required to be verified at or above 551°F (value does not account for instrument error) every 30 minutes when the Tavg - Tref deviation alarm is not reset and any RCS loop Tavg <

561°F.

The Note modifies the SR. When any RCS loop average temperature is

< 561°F and the Tavg - Tref deviation alarm is alarming, RCS loop average temperatures could fall below the LCO requirement without additional warning. The SR to verify RCS loop average temperatures every 30 minutes is frequent enough to prevent the inadvertent violation of the LCO.

REFERENCES 1. Watts Bar FSAR, Section 15.0, "Accident Analysis."

Watts Bar - Unit 2 B 3.4-9 (developmental) B

RCS P/T Limits B 3.4.3 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.3 RCS Pressure and Temperature (P/T) Limits BASES BACKGROUND All components of the RCS are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and shutdown (cooldown) operations, power transients, and reactor trips. This LCO limits the pressure and temperature changes during RCS heatup and cooldown, within the design assumptions and the stress limits for cyclic operation.

The PTLR contains P/T limit curves for heatup, cooldown, inservice leak and hydrostatic (ISLH) testing, and data for the maximum rate of change of reactor coolant temperature (Ref. 1).

Each P/T limit curve defines an acceptable region for normal operation.

The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region.

The LCO establishes operating limits that provide a margin to brittle failure of the reactor vessel and piping of the reactor coolant pressure boundary (RCPB). The vessel is the component most subject to brittle failure, and the LCO limits apply mainly to the vessel. The limits do not apply to the pressurizer, which has different design characteristics and operating functions.

10 CFR 50, Appendix G (Ref. 2), requires the establishment of P/T limits for specific material fracture toughness requirements of the RCPB materials. Reference 2 requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. It mandates the use of the American Society of Mechanical Engineers (ASME) Code,Section XI, Appendix G (Ref. 3).

The neutron embrittlement effect on the material toughness is reflected by increasing the nil ductility reference temperature (RTNDT) as exposure to neutron fluence increases.

(continued)

Watts Bar - Unit 2 B 3.4-10 (developmental) B

RCS P/T Limits B 3.4.3 BASES BACKGROUND The actual shift in the RTNDT of the vessel material will be established (continued) periodically by removing and evaluating the irradiated reactor vessel material specimens, in accordance with ASTM E 185 (Ref. 4) and Appendix H of 10 CFR 50 (Ref. 5). The operating P/T limit curves will be adjusted, as necessary, based on the evaluation findings and the recommendations of Regulatory Guide 1.99 (Ref. 6).

The P/T limit curves are composite curves established by superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the P/T limit curves, different locations are more restrictive, and, thus, the curves are composites of the most restrictive regions.

The heatup curve represents a different set of restrictions than the cooldown curve because the directions of the thermal gradients through the vessel wall are reversed. The thermal gradient reversal alters the location of the tensile stress between the outer and inner walls.

The criticality limit curve includes the Reference 2 requirement that it be 40°F above the heatup curve or the cooldown curve, and not less than the minimum permissible temperature for ISLH testing. However, the criticality curve is not operationally limiting; a more restrictive limit exists in LCO 3.4.2, "RCS Minimum Temperature for Criticality."

The consequence of violating the LCO limits is that the RCS has been operated under conditions that can result in brittle failure of the RCPB, possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components.

The ASME Code,Section XI, Appendix E (Ref. 7), provides a recommended methodology for evaluating an operating event that causes an excursion outside the limits.

(continued)

Watts Bar - Unit 2 B 3.4-11 (developmental) A

RCS P/T Limits B 3.4.3 BASES (continued)

APPLICABLE The P/T limits are not derived from Design Basis Accident (DBA)

SAFETY analyses. They are prescribed during normal operation to avoid ANALYSES encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws to propagate and cause nonductile failure of the RCPB, an unanalyzed condition. Reference 8 establishes the methodology for determining the P/T limits. Although the P/T limits are not derived from any DBA, the P/T limits are acceptance limits since they preclude operation in an unanalyzed condition.

RCS P/T limits satisfy Criterion 2 of the NRC Policy Statement.

LCO The two elements of this LCO are:

a. The limit curves for heatup, cooldown, and ISLH testing; and

b. Limits on the rate of change of temperature.

The LCO limits apply to all components of the RCS, except the pressurizer. These limits define allowable operating regions and permit a large number of operating cycles while providing a wide margin to nonductile failure.

The limits for the rate of change of temperature control and the thermal gradient through the vessel wall are used as inputs for calculating the heatup, cooldown, and ISLH testing P/T limit curves. Thus, the LCO for the rate of change of temperature restricts stresses caused by thermal gradients and also ensures the validity of the P/T limit curves.

Violating the LCO limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCPB components. The consequences depend on several factors, as follow:

a. The severity of the departure from the allowable operating P/T regime or the severity of the rate of change of temperature;

b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced); and

c. The existences, sizes, and orientations of flaws in the vessel material.

(continued)

Watts Bar - Unit 2 B 3.4-12 (developmental) B

RCS P/T Limits B 3.4.3 BASES (continued)

APPLICABILITY The RCS P/T limits LCO provides a definition of acceptable operation for prevention of nonductile failure in accordance with 10 CFR 50, Appendix G (Ref. 2). Although the P/T limits were developed to provide guidance for operation during heatup or cooldown (MODES 3, 4, and 5) or ISLH testing, their Applicability is at all times in keeping with the concern for nonductile failure. The limits do not apply to the pressurizer.

During MODES 1 and 2, other Technical Specifications provide limits for operation that can be more restrictive than or can supplement these P/T limits. LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits"; LCO 3.4.2, "RCS Minimum Temperature for Criticality"; and Safety Limit 2.1, "Safety Limits," also provide operational restrictions for pressure and temperature and maximum pressure. Furthermore, MODES 1 and 2 are above the temperature range of concern for nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent.

ACTIONS A.1 and A.2 Operation outside the P/T limits during MODE 1, 2, 3, or 4 must be corrected so that the RCPB is returned to a condition that has been verified by stress analyses.

The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner.

Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection of the components.

ASME Code,Section XI, Appendix E (Ref. 7), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.

(continued)

Watts Bar - Unit 2 B 3.4-13 (developmental) A

RCS P/T Limits B 3.4.3 BASES ACTIONS A.1 and A.2 (continued)

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable to accomplish the evaluation.

The evaluation for a mild violation is possible within this time, but more severe violations may require special, event specific stress analyses or inspections. A favorable evaluation must be completed before continuing to operate.

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

B.1 and B.2 If a Required Action and associated Completion Time of Condition A are not met, the plant must be placed in a lower MODE because either the RCS remained in an unacceptable P/T region for an extended period of increased stress or a sufficiently severe event caused entry into an unacceptable region. Either possibility indicates a need for more careful examination of the event, best accomplished with the RCS at reduced pressure and temperature. In reduced pressure and temperature conditions, the possibility of propagation with undetected flaws is decreased.

If the required restoration activity cannot be accomplished within 30 minutes, Required Action B.1 and Required Action B.2 must be implemented to reduce pressure and temperature.

If the required evaluation for continued operation cannot be accomplished within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the results are indeterminate or unfavorable, action must proceed to reduce pressure and temperature as specified in Required Action B.1 and Required Action B.2. A favorable evaluation must be completed and documented before returning to operating pressure and temperature conditions.

Pressure and temperature are reduced by bringing the plant to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 with RCS pressure < 500 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued)

Watts Bar - Unit 2 B 3.4-14 (developmental) A

RCS P/T Limits B 3.4.3 BASES ACTIONS B.1 and B.2 (continued)

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.

C.1 and C.2 Actions must be initiated immediately to correct operation outside of the P/T limits at times other than when in MODE 1, 2, 3, or 4, so that the RCPB is returned to a condition that has been verified by stress analysis.

The immediate Completion Time reflects the urgency of initiating action to restore the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner.

Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify that the RCPB integrity remains acceptable and must be completed prior to entry into MODE 4. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, or inspection of the components.

ASME Code,Section XI, Appendix E (Ref. 7), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.

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

(continued)

Watts Bar - Unit 2 B 3.4-15 (developmental) A

RCS P/T Limits B 3.4.3 BASES (continued)

SURVEILLANCE SR 3.4.3.1 REQUIREMENTS Verification that operation is within the PTLR limits is required every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. This Frequency is considered reasonable in view of the control room indication available to monitor RCS status.

Also, since temperature rate of change limits are specified in hourly increments, 30 minutes permit assessment and correction for minor deviations within a reasonable time.

Surveillance for heatup, cooldown, or ISLH testing may be discontinued when the definition given in the relevant plant procedure for ending the activity is satisfied.

This SR is modified by a Note that only requires this SR to be performed during system heatup, cooldown, and ISLH testing. No SR is given for criticality operations because LCO 3.4.2 contains a more restrictive requirement.

REFERENCES 1. Appendix "B" to RCS System Description N3-68-4001, "Watts Bar Unit 2 RCS Pressure and Temperature Limits Report."

2. Title 10, Code of Federal Regulations, Part 50, Appendix G, "Fracture Toughness Requirements."

3. ASME Boiler and Pressure Vessel Code,Section XI, Appendix G, "Fracture Toughness Criteria for Protection Against Failure."

4. ASTM E 185-82, "Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels,"

July 1982.

5. Title 10, Code of Federal Regulations, Part 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements."

6. Regulatory Guide 1.99, Revision 2, "Radiation Embrittlement of Reactor Vessel Materials," May 1988.

Watts Bar - Unit 2 B 3.4-16 (developmental) B

RCS P/T Limits B 3.4.3 BASES (continued)

REFERENCES 7. ASME Boiler and Pressure Vessel Code,Section XI, Appendix E, (continued) "Evaluation of Unanticipated Operating Events."

8. WCAP-14040-A, Revision 4, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, May 2004.

Watts Bar - Unit 2 B 3.4-17 (developmental) B

RCS Loops - MODES 1 and 2 B 3.4.4 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.4 RCS Loops - MODES 1 and 2 BASES BACKGROUND The primary function of the RCS is removal of the heat generated in the fuel due to the fission process, and transfer of this heat, via the steam generators (SGs), to the secondary plant.

The secondary functions of the RCS include:

a. Moderating the neutron energy level to the thermal state, to increase the probability of fission;

b. Improving the neutron economy by acting as a reflector;

c. Carrying the soluble neutron poison, boric acid;

d. Providing a second barrier against fission product release to the environment; and

e. Removing the heat generated in the fuel due to fission product decay following a unit shutdown.

The reactor coolant is circulated through four loops connected in parallel to the reactor vessel, each containing an SG, a reactor coolant pump (RCP), and appropriate flow and temperature instrumentation for both control and protection. The reactor vessel contains the clad fuel. The SGs provide the heat sink to the isolated secondary coolant. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and prevent fuel damage. This forced circulation of the reactor coolant ensures mixing of the coolant for proper boration and chemistry control.

APPLICABLE Safety analyses contain various assumptions for the design bases SAFETY accident initial conditions including RCS pressure, RCS temperature, ANALYSES reactor power level, core parameters, and safety system setpoints. The important aspect for this LCO is the reactor coolant forced flow rate, which is represented by the number of RCS loops in service.

(continued)

Watts Bar - Unit 2 B 3.4-18 (developmental) A

RCS Loops - MODES 1 and 2 B 3.4.4 BASES APPLICABLE Both transient and steady state analyses have been performed to SAFETY establish the effect of flow on the departure from nucleate boiling (DNB).

ANALYSES The transient and accident analyses for the plant have been performed (continued) assuming four RCS loops are in operation. The majority of the plant safety analyses are based on initial conditions at high core power or zero power. The accident analyses that are most important to RCP operation are the four pump coastdown, single pump locked rotor, single pump (broken shaft or coastdown), and rod withdrawal events (Ref. 1).

Steady state DNB analysis has been performed for the four RCS loop operation. For four RCS loop operation, the steady state DNB analysis, which generates the pressure and temperature Safety Limit (SL) (i.e., the departure from nucleate boiling ratio (DNBR) limit) assumes a maximum power level of 118% RTP. This is the design overpower condition for four RCS loop operation. The value for the accident analysis setpoint of the nuclear overpower (high flux) trip is 118% and is based on an analysis assumption that bounds possible instrumentation errors. The DNBR limit defines a locus of pressure and temperature points that result in a minimum DNBR greater than or equal to the critical heat flux correlation limit.

The plant is designed to operate with all RCS loops in operation to maintain DNBR above the SL, during all normal operations and anticipated transients. By ensuring heat transfer in the nucleate boiling region, adequate heat transfer is provided between the fuel cladding and the reactor coolant.

RCS Loops - MODES 1 and 2 satisfy Criterion 2 of the NRC Policy Statement.

LCO The purpose of this LCO is to require an adequate forced flow rate for core heat removal. Flow is represented by the number of RCPs in operation for removal of heat by the SGs. To meet safety analysis acceptance criteria for DNB, four pumps are required at rated power.

An OPERABLE RCS loop consists of an OPERABLE RCP in operation providing forced flow for heat transport and an OPERABLE SG.

(continued)

Watts Bar - Unit 2 B 3.4-19 (developmental) A

RCS Loops - MODES 1 and 2 B 3.4.4 BASES (continued)

APPLICABILITY In MODES 1 and 2, the reactor is critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure that the assumptions of the accident analyses remain valid, all RCS loops are required to be OPERABLE and in operation in these MODES to prevent DNB and core damage.

The decay heat production rate is much lower than the full power heat rate. As such, the forced circulation flow and heat sink requirements are reduced for lower, noncritical MODES as indicated by the LCOs for MODES 3, 4, and 5.

Operation in other MODES is covered by:

LCO 3.4.5, "RCS Loops - MODE 3";

LCO 3.4.6, "RCS Loops - MODE 4";

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

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

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

Low Water Level" (MODE 6).

ACTIONS A.1 If the requirements of the LCO are not met, the Required Action is to reduce power and bring the plant to MODE 3. This lowers power level and thus reduces the core heat removal needs and minimizes the possibility of violating DNB limits.

The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems.

(continued)

Watts Bar - Unit 2 B 3.4-20 (developmental) A

RCS Loops - MODES 1 and 2 B 3.4.4 BASES (continued)

SURVEILLANCE SR 3.4.4.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that each RCS loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal while maintaining the margin to DNB. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop performance.

REFERENCES 1. Watts Bar FSAR, Section 15.0, "Accident Analysis."

Watts Bar - Unit 2 B 3.4-21 (developmental) A

RCS Loops - MODE 3 B 3.4.5 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 RCS Loops - MODE 3 BASES BACKGROUND In MODE 3, the primary function of the reactor coolant is removal of decay heat and transfer of this heat, via the steam generators (SGs), to the secondary plant fluid. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

The reactor coolant is circulated through four RCS loops, connected in parallel to the reactor vessel, each containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The reactor vessel contains the clad fuel. The SGs provide the heat sink. The RCPs circulate the water through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and prevent fuel damage.

In MODE 3, RCPs are used to provide forced circulation for heat removal during heatup and cooldown. The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP running is sufficient to remove core decay heat. However, two RCS loops are required to be OPERABLE to ensure redundant capability for decay heat removal.

APPLICABLE Whenever the reactor trip breakers (RTBs) are in the closed position and SAFETY the control rod drive mechanisms (CRDMs) are energized, an inadvertent ANALYSES rod withdrawal from subcritical, resulting in a power excursion, is possible. Such a transient could be caused by a malfunction of the rod control system. In addition, the possibility of a power excursion due to the ejection of an inserted control rod is possible with the breakers closed or open. Such a transient could be caused by the mechanical failure of a CRDM.

(continued)

Watts Bar - Unit 2 B 3.4-22 (developmental) A

RCS Loops - MODE 3 B 3.4.5 BASES APPLICABLE Therefore, in MODE 3 with RTBs in the closed position and Rod Control SAFETY System capable of rod withdrawal, accidental control rod withdrawal from ANALYSES subcritical is postulated and requires at least two RCS loops to be (continued) OPERABLE and in operation to ensure that the accident analyses limits are met. For those conditions when the Rod Control System is not capable of rod withdrawal, two RCS loops are required to be OPERABLE, but only one RCS loop is required to be in operation to be consistent with MODE 3 accident analyses.

Failure to provide decay heat removal may result in challenges to a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.

RCS Loops - MODE 3 satisfy Criterion 3 of the NRC Policy Statement.

LCO The purpose of this LCO is to require that at least two RCS loops be OPERABLE. In MODE 3 with the RTBs in the closed position and Rod Control System capable of rod withdrawal, two RCS loops must be in operation. Two RCS loops are required to be in operation in MODE 3 with RTBs closed and Rod Control System capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the Safety Limit criteria will be met for all of the postulated accidents.

With the RTBs in the open position, or the CRDMs de-energized, the Rod Control System is not capable of rod withdrawal; therefore, only one RCS loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. An additional RCS loop is required to be OPERABLE to ensure adequate decay heat removal capability.

The Note permits all RCPs to be de-energized for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to perform tests that are designed to validate various accident analyses values. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once.

(continued)

Watts Bar - Unit 2 B 3.4-23 (developmental) A

RCS Loops - MODE 3 B 3.4.5 BASES LCO If, however, changes are made to the RCS that would cause a change to (continued) the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period specified is adequate to perform the desired tests, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of the Note is permitted provided the following conditions are met, along with any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration, thereby maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

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

An OPERABLE RCS loop consists of one OPERABLE RCP and one OPERABLE SG, which has the minimum water level specified in SR 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required.

(continued)

Watts Bar - Unit 2 B 3.4-24 (developmental) A

RCS Loops - MODE 3 B 3.4.5 BASES (continued)

APPLICABILITY In MODE 3, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

The most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with RTBs in the closed position. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the RTBs open.

Operation in other MODES is covered by:

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

LCO 3.4.6, "RCS Loops - MODE 4";

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

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

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

Low Water Level" (MODE 6).

ACTIONS A.1 If one required RCS loop is inoperable, redundancy for heat removal is lost. The Required Action is restoration of the required RCS loop to OPERABLE status within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This time allowance is a justified period to be without the redundant, non-operating loop because a single loop in operation has a heat transfer capability greater than that needed to remove the decay heat produced in the reactor core and because of the low probability of a failure in the remaining loop occurring during this period.

B.1 If restoration is not possible within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the unit must be brought to MODE 4. In MODE 4, the unit may be placed on the Residual Heat Removal System. The additional Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is compatible with required operations to achieve cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging plant systems.

(continued)

Watts Bar - Unit 2 B 3.4-25 (developmental) A

RCS Loops - MODE 3 B 3.4.5 BASES ACTIONS C.1 and C.2 (continued)

If the required RCS loop is not in operation, and the RTBs are closed and Rod Control System capable of rod withdrawal, the Required Action is either to restore the required RCS loop to operation or to de-energize all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets. When the RTBs are in the closed position and Rod Control System capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal. This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the RTBs must be opened.

The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the required RCS loop to operation or de-energize all CRDMs is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period.

D.1, D.2, and D.3 If all RCS loops are inoperable or no RCS loop is in operation, except as during conditions permitted by the Note in the LCO section, all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets. All operations involving a reduction of RCS boron concentration must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod withdrawal. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

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

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

(continued)

Watts Bar - Unit 2 B 3.4-26 (developmental) A

RCS Loops - MODE 3 B 3.4.5 BASES SURVEILLANCE SR 3.4.5.2 REQUIREMENTS (continued) SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 6 % (value does not account for instrument error) for required RCS loops. If the SG secondary side narrow range water level is less than 6 %, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink for removal of the decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.

SR 3.4.5.3 Verification that the required RCPs are OPERABLE ensures that safety analyses limits are met. The requirement also ensures that an additional RCP can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power availability to the required RCPs.

REFERENCES None Watts Bar - Unit 2 B 3.4-27 (developmental) B

RCS Loops - MODE 4 B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Loops - MODE 4 BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

The reactor coolant is circulated through four RCS loops connected in parallel to the reactor vessel, each loop containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and to prevent boric acid stratification.

In MODE 4, with the reactor trip breakers open and the rods not capable of withdrawal, either RCPs or RHR loops can be used to provide forced circulation. The intent in this case is to provide forced flow from at least one RCP or one RHR loop for decay heat removal and transport. The flow provided by one RCP loop or RHR loop is adequate for decay heat removal. The other intent is to require that two paths be available to provide redundancy for decay heat removal.

In MODE 4, with the reactor trip breakers closed and the rods capable of withdrawal, two RCPs must be OPERABLE and in operation to provide forced circulation.

APPLICABLE In MODE 4, with the reactor trip breakers open and the rods not capable SAFETY of withdrawal, RCS circulation is considered in determination of the time ANALYSES available for mitigation of the accidental boron dilution event. The RCS and RHR loops provide this circulation.

(continued)

Watts Bar - Unit 2 B 3.4-28 (developmental) A

RCS Loops - MODE 4 B 3.4.6 BASES APPLICABLE Whenever the reactor trip breakers (RTBs) are in the closed position and SAFETY the control rod drive mechanisms (CRDMs) are energized, an inadvertent ANALYSES rod withdrawal from subcritical, resulting in a power excursion, is (continued) possible. Such a transient could be caused by a malfunction of the rod control system. In addition, the possibility of a power excursion due to the ejection of an inserted control rod is possible with the breakers closed or open. Such a transient could be caused by the mechanical failure of a CRDM.

Therefore, in MODE 4 with RTBs in the closed position and Rod Control System capable of rod withdrawal, accidental control rod withdrawal from subcritical is postulated and requires at least two RCS loops to be OPERABLE and in operation to ensure that the accident analyses limits are met. For those conditions when the Rod Control System is not capable of rod withdrawal, any combination of two RCS or RHR loops are required to be OPERABLE, but only one loop is required to be in operation to meet decay heat removal requirements.

RCS Loops - MODE 4 have been identified in the NRC Policy Statement as important contributors to risk reduction.

LCO The purpose of this LCO is to require that at least two loops be OPERABLE. In MODE 4 with the RTBs in the closed position and Rod Control System capable of rod withdrawal, two RCS loops must be OPERABLE and in operation. Two RCS loops are required to be in operation in MODE 4 with RTBs closed and Rod Control System capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the Safety Limit criteria will be met for all of the postulated accidents.

With the RTBs in the open position, or the CRDMs de-energized, the Rod Control System is not capable of rod withdrawal; therefore, only one loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. In this case, the LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

(continued)

Watts Bar - Unit 2 B 3.4-29 (developmental) A

RCS Loops - MODE 4 B 3.4.6 BASES LCO The Note requires that the secondary side water temperature of each SG (continued) be 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature the COMS arming temperature as specified in the PTLR. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.3.

Similarly for the RHR System, an OPERABLE RHR loop comprises an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE if they are capable of being powered and are able to provide forced flow if required.

APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

One loop of either RCS or RHR provides sufficient circulation for these purposes. However, two loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to meet single failure considerations.

Operation in other MODES is covered by:

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

LCO 3.4.5, "RCS Loops - MODE 3";

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

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

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

Low Water Level" (MODE 6).

(continued)

Watts Bar - Unit 2 B 3.4-30 (developmental) B

RCS Loops - MODE 4 B 3.4.6 BASES (continued)

ACTIONS A.1 If only one RCS loop is OPERABLE and both RHR loops are inoperable, redundancy for heat removal is lost. Action must be initiated to restore a second RCS or RHR loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 If one required RHR loop is OPERABLE and in operation and there are no RCS loops OPERABLE, an inoperable RCS or RHR loop must be restored to OPERABLE status to provide a redundant means for decay heat removal.

If the parameters that are outside the limits cannot be restored, the plant must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the plant to MODE 5 is a conservative action with regard to decay heat removal. With only one RHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 ( 200°F) rather than MODE 4 (200 to 350°F). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

C.1 and C.2 If one required RCS loop is not in operation, and the RTBs are closed and Rod Control System capable of rod withdrawal, the Required Action is either to restore the required RCS loop to operation or to de-energize all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets. When the RTBs are in the closed position and Rod Control System capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal. This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the RTBs must be opened.

The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the required RCS loop to operation or de-energize all CRDMs is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period.

(continued)

Watts Bar - Unit 2 B 3.4-31 (developmental) A

RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS D.1, D.2 and D.3 (continued)

If no loop is OPERABLE or in operation, all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets. All operations involving a reduction of RCS boron concentration must be suspended, and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and the margin to criticality must not be reduced in this type of operation. Opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod withdrawal. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that two RCS loops are in operation when the rod control system is capable of rod withdrawal.

Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

SR 3.4.6.2 This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one RCS or RHR loop is in operation when the rod control system is not capable of rod withdrawal.

Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

(continued)

Watts Bar - Unit 2 B 3.4-32 (developmental) A

RCS Loops - MODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.3 REQUIREMENTS (continued) SR 3.4.6.3 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 6% (value does not account for instrument error). If the SG secondary side narrow range water level is < 6%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The 12-hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

SR 3.4.6.4 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

REFERENCES None Watts Bar - Unit 2 B 3.4-33 (developmental) B

RCS Loops - MODE 5, Loops Filled B 3.4.7 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.7 RCS Loops - MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers.

While the principal means for decay heat removal is via the RHR System, the SGs are specified as a backup means for redundancy. Even though the SGs cannot produce steam in this MODE, they are capable of being a heat sink due to their large contained volume of secondary water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

In MODE 5 with RCS loops filled, the reactor coolant is circulated by means of two RHR loops connected to the RCS, each loop containing an RHR heat exchanger, an RHR pump, and appropriate flow and temperature instrumentation for control, protection, and indication.

One RHR pump circulates the water through the RCS at a sufficient rate to prevent boric acid stratification.

The number of loops in operation can vary to suit the operational needs.

The intent of this LCO is to provide forced flow from at least one RHR loop for decay heat removal and transport. The flow provided by one RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that a second path be available to provide redundancy for heat removal.

The LCO provides for redundant paths of decay heat removal capability.

The first path can be an RHR loop that must be OPERABLE and in operation. The second path can be another OPERABLE RHR loop or maintaining two SGs with secondary side water levels greater than or equal to 6% narrow range to provide an alternate method for decay heat removal.

(continued)

Watts Bar - Unit 2 B 3.4-34 (developmental) A

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES (continued)

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The RHR ANALYSES loops provide this circulation.

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

LCO The purpose of this LCO is to require that at least one of the RHR loops be OPERABLE and in operation with an additional RHR loop OPERABLE or two SGs with secondary side water level greater than or equal to 6% narrow range. One RHR loop provides sufficient forced circulation to perform the safety functions of the reactor coolant under these conditions.

An additional RHR loop is required to be OPERABLE to meet single failure considerations. However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is two SGs with their secondary side water levels greater than or equal to 6% narrow range.

Should the operating RHR loop fail, the SGs could be used to remove the decay heat.

Note 1 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

Note 2 requires that the secondary side water temperature of each SG be 50°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature the COMS arming temperature specified in the PTLR. This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 3 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An SG can perform as a heat sink when it has an adequate water level and is OPERABLE.

(continued)

Watts Bar - Unit 2 B 3.4-35 (developmental) B

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES (continued)

APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side water level of at least two SGs is required to be 6% narrow range.

Operation in other MODES is covered by:

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

LCO 3.4.5, "RCS Loops - MODE 3";

LCO 3.4.6, "RCS Loops - MODE 4";

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

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

Low Water Level" (MODE 6).

ACTIONS A.1 and A.2 If one RHR loop is inoperable and the required SGs have secondary side water levels < 6% narrow range, redundancy for heat removal is lost.

Action must be initiated immediately to restore a second RHR loop to OPERABLE status or to restore the required SG secondary side water levels. Either Required Action A.1 or Required Action A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no RHR loop is in operation, except during conditions permitted by Note 1, or if no loop is OPERABLE, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. To prevent boron dilution, forced circulation is required to provide proper mixing and preserve the margin to criticality in this type of operation. The immediate Completion Times reflect the importance of maintaining operation for heat removal.

(continued)

Watts Bar - Unit 2 B 3.4-36 (developmental) A

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES (continued)

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

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

SR 3.4.7.2 Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are greater than or equal to 6%

(value does not account for instrument error) narrow range ensures an alternate decay heat removal method in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12-hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

SR 3.4.7.3 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the RHR pump.

If secondary side water level is greater than or equal to 6% narrow range in at least two SGs, this Surveillance is not needed. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

REFERENCES None Watts Bar - Unit 2 B 3.4-37 (developmental) B

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.8 RCS Loops - MODE 5, Loops Not Filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated in the fuel, and the transfer of this heat to the component cooling water via the residual heat removal (RHR) heat exchangers. The steam generators (SGs) are not available as a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.

In MODE 5 with loops not filled, only RHR pumps can be used for coolant circulation. The number of pumps in operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least one RHR pump for decay heat removal and transport and to require that two paths be available to provide redundancy for heat removal.

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The RHR ANALYSES loops provide this circulation. The flow provided by one RHR loop is adequate for heat removal and for boron mixing.

RCS loops in MODE 5 (loops not filled) have been identified in the NRC Policy Statement as important contributors to risk reduction.

LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation. An OPERABLE loop is one that has the capability of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used. A minimum of one running RHR pump meets the LCO requirement for one loop in operation. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

(continued)

Watts Bar - Unit 2 B 3.4-38 (developmental) A

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES LCO Note 1 permits all RHR pumps to be de-energized for 15 minutes when (continued) switching from one loop to another. The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short and core outlet temperature is maintained > 10°F below saturation temperature. The Note prohibits boron dilution or draining operations when RHR forced flow is stopped.

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

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

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

LCO 3.4.5, "RCS Loops - MODE 3;"

LCO 3.4.6, "RCS Loops - MODE 4;"

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

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

(continued)

Watts Bar - Unit 2 B 3.4-39 (developmental) A

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES (continued)

ACTIONS A.1 If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no required RHR loops are OPERABLE or in operation, except during conditions permitted by Note 1, all operations involving a reduction of RCS boron concentration must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation.

Boron dilution requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one loop is in operation.

Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

REFERENCES None.

Watts Bar - Unit 2 B 3.4-40 (developmental) A

Pressurizer B 3.4.9 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.9 Pressurizer BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady state operation, and limiting the pressure changes caused by reactor coolant thermal expansion and contraction during normal load transients.

The pressure control components addressed by this LCO include the pressurizer water level, the required heaters, and their controls.

Pressurizer safety valves and pressurizer power operated relief valves are addressed by LCO 3.4.10, "Pressurizer Safety Valves," and LCO 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs),"

respectively.

The intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients. The presence of a steam bubble is consistent with analytical assumptions. Relatively small amounts of noncondensible gases can inhibit the condensation heat transfer between the pressurizer spray and the steam, and diminish the spray effectiveness for pressure control.

Electrical immersion heaters, located in the lower section of the pressurizer vessel, keep the water in the pressurizer at saturation temperature and maintain a constant operating pressure. A minimum required available capacity of pressurizer heaters ensures that the RCS pressure can be maintained. The capability to maintain and control system pressure is important for maintaining subcooled conditions in the RCS and ensuring the capability to remove core decay heat by either forced or natural circulation of reactor coolant. Unless adequate heater capacity is available, the hot, high pressure condition cannot be maintained indefinitely and still provide the required subcooling margin in the primary system. Inability to control the system pressure and maintain subcooling under conditions of natural circulation flow in the primary system could lead to a loss of single phase natural circulation and decreased capability to remove core decay heat.

(continued)

Watts Bar - Unit 2 B 3.4-41 (developmental) A

Pressurizer B 3.4.9 BASES (continued)

APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble is SAFETY reflected implicitly in the accident analyses. Safety analyses performed ANALYSES for lower MODES are not limiting. All analyses performed from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensible gases normally present.

Safety analyses presented in the FSAR (Ref. 1) do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure.

The maximum pressurizer water level limit satisfies Criterion 2 of the NRC Policy Statement. Although the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long term during loss of offsite power, as indicated in NUREG-0737 (Ref. 2), is the reason for providing an LCO.

LCO The LCO requirement for the pressurizer to be OPERABLE with a water volume 1656 cubic feet, which is equivalent to 92%, ensures that a steam bubble exists. Limiting the LCO maximum operating water level preserves the steam space for pressure control. The LCO has been established to ensure the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions.

The LCO requires two groups of OPERABLE pressurizer heaters, each with a capacity 150 kW. The minimum heater capacity required is sufficient to maintain the RCS near normal operating pressure when accounting for heat losses through the pressurizer insulation. By maintaining the pressure near the operating conditions, a wide margin to subcooling can be obtained in the loops. The design value of 150 kW per group is exceeded by the use of fifteen heaters in a group rated at 23.1 kW each. The amount needed to maintain pressure is dependent on the heat losses.

(continued)

Watts Bar - Unit 2 B 3.4-42 (developmental) A

Pressurizer B 3.4.9.

BASES (continued)

APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup.

In MODES 1, 2, and 3, there is need to maintain the availability of pressurizer heaters. In the event of a loss of offsite power, the initial conditions of these MODES give the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Residual Heat Removal (RHR) System is in service, and therefore, the LCO is not applicable.

ACTIONS A.1 and A.2 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions. Normally the plant will trip in this event since the upper limit of this LCO is the same as the Pressurizer Water Level - High Trip.

If the pressurizer water level is not within the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses. To achieve this status, the plant must be brought to MODE 3, with the reactor trip breakers open, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This takes the plant out of the applicable MODES and restores the plant to operation within the bounds of the safety analyses.

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.

(continued)

Watts Bar - Unit 2 B 3.4-43 (developmental) A

Pressurizer B 3.4.9.

BASES ACTIONS B.1 (continued)

If one required group of pressurizer heaters is inoperable, restoration is required within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable considering the anticipation that a demand caused by loss of offsite power would be unlikely in this period.

C.1 and C.2 If one group of pressurizer heaters is inoperable and cannot be restored in the allowed Completion Time of Required Action B.1, 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 MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This SR requires that during steady state operation, pressurizer level is maintained below the nominal upper level limit of 92% (value does not account for instrument error) to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months corresponds to verifying the parameter each shift. The 12-hour interval has been shown by operating practice to be sufficient to regularly assess level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications.

SR 3.4.9.2 The SR is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating. This may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance. The Frequency of 92 days is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.

(continued)

Watts Bar - Unit 2 B 3.4-44 (developmental) B

Pressurizer B 3.4.9.

BASES (continued)

REFERENCES 1. Watts Bar FSAR, Section 15.0, "Accident Analyses."

2. NUREG-0737, "Clarification of TMI Action Plan Requirements,"

November 1980.

Watts Bar - Unit 2 B 3.4-45 (developmental) B

Pressurizer Safety Valves B 3.4.10 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.10 Pressurizer Safety Valves BASES BACKGROUND The pressurizer safety valves provide, in conjunction with the Reactor Protection System, overpressure protection for the RCS. The pressurizer safety valves are totally enclosed pop type, spring loaded, self actuated valves with backpressure compensation. The safety valves are designed to prevent the system pressure from exceeding the system Safety Limit (SL), 2735 psig, which is 110% of the design pressure.

Because the safety valves are totally enclosed and self actuating, they are considered independent components. The relief capacity for each valve, 420,000 lb/hr, is based on postulated overpressure transient conditions resulting from a complete loss of steam flow to the turbine.

This event results in the maximum surge rate into the pressurizer, which specifies the minimum relief capacity for the safety valves. The discharge flow from the pressurizer safety valves is directed to the pressurizer relief tank. This discharge flow is indicated by an increase in temperature downstream of the pressurizer safety valves or increase in the pressurizer relief tank temperature or level.

Overpressure protection is required in MODES 1, 2, 3, 4, and 5; however, in MODE 4 with any RCS cold leg temperature < the COMS arming temperature specified in the PTLR, MODE 5, and MODE 6 with the reactor vessel head on, overpressure protection is provided by operating procedures and by meeting the requirements of LCO 3.4.12, "Cold Overpressure Mitigation System (COMS)."

The upper and lower pressure limits are based on a +/- 3% tolerance. The lift setting is for the ambient conditions associated with MODES 1, 2, 3, and MODE 4 with all RCS cold leg temperatures > the COMS arming temperature specified in the PTLR. This requires either that the valves be set hot or that a correlation between hot and cold settings be established.

The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure.

(continued)

Watts Bar - Unit 2 B 3.4-46 (developmental) B

Pressurizer Safety Valves B 3.4.10 BASES BACKGROUND The consequences of exceeding the American Society of Mechanical (continued) Engineers (ASME) pressure limit (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation.

APPLICABLE All accident and safety analyses in the FSAR (Ref. 2) that require safety SAFETY valve actuation assume operation of three pressurizer safety valves to ANALYSES limit increases in RCS pressure. The overpressure protection analysis (Ref. 3) is also based on operation of three safety valves. Accidents that could result in overpressurization if not properly terminated include:

a. Uncontrolled rod withdrawal from full power;

b. Loss of reactor coolant flow;

c. Loss of external electrical load;

d. Loss of normal feedwater;

e. Loss of all AC power to station auxiliaries;

f. Locked rotor; and

g. Feedwater line break.

Detailed analyses of the above transients are contained in Reference 2.

Safety valve actuation is required in events c, d, e, f, and g (above) to limit the pressure increase. Compliance with this LCO is consistent with the design bases and accident analyses assumptions.

Pressurizer safety valves satisfy Criterion 3 of the NRC Policy Statement.

(continued)

Watts Bar - Unit 2 B 3.4-47 (developmental) A

Pressurizer Safety Valves B 3.4.10 BASES (continued)

LCO The three pressurizer safety valves are set to open at the RCS design pressure (2485 psig), and within the specified tolerance, to avoid exceeding the maximum design pressure SL, to maintain accident analyses assumptions, and to comply with ASME requirements. The upper and lower pressure tolerance limits are based on a +/- 3% tolerance.

The limit protected by this Specification is the reactor coolant pressure boundary (RCPB) SL of 110% of design pressure. Inoperability of one or more valves could result in exceeding the SL if a transient were to occur.

The consequences of exceeding the ASME pressure limit could include damage to one or more RCS components, increased leakage, or additional stress analysis being required prior to resumption of reactor operation.

APPLICABILITY In MODES 1, 2, 3, and MODE 4 with all RCS cold leg temperatures > the COMS arming temperature specified in the PTLR, OPERABILITY of three valves is required because the combined capacity is required to keep reactor coolant pressure below 110% of its design value during certain accidents. MODE 3 is conservatively included, although the listed accidents may not require the safety valves for protection.

The LCO is not applicable in MODE 4 when all RCS cold leg temperatures are the COMS arming temperature as specified in the PTLR, in MODE 5, or in MODE 6 (with the reactor vessel head on) because COMS is provided. Overpressure protection is not required in MODE 6 with reactor vessel head detensioned.

The Note allows entry into MODE 3 and MODE 4 with all RCS cold leg temperatures > the COMS arming temperature specified in the PTLR, with the lift settings outside the LCO limits. This permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. The cold setting gives assurance that the valves are OPERABLE near their design condition. Only one valve at a time will be removed from service for testing. The 54-hour exception is based on 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months outage time for each of the three valves. The 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months period is derived from operating experience that hot testing can be performed in this timeframe.

(continued)

Watts Bar - Unit 2 B 3.4-48 (developmental) B

Pressurizer Safety Valves B 3.4.10 BASES (continued)

ACTIONS A.1 With one pressurizer safety valve inoperable, restoration must take place within 15 minutes. The Completion Time of 15 minutes reflects the importance of maintaining the RCS Overpressure Protection System. An inoperable safety valve coincident with an RCS overpressure event could challenge the integrity of the pressure boundary.

B.1 and B.2 If the Required Action of A.1 cannot be met within the required Completion Time or if two or more pressurizer safety valves are inoperable, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with any RCS cold leg temperature < the COMS arming temperature specified in the PTLR within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. With any RCS cold leg temperatures at or below the COMS arming temperature as specified in the PTLR, overpressure protection is provided by the COMS System. The change from MODE 1, 2, or 3 to MODE 4 with any RCS cold leg temperature < the COMS arming temperature specified in the PTLRreduces the RCS energy (core power and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by three pressurizer safety valves.

SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested in accordance with the requirements of the ASME OM Code (Ref. 4), which provides the activities and Frequencies necessary to satisfy the SRs. No additional requirements are specified.

The pressurizer safety valve setpoint is +/- 3% for OPERABILITY, however, the valves are reset to +/- 1% during the surveillance to allow for drift.

(continued)

Watts Bar - Unit 2 B 3.4-49 (developmental) B

Pressurizer Safety Valves B 3.4.10 BASES (continued)

REFERENCES 1. ASME Boiler and Pressure Vessel Code,Section III, NB 7000, 1971 Edition through Summer 1973.

2. Watts Bar FSAR, Section 15.0, "Accident Analyses."

3. WCAP-7769, Rev. 1, "Topical Report on Overpressure Protection for Westinghouse Pressurized Water Reactors," June 1972.

4. American Society of Mechanical Engineers (ASME) OM Code, Code for Operation and Maintenance of Nuclear Power Plants."

Watts Bar - Unit 2 B 3.4-50 (developmental) B

Pressurizer PORVs B 3.4.11 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

BASES BACKGROUND The pressurizer is equipped with two types of devices for pressure relief:

pressurizer safety valves and PORVs. The PORVs are pilot-operated solenoid valves that are controlled to open at a specific set pressure when the pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually operated from the control room.

Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room. A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss.

The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of surveillances on the valves during power operation.

The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater.

The PORVs, their block valves, and their controls are powered from the vital buses that normally receive power from offsite power sources, but are also capable of being powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block valves are powered from two separate safety trains (Ref. 1).

(continued)

Watts Bar - Unit 2 B 3.4-51 (developmental) A

Pressurizer PORVs B 3.4.11 BASES BACKGROUND The plant has two PORVs, each having a relief capacity of 210,000 lb/hr (continued) at 2485 psig. The functional design of the PORVs is based on maintaining pressure below the Pressurizer Pressure - High reactor trip setpoint following a step reduction of 50% of full load with steam dump.

In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (LTOP). See LCO 3.4.12, "Cold Overpressure Mitigation System (COMS)."

APPLICABLE Plant operators employ the PORVs to depressurize the RCS in response SAFETY to certain plant transients if normal pressurizer spray is not available. For ANALYSES the Steam Generator Tube Rupture (SGTR) event, the safety analysis assumes that manual operator actions are required to mitigate the event.

A loss of offsite power is assumed to accompany the event, and thus, normal pressurizer spray is unavailable to reduce RCS pressure. The PORVs are assumed to be used for RCS depressurization, which is one of the steps performed to equalize the primary and secondary pressures in order to terminate the primary to secondary break flow and the radioactive releases from the affected steam generator.

The PORVs are modeled in safety analyses for events that result in increasing RCS pressure for which departure from nucleate boiling ratio (DNBR), pressurizer filling, or reactor coolant saturation criteria are critical (Ref. 2). By assuming PORV actuation, the primary pressure remains below the high pressurizer pressure trip setpoint; thus, the DNBR calculation is more conservative. As such, this actuation is not required to mitigate these events, and PORV automatic operation is, therefore, not an assumed safety function.

Pressurizer PORVs satisfy Criterion 3 of the NRC Policy Statement.

(continued)

Watts Bar - Unit 2 B 3.4-52 (developmental) A

Pressurizer PORVs B 3.4.11 BASES (continued)

LCO The LCO requires the PORVs and their associated block valves to be OPERABLE for manual operation to mitigate the effects associated with an SGTR.

By maintaining two PORVs and their associated block valves OPERABLE, the single failure criterion is satisfied. An OPERABLE block valve may be either open and energized with the capability to be closed, or closed and energized with the capability to be opened, since the required safety function is accomplished by manual operation, the block valves may be OPERABLE when closed to isolate the flow path of an inoperable PORV that is capable of being manually cycled (e.g., as in the case of excessive PORV leakage). Similarly, isolation of an OPERABLE PORV does not render that PORV or block valve inoperable provided the relief function remains available with manual action.

An OPERABLE PORV is required to be capable of manually opening and closing and not experiencing excessive seat leakage. Excessive seat leakage although not associated with a specific acceptance criteria, exists when conditions dictate closure of block valve to limit leakage.

Satisfying the LCO helps minimize challenges to fission product barriers.

APPLICABILITY In MODES 1, 2, and 3, the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. The most likely cause for a PORV small break LOCA is a result of a pressure increase transient that causes the PORV to open. Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORV opening setpoint. The most rapid increases will occur at the higher operating power and pressure conditions of MODES 1 and 2. The PORVs are also required to be OPERABLE in MODES 1, 2, and 3 for manual actuation to mitigate a steam generator tube rupture event.

Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not applicable in MODE 4, 5, and 6 with the reactor vessel head in place when both pressure and core energy are decreased and the pressure surges become much less significant. LCO 3.4.12 addresses the PORV requirements in these MODES.

(continued)

Watts Bar - Unit 2 B 3.4-53 (developmental) A

Pressurizer PORVs B 3.4.11 BASES (continued)

ACTIONS A Note has been added to clarify that all pressurizer PORVs are treated as separate entities, each with separate Completion Times (i.e., the Completion Time is on a component basis).

A.1 PORVs may be inoperable and capable of being manually cycled (e.g., due to excessive seat leakage). In this condition, either the PORV must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The associated block valve is required to be closed, but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. This permits operation of the plant until the next refueling outage (MODE 6) so that maintenance can be performed on the PORVs to eliminate the problem condition.

Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period.

B.1, B.2, and B.3 If one PORV is inoperable and not capable of being manually cycled, it must be either restored or isolated by closing the associated block valve and removing the power to the associated block valve. The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months are reasonable, based on challenges to the PORVs during this time period, and provide the operator adequate time to correct the situation. If the inoperable valve cannot be restored to OPERABLE status, it must be isolated within the specified time. Because there is at least one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore the inoperable PORV to OPERABLE status. If the PORV cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply, as required by Condition D.

C.1 and C.2 If one block valve is inoperable, then it is necessary to either restore the block valve to OPERABLE status within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV.

Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the Required Action is to place the PORV in manual control (continued)

Watts Bar - Unit 2 B 3.4-54 (developmental) A

Pressurizer PORVs B 3.4.11 BASES ACTIONS C.1 and C.2 (continued) to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and provides the operator time to correct the situation. Because at least one PORV remains OPERABLE, the operator is permitted a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable block valve to OPERABLE status.

The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition B, since the PORVs may not be capable of mitigating an event if the inoperable block valve is not full open. If the block valve is restored within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the PORV may be restored to automatic operation. If it cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply, as required by Condition D.

D.1 and D.2 If the Required Action of Condition A, B, or C is not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

E.1, E.2, E.3, and E.4 If both PORVs are inoperable and not capable of being manually cycled, it is necessary to either restore at least one valve within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If no PORVs are restored within the Completion Time, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

(continued)

Watts Bar - Unit 2 B 3.4-55 (developmental) A

Pressurizer PORVs B 3.4.11 BASES ACTIONS F.1 and F.2 (continued)

If both block valves are inoperable, it is necessary to either restore the block valves within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or place the associated PORVs in manual control and restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Completion Times are reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation.

G.1 and G.2 If the Required Actions of Condition F are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, automatic PORV OPERABILITY may be required. See LCO 3.4.12.

SURVEILLANCE SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can be opened and closed if needed. The basis for the Frequency of 92 days is the ASME OM Code (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure. If the block valve is closed to isolate an inoperable PORV that is incapable of being manually cycled, the maximum Completion Time to restore the PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the allowable limits (25%) to extend the block valve Frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status.

The Note modifies this SR by stating that it is not required to be met with the block valve closed, in accordance with the Required Action of this LCO.

(continued)

Watts Bar - Unit 2 B 3.4-56 (developmental) A

Pressurizer PORVs B 3.4.11 BASES SURVEILLANCE SR 3.4.11.2 REQUIREMENTS (continued) SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of an SGTR. The Frequency of 18 months is based on a typical refueling cycle and industry accepted practice.

REFERENCES 1. Regulatory Guide 1.32, "Criteria for Safety Related Electric Power Systems for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, February 1977.

2. Watts Bar FSAR, Section 15.2, "Condition II - Faults of Moderate Frequency."

3. American Society of Mechanical Engineers (ASME) OM Code, "Code for Operation and Maintenance of Nuclear Power Plants."

Watts Bar - Unit 2 B 3.4-57 (developmental) A

COMS B 3.4.12 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.12 Cold Overpressure Mitigation System (COMS)

BASES BACKGROUND The COMS controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. The PTLR provides the maximum allowable actuation logic setpoints for the power operated relief valves (PORVs) and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Reference 1 requirements during the COMS MODES.

The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures (Ref. 2). RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.

The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition.

Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the PTLR limits.

This LCO provides RCS overpressure protection by having a minimum coolant input capability and having adequate pressure relief capacity.

Limiting coolant input capability requires all safety injection pumps and all but one charging pump incapable of injection into the RCS and isolating the accumulators. The pressure relief capacity requires either two redundant RCS relief valves or a depressurized RCS and an RCS vent of sufficient size. One RCS relief valve or the open RCS vent is the overpressure protection device that acts to terminate an increasing pressure event.

(continued)

Watts Bar - Unit 2 B 3.4-58 (developmental) A

COMS B 3.4.12 BASES BACKGROUND With minimum coolant input capability, the ability to provide core coolant (continued) addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked.

Due to the lower pressures in the COMS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve. If conditions require the use of more than one charging pump or safety injection pump for makeup in the event of loss of inventory, then pumps can be made available through manual actions.

The COMS for pressure relief consists of two PORVs with reduced lift settings, or one PORV and the Residual Heat Removal (RHR) suction relief valve, or a depressurized RCS and an RCS vent of sufficient size.

Two RCS relief valves are required for redundancy. One RCS relief valve has adequate relieving capability to keep from overpressurization for the required coolant input capability.

PORV Requirements As designed for the COMS, each PORV is signaled to open if the RCS pressure approaches a limit determined by the COMS actuation logic.

The COMS actuation logic monitors both RCS temperature and RCS pressure and determines when a condition not acceptable in the PTLR limits is approached. The wide range RCS temperature indications are auctioneered to select the lowest temperature signal.

The lowest temperature signal is processed through a function generator that calculates a pressure limit for that temperature. The calculated pressure limit is then compared with the indicated RCS pressure from a wide range pressure channel. If the indicated pressure meets or exceeds the calculated value, a PORV is signaled to open.

The PTLR presents the PORV setpoints for COMS. The setpoints are normally staggered so only one valve opens during a low temperature overpressure transient. Having the setpoints of both valves within the limits in the PTLR ensures that the Reference 1 limits will not be exceeded in any analyzed event.

When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

(continued)

Watts Bar - Unit 2 B 3.4-59 (developmental) A

COMS B 3.4.12 BASES BACKGROUND RHR Suction Relief Valve Requirements (continued)

During COMS MODES, the RHR System is operated for decay heat removal and low pressure letdown control. Therefore, the RHR suction isolation valves are open in the piping from the RCS hot leg to the inlet header of the RHR pumps. While these valves are open, the RHR suction relief valve is exposed to the RCS and is able to relieve pressure transients in the RCS.

The RHR suction isolation valves must be open to make the RHR suction relief valve OPERABLE for RCS overpressure mitigation. Autoclosure interlocks are not permitted to cause the RHR suction isolation valves to close. The RHR suction relief valve is a spring loaded, bellows type water relief valve with pressure tolerances and accumulation limits established by Section III of the American Society of Mechanical Engineers (ASME) Code (Ref. 3) for Class 2 relief valves.

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

For an RCS vent to meet the flow capacity requirement, it requires removing a pressurizer safety valve, removing a PORV, and disabling its block valve in the open position, or opening the pressurizer manway. The vent path(s) must be above the level of reactor coolant, so as not to drain the RCS when open.

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

Below the COMS arming temperature specified in the PTLR, overpressure prevention falls to two OPERABLE RCS relief valves or to a depressurized RCS and a sufficient sized RCS vent. Each of these means has a limited overpressure relief capability.

(continued)

Watts Bar - Unit 2 B 3.4-60 (developmental) B

COMS B 3.4.12 BASES APPLICABLE The actual temperature at which the pressure in the P/T limit curve falls SAFETY below the pressurizer safety valve setpoint increases as the reactor ANALYSES vessel material toughness decreases due to neutron embrittlement. Each (continued) time the PTLR curves are revised, the COMS must be re-evaluated to ensure its functional requirements can still be met using the RCS relief valve method or the depressurized and vented RCS condition.

The PTLR contains the acceptance limits that define the COMS requirements. Any change to the RCS must be evaluated against the Reference 4 analyses to determine the impact of the change on the COMS acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow:

Mass Input Type Transients

a. Inadvertent safety injection; or

b. Charging/letdown flow mismatch.

Heat Input Type Transients

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

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

The following are required during the COMS MODES to ensure that mass and heat input transients do not occur, which either of the COMS overpressure protection means cannot handle:

a. Rendering all safety injection pumps and all but one charging pump incapable of injection;

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

c. Disallowing start of an RCP if secondary temperature is more than 50°F above primary temperature in any one loop. LCO 3.4.6, "RCS Loops - MODE 4," and LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled," provide this protection.

(continued)

Watts Bar - Unit 2 B 3.4-61 (developmental) A

COMS B 3.4.12 BASES APPLICABLE The Reference 4 analyses demonstrate that either one RCS relief valve SAFETY or the depressurized RCS and RCS vent can maintain RCS pressure ANALYSES below limits when no safety injection pumps and only one centrifugal (continued) charging pump is actuated. Thus, the LCO allows only one charging pump OPERABLE during the COMS MODES. Since neither one RCS relief valve nor the RCS vent can handle the pressure transient induced from accumulator injection, when RCS temperature is low, the LCO also requires the accumulators be isolated when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR.

The isolated accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions. Fracture mechanics analyses established the temperature of COMS Applicability at as specified in the PTLR.

The consequences of a small break loss of coolant accident (LOCA) in COMS MODE 4 conform to 10 CFR 50.46 and 10 CFR 50, Appendix K (Refs. 5 and 6) requirements by having a maximum of one charging pump OPERABLE and SI actuation enabled.

PORV Performance The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit shown in the PTLR. The setpoints are derived by analyses that model the performance of the COMS, assuming the mass injection COMS transient of no safety injection pumps and only one centrifugal charging pump injecting into the RCS and the heat injection COMS transient of starting a RCP with the RCS 50°F colder than the secondary side. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensures the Reference 1 P/T limits will be met.

The PORV setpoints in the PTLR will be updated when the revised P/T limits conflict with the COMS analysis limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," discuss these examinations.

(continued)

Watts Bar - Unit 2 B 3.4-62 (developmental) B

COMS B 3.4.12 BASES APPLICABLE PORV Performance (continued)

SAFETY ANALYSES The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

RHR Suction Relief Valve Performance The RHR suction relief valve does not have variable pressure and temperature lift setpoints like the PORVs. Analyses must show that the RHR suction relief valve with a setpoint at or between 436.5 psig and 463.5 psig will pass flow greater than that required for the limiting COMS transient while maintaining RCS pressure less than the P/T limit curve.

Assuming all relief flow requirements during the limiting COMS event, the RHR suction relief valve will maintain RCS pressure to within the valve rated lift setpoint, plus an accumulation < 3% of the rated lift setpoint.

The RHR suction relief valve inclusion and location within the RHR System does not allow it to meet single failure criteria when spurious RHR suction isolation valve closure is postulated. Also, as the RCS P/T limits are decreased to reflect the loss of toughness in the reactor vessel materials due to neutron embrittlement, the RHR suction relief valves must be analyzed to still accommodate the design basis transients for COMS.

The RHR suction relief valve is considered an active component. Thus, the failure of this valve is assumed to represent the worst case single active failure.

RCS Vent Performance With the RCS depressurized, analyses show a vent capable of relieving

> 475 gpm water flow is capable of mitigating the allowed COMS overpressure transient. The capacity of 475 gpm is greater than the flow of the limiting transient for the COMS configuration, with one centrifugal charging pump OPERABLE, maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

Three vent flow paths have been identified in the RCS which could serve as pressure release (vent) paths. With one safety or PORV removed, the open line could serve as one vent path. The pressurizer manway could serve as an alternative vent path with the manway cover removed. These flow paths are capable of discharging 475 gpm at low pressure in the RCS. Thus, any one of the openings can be used for relieving the pressure to prevent violating the P/T limits.

(continued)

Watts Bar - Unit 2 B 3.4-63 (developmental) A

COMS B 3.4.12 BASES APPLICABLE RCS Vent Performance (continued)

SAFETY ANALYSES The RCS vent size will be re-evaluated for compliance each time the P/T limit curves are revised based on the results of the vessel material surveillance. The RCS vent is passive and is not subject to active failure.

The COMS satisfies Criterion 2 of the NRC Policy Statement.

LCO This LCO requires that the COMS is OPERABLE. The COMS is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient.

To limit the coolant input capability, the LCO requires no safety injection pumps and a maximum of one charging pump be capable of injecting into the RCS, and all accumulator discharge isolation valves be closed and immobilized when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR.

The LCO is modified by two Notes. Note 1 allows two charging pumps to be made capable of injecting for less than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during pump swap operations. One hour provides sufficient time to safely complete the actual transfer and to complete the administrative controls and surveillance requirements associated with the swap. The intent is to minimize the actual time that more than one charging pump is physically capable of injection.

Note 2 states that accumulator isolation is only required when the accumulator pressure is more than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This Note permits the accumulator discharge isolation valve Surveillance to be performed only under these pressure and temperature conditions.

(continued)

Watts Bar - Unit 2 B 3.4-64 (developmental) A

COMS B 3.4.12 BASES LCO The elements of the LCO that provide low temperature overpressure (continued) mitigation through pressure relief are:

a. Two RCS relief valves, as follows:

1. Two OPERABLE PORVs; or A PORV is OPERABLE for COMS when its block valve is open, its lift setpoint is set to the limit required by the PTLR and testing proves its ability to open at this setpoint, and motive power is available to the valve and its control circuit.

2. One OPERABLE PORV and the OPERABLE RHR suction relief valve; or An RHR suction relief valve is OPERABLE for COMS when both RHR suction isolation valves are open, its setpoint is at or between 436.5 psig and 463.5 psig, and testing has proven its ability to open at this setpoint.

b. A depressurized RCS and an RCS vent.

An RCS vent is OPERABLE when capable of relieving > 475 gpm water flow.

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

APPLICABILITY This LCO is applicable in MODE 4 with any RCS cold leg temperature

< the COMS arming temperature specified in the PTLR, MODE 5, and MODE 6 when the reactor vessel head is on. The pressurizer safety valves provide overpressure protection that meets the Reference 1 P/T limits above the COMS arming temperature specified in the PTLR. When the reactor vessel head is off, overpressurization cannot occur.

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

LCO 3.4.10, "Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1, 2, and 3 and MODE 4 with all RCS cold leg temperatures

> the COMS arming temperature specified in the PTLR.

(continued)

Watts Bar - Unit 2 B 3.4-65 (developmental) B

COMS B 3.4.12 BASES APPLICABILITY Low temperature overpressure prevention is most critical during (continued) shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable COMS.

There is an increased risk associated with entering MODE 4 from MODE 5 with COMS inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and B.1 With two or more charging pumps or any safety injection pumps capable of injecting into the RCS, RCS overpressurization is possible.

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

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

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action D.1 and Required Action D.2 provide two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to > the COMS arming temperature specified in the PTLR, an accumulator pressure specified in WAT-D-0863 (Ref. 8) cannot exceed the COMS limits if the accumulators are fully injected.

Depressurizing the accumulators below the COMS limit from the PTLR also gives this protection.

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

(continued)

Watts Bar - Unit 2 B 3.4-66 (developmental) B

COMS B 3.4.12 BASES ACTIONS E.1 (continued)

In MODE 4 with one required RCS relief valve inoperable, the RCS relief valve must be restored to OPERABLE status within a Completion Time of 7 days. Two RCS relief valves are required to provide low temperature overpressure mitigation while withstanding a single failure of an active component.

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

F.1 The consequences of operational events that will overpressurize the RCS are more severe at lower temperature (Ref. 7). Thus, with one of the two RCS relief valves inoperable in MODE 5 or in MODE 6 with the head on, the Completion Time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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

G.1 The RCS must be depressurized and a vent must be established within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when:

a. Both required RCS relief valves are inoperable; or

b. A Required Action and associated Completion Time of Condition A, B, D, E or F is not met; or

c. The COMS is inoperable for any reason other than Condition A, B, C, D, E or F.

This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

(continued)

Watts Bar - Unit 2 B 3.4-67 (developmental) A

COMS B 3.4.12 BASES ACTIONS G.1 (continued)

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

SURVEILLANCE SR 3.4.12.1, SR 3.4.12.2, and SR 3.4.12.3 REQUIREMENTS To minimize the potential for a low temperature overpressure event by limiting the mass input capability, no safety injection pumps and all but one charging pump are verified incapable of injecting into the RCS and the accumulator discharge isolation valves are verified closed and locked out.

The safety injection pumps and charging pump are rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control. Alternative methods of low temperature overpressure protection control may be employed using at least two independent means such that a single failure or single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in pull to lock and at least one valve in the discharge flow path being closed, or closing discharge MOV(s) and de-energizing the motor operator(s) under administrative control, or locking closed and tagging manual valve(s) in the discharge flow path.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment. The additional Frequency for SR 3.4.12.1 and SR 3.4.12.2 is necessary to allow time during the transition from MODE 3 to MODE 4 to make the pumps inoperable.

SR 3.4.12.4 The RCS vent capable of relieving > 475 gpm water flow is proven OPERABLE by verifying its open condition either:

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

b. Once every 31 days for a vent path that is locked, sealed, or secured in position. A removed safety or PORV fits this category.

(continued)

Watts Bar - Unit 2 B 3.4-68 (developmental) A

COMS B 3.4.12 BASES SURVEILLANCE SR 3.4.12.4 (continued)

REQUIREMENTS The passive vent arrangement must only be open to be OPERABLE.

This Surveillance is required to be performed if the vent is being used to satisfy the pressure relief requirements of the LCO 3.4.12b.

SR 3.4.12.5 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve must be remotely verified open in the main control room. This Surveillance is performed if the PORV satisfies the LCO.

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

The 72-hour Frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

SR 3.4.12.6 The required RHR suction relief valve shall be demonstrated OPERABLE by verifying both RHR suction isolation valves are open and by testing it in accordance with the Inservice Testing Program. This Surveillance is only performed if the RHR suction relief valve is being used to satisfy this LCO.

Every 31 days both RHR suction isolation valves are verified locked open, with power to the valve operator removed, to ensure that accidental closure will not occur. The "locked open" valves must be locally verified in the open position with the manual actuator locked. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve position.

(continued)

Watts Bar - Unit 2 B 3.4-69 (developmental) A

COMS B 3.4.12 BASES SURVEILLANCE SR 3.4.12.7 REQUIREMENTS (continued) The COT is required to be in frequency prior to decreasing RCS temperature to the COMS arming temperature specified in the PTLR or be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS temperature to the COMS arming temperature specified in the PTLR on each required PORV to verify and, as necessary, adjust its lift setpoint. The COT will verify the setpoint is within the PTLR allowed maximum limits in the PTLR. PORV actuation could depressurize the RCS and is not required. The COT is required to be performed every 31 days when RCS temperature is the COMS arming temperature specified in the PTLR with the reactor head in place.

The 12-hour allowance to meet the requirement considers the unlikelihood of a low temperature overpressure event during this time.

A Note has been added indicating that this SR is required to be met within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to the COMS arming temperature specified in the PTLR.

SR 3.4.12.8 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

(continued)

Watts Bar - Unit 2 B 3.4-70 (developmental) B

COMS B 3.4.12 BASES (continued)

REFERENCES 1. Title 10, Code of Federal Regulations, Part 50, Appendix G, "Fracture Toughness Requirements."

2. Generic Letter 88-11, "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and Its Impact on Plant Operation."

3. ASME Boiler and Pressure Vessel Code,Section III.

4. Watts Bar FSAR, Section 15.2, "Condition II - Faults of Moderate Frequency."

5. Title 10, Code of Federal Regulations, Part 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors."

6. Title 10, Code of Federal Regulations, Part 50, Appendix K, "ECCS Evaluation Models."

7. Generic Letter 90-06, "Resolution of Generic Issue 70,

'Power-Operated Relief Valve and Block Valve Reliability, and Generic Issue 94, 'Additional Low-Temperature Overpressure Protection for Light Water Reactors,' pursuant to 10 CFR 50.44(f)."

8. Westinghouse Letter to TVA, WBT-D-0863, WBS 5.6.10 Cold Overpressure Mitigation System Setpoint Analysis, July 2009.

Watts Bar - Unit 2 B 3.4-71 (developmental) B

RCS Operational LEAKAGE B 3.4.13 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.13 RCS Operational LEAKAGE BASES BACKGROUND Components that contain or transport the coolant to or from the reactor core make up the RCS. Component joints are made by welding, bolting, rolling, or pressure loading, and valves isolate connecting systems from the RCS.

During plant life, the joint and valve interfaces can allow varying amounts of reactor coolant LEAKAGE, through either normal operational wear or mechanical deterioration. The purpose of the RCS Operational LEAKAGE LCO is to limit system operation in the presence of LEAKAGE from these sources to amounts that do not compromise safety. This LCO specifies the types and amounts of LEAKAGE.

10 CFR 50, Appendix A, GDC 30 (Ref. 1), requires means for detecting and, to the extent practical, identifying the source of reactor coolant LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring reactor coolant LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE is necessary to provide quantitative information to the operators, allowing them to take corrective action should a leak occur that is detrimental to the safety of the facility and the public.

A limited amount of leakage inside containment is expected from auxiliary systems that cannot be made 100% leaktight. Leakage from these systems should be detected, located, and isolated from the containment atmosphere, if possible, to not interfere with RCS leakage detection.

This LCO deals with protection of the reactor coolant pressure boundary (RCPB) from degradation and the core from inadequate cooling, in addition to preventing the accident analyses radiation release assumptions from being exceeded. The consequences of violating this LCO include the possibility of a loss of coolant accident (LOCA) or steam generator tube rupture (SGTR).

(continued)

Watts Bar - Unit 2 B 3.4-72 (developmental) A

RCS Operational LEAKAGE B 3.4.13 BASES (continued)

APPLICABLE Except for primary to secondary LEAKAGE, the safety analyses do not SAFETY address operational LEAKAGE. However, other operational LEAKAGE is ANALYSES related to the safety analyses for LOCA; the amount of leakage can affect the probability of such an event. The safety analysis for a main steam line break (MSLB) assumes that the pre-accident primary-to-secondary LEAKAGE from three steam generators is 150 gallons per day (gpd) per steam generator and 1 gallon per minute (gpm) from one steam generator. This leakage assumption remains the same after the accident.

For an SGTR accident, the accident analysis assumes a primary-to-secondary leakage of 150 gpd per steam generator prior to the accident.

Subsequent to the SGTR a leakage of 150 gpd is assumed in each of three intact steam generators and RCS blowdown flow through the ruptured tube in the faulted steam generator. Consequently, the LCO requirement to limit primary-to-secondary LEAKAGE through any one steam generator to less than or equal to 150 gpd is acceptable.

The safety analysis for the SLB accident assumes the entire 1 gpm primary-to-secondary LEAKAGE is through the affected steam generator as an initial condition. The dose consequences resulting from the SLB accident are within the limits defined in 10 CFR 100 or the staff approved licensing basis (i.e., a small fraction of these limits).

The RCS operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO RCS operational LEAKAGE shall be limited to:

a. Pressure Boundary LEAKAGE No pressure boundary LEAKAGE is allowed, being indicative of an off-normal condition. LEAKAGE of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

(continued)

Watts Bar - Unit 2 B 3.4-73 (developmental) A

RCS Operational LEAKAGE B 3.4.13 BASES LCO b. Unidentified LEAKAGE (continued)

One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment pocket sump level monitoring equipment can detect within a reasonable time period. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary.

c. Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS Makeup System. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.

d. Primary to Secondary LEAKAGE through ANY One SG The limit of 150 gallons per day (gpd) per SG (600 gpd total for all SGs) is based on the operational LEAKAGE performance criteria in NEI 97-06, Steam Generator Program Guidelines (Reference 4).

The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day. The limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational leakage rate criterion in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.

(continued)

Watts Bar - Unit 2 B 3.4-74 (developmental) A

RCS Operational LEAKAGE B 3.4.13 BASES (continued)

APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.

In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

ACTIONS A.1 Unidentified LEAKAGE or identified LEAKAGE in excess of the LCO limits must be reduced to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB.

B.1 and B.2 If any pressure boundary LEAKAGE exists, or primary-to-secondary LEAKAGE is not within limits, or if unidentified LEAKAGE or identified LEAKAGE cannot be reduced to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

The reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.

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.

In MODE 5, the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.

Watts Bar - Unit 2 B 3.4-75 (developmental) A

RCS Operational LEAKAGE B 3.4.13 BASES (continued)

SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance.

The RCS water inventory balance must be met with the reactor at steady state operating conditions and near operating pressure. The SR is modified by 2 Notes. Note 1 states that this SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Steady state operation is required to perform a proper inventory balance; calculations during maneuvering are not useful. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment pocket sump level. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. These leakage detection systems are specified in LCO 3.4.15, "RCS Leakage Detection Instrumentation."

Note 2 states that this SR is not applicable to primary-to-secondary LEAKAGE because LEAKAGE of 150 gallons per day cannot be measured accurately by an RCS water inventory balance.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Frequency is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents.

Watts Bar - Unit 2 B 3.4-76 (developmental) A

RCS Operational LEAKAGE B 3.4.13 BASES (continued)

SURVEILLANCE SR 3.4.13.2 REQUIREMENTS (continued) This SR verifies that primary-to-secondary LEAKAGE is less than or equal to 150 gallons per day through any one SG. Satisfying the primary-to-secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, compliance with LCO 3.4.17 Steam Generator Tube Integrity, should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Ref. 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary-to-secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a NOTE which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation. For RCS primary-to-secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable interval to trend primary-to-secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. The primary-to-secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with EPRI guidelines (Ref. 5)

REFERENCES 1. Title 10, Code of Federal Regulations, Part 50, Appendix A, General Design Criteria 30, "Quality of Reactor Coolant Boundary."

2. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

3. Watts Bar FSAR, Section 15.4, "Condition IV - Limiting Faults."

4. NEI 97-06, Steam Generator Program Guidelines.

5. EPRI Pressurized Water Reactor Primary-to-Secondary Leak Guidelines.

Watts Bar - Unit 2 B 3.4-77 (developmental) A

RCS PIV Leakage B 3.4.14 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage BASES BACKGROUND 10 CFR 50.2, 10 CFR 50.55a(c), and GDC 55 of 10 CFR 50, Appendix A (Refs. 1, 2, and 3), define RCS PIVs as any two normally closed valves in series within the reactor coolant pressure boundary (RCPB), which separate the high pressure RCS from an attached low pressure system.

During their lives, these valves can produce varying amounts of reactor coolant leakage through either normal operational wear or mechanical deterioration. The RCS PIV Leakage LCO allows RCS high pressure operation when leakage through these valves exists in amounts that do not compromise safety.

The PIV leakage limit applies to each individual valve.

Although this specification provides a limit on allowable PIV leakage rate, its main purpose is to prevent overpressure failure of the low pressure portions of connecting systems. The leakage limit is an indication that the PIVs between the RCS and the connecting systems are degraded or degrading. PIV leakage could lead to overpressure of the low pressure piping or components. Failure consequences could be a loss of coolant accident (LOCA) outside of containment, an unanalyzed accident, that could degrade the ability for low pressure injection.

The basis for this LCO is the 1975 NRC "Reactor Safety Study" (Ref. 4) that identified potential intersystem LOCAs as a significant contributor to the risk of core melt. A subsequent study (Ref. 5) evaluated various PIV configurations to determine the probability of intersystem LOCAs.

PIVs are provided to isolate the RCS from the following typically connected systems:

a. Residual Heat Removal (RHR) System;

b. Safety Injection System; and

c. Chemical and Volume Control System.

The PIVs are listed in the FSAR, Section 3.9 (Ref. 6).

(continued)

Watts Bar - Unit 2 B 3.4-78 (developmental) A

RCS PIV Leakage B 3.4.14 BASES BACKGROUND Violation of this LCO could result in continued degradation of a PIV, which (continued) could lead to overpressurization of a low pressure system and the loss of the integrity of a fission product barrier.

APPLICABLE Reference 4 identified potential intersystem LOCAs as a significant SAFETY contributor to the risk of core melt. The dominant accident sequence in ANALYSES the intersystem LOCA category is the failure of the low pressure portion of the RHR System outside of containment. The accident is the result of a postulated failure of the PIVs, which are part of the RCPB, and the subsequent pressurization of the RHR System downstream of the PIVs from the RCS. Because the low pressure portion of the RHR System is typically designed for 600 psig, overpressurization failure of the RHR low pressure line would result in a LOCA outside containment and subsequent risk of core melt.

Reference 5 evaluated various PIV configurations, leakage testing of the valves, and operational changes to determine the effect on the probability of intersystem LOCAs. This study concluded that periodic leakage testing of the PIVs can substantially reduce the probability of an intersystem LOCA.

RCS PIV leakage satisfies Criterion 2 of the NRC Policy Statement.

LCO RCS PIV leakage is LEAKAGE into closed systems connected to the RCS. Isolation valve leakage is usually on the order of drops per minute.

Leakage that increases significantly suggests that something is operationally wrong and corrective action must be taken.

The LCO PIV leakage limit is 0.5 gpm per nominal inch of valve size with a maximum limit of 5 gpm. The previous criterion of 1 gpm for all valve sizes imposed an unjustified penalty on the larger valves without providing information on potential valve degradation and resulted in higher personnel radiation exposures. A study concluded a leakage rate limit based on valve size was superior to a single allowable value.

(continued)

Watts Bar - Unit 2 B 3.4-79 (developmental) A

RCS PIV Leakage B 3.4.14 BASES LCO Reference 7 permits leakage testing at a lower pressure differential than (continued) between the specified maximum RCS pressure and the normal pressure of the connected system during RCS operation (the maximum pressure differential) in those types of valves in which the higher service pressure will tend to diminish the overall leakage channel opening. In such cases, the observed rate may be adjusted to the maximum pressure differential by assuming leakage is directly proportional to the pressure differential to the one half power.

APPLICABILITY In MODES 1, 2, 3, and 4, this LCO applies because the PIV leakage potential is greatest when the RCS is pressurized. In MODE 4, valves in the RHR flow path are not required to meet the requirements of this LCO when in or during the transition to or from the RHR mode of operation.

In MODES 5 and 6, leakage limits are not provided because the lower reactor coolant pressure results in a reduced potential for leakage and for a LOCA outside the containment.

ACTIONS The Actions are modified by two Notes. Note 1 provides clarification that each flow path allows separate entry into a Condition. This is allowed based upon the functional independence of the flow path. Note 2 requires an evaluation of affected systems if a PIV is inoperable. The leakage may have affected system operability, or isolation of a leaking flow path with an alternate valve may have degraded the ability of the interconnected system to perform its safety function.

A.1 and A.2 The flow path must be isolated. Required Actions A.1 and A.2 are modified by a Note that the valve used for isolation must meet the same leakage requirements as the PIVs and must be within the RCPB.

Required Action A.1 requires that the isolation with one valve must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Four hours provides time to reduce leakage in excess of the allowable limit and to isolate the affected system if leakage cannot be reduced. The 4-hour Completion Time allows the actions and restricts the operation with leaking isolation valves.

(continued)

Watts Bar - Unit 2 B 3.4-80 (developmental) A

RCS PIV Leakage B 3.4.14 BASES ACTIONS A.1 and A.2 (continued)

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time after exceeding the limit allows for the restoration of the leaking PIV to OPERABLE status. This timeframe considers the time required to complete this Action and the low probability of a second valve failing during this period.

B.1 and B.2 If leakage cannot be reduced, or the system isolated, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This Action may reduce the leakage and also reduces the potential for a LOCA outside the containment. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

(continued)

Watts Bar - Unit 2 B 3.4-81 (developmental) A

RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE SR 3.4.14.1 (continued)

REQUIREMENTS Testing is to be performed every 18 months, a typical refueling cycle, if the plant does not go into MODE 5 for at least 7 days. The 18 month Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8) as contained in the Inservice Testing Program, is within the frequency allowed by the American Society of Mechanical Engineers (ASME) OM Code (Ref. 7),

and is based on the need to perform such surveillances under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the valve has been reseated. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable and practical time limit for performing this test after opening or reseating a valve.

The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.

Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.

(continued)

Watts Bar - Unit 2 B 3.4-82 (developmental) A

RCS PIV Leakage B 3.4.14 BASES (continued)

REFERENCES 1. Title 10, Code of Federal Regulations, Part 50, Section 50.2, "Definitions - Reactor Coolant Pressure Boundary."

2. Title 10, Code of Federal Regulations, Part 50, Section 50.55a, "Codes and Standards," Subsection (c), "Reactor Coolant Pressure Boundary."

3. Title 10, Code of Federal Regulations, Part 50, Appendix A,Section V, "Reactor Containment," General Design Criterion 55, "Reactor Coolant Pressure Boundary Penetrating Containment."

4. U.S. Nuclear Regulatory Commission (NRC), "Reactor Safety Study

- An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants," Appendix V, WASH-1400 (NUREG-75/014),

October 1975.

5. U.S. NRC, "The Probability of Intersystem LOCA: Impact Due to Leak Testing and Operational Changes," NUREG-0677, May 1980.

6. Watts Bar FSAR, Section 3.9, "Mechanical Systems and Components" (Table 3.9-17).

7. American Society of Mechanical Engineers (ASME) OM Code, Code for Operation and Maintenance of Nuclear Power Plants.

8. Title 10, Code of Federal Regulations, Part 50, Section 50.55a, "Codes and Standards," Subsection (g), "Inservice Inspection Requirements."

Watts Bar - Unit 2 B 3.4-83 (developmental) A

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

Industry practice has shown that water flow changes of 0.5 gpm to 1.0 gpm can be readily detected in contained volumes by monitoring changes in water level, in flow rate, or in the operating frequency of a pump. The containment pocket sump used to collect unidentified LEAKAGE is instrumented to alarm for increases of 0.5 gpm to 1.0 gpm in the normal flow rates. This sensitivity is acceptable for detecting increases in unidentified LEAKAGE.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. Instrument sensitivity of 10-9 µCi/cc radioactivity for particulate monitoring is practical for this leakage detection system. A radioactivity detection system is included for monitoring particulate activity because of its sensitivity and rapid response to RCS LEAKAGE.

(continued)

Watts Bar - Unit 2 B 3.4-84 (developmental) B

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND An atmospheric gaseous radioactivity monitor will provide a positive (continued) indication of leakage in the event that high levels of reactor coolant gaseous activity exist due to fuel cladding defects. The effectiveness of the atmospheric gaseous radioactivity monitors depends primarily on the activity of the reactor coolant and also, in part, on the containment volume and the background activity level. Shortly after startup and also during steady state operation with low levels of fuel defects, the level of radioactivity in the reactor coolant may be too low for the containment atmosphere gaseous radiation monitors to detect a reactor coolant leak of 1 gpm within one hour. Atmospheric gaseous radioactivity monitors are not required by this LCO.

The sample lines supplying the radioactivity monitoring instrumentation are heated (heat traced) to ensure that a representative sample can be obtained. During periods when the heat tracing is inoperable, the particulate channel of the radioactivity monitoring instrumentation is inoperable and grab samples for particulates may not be taken using the sample lines.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE.

A 1°F increase in dew point is well within the sensitivity range of available instruments.

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment pocket sump. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO.

(continued)

Watts Bar - Unit 2 B 3.4-85 (developmental) B

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

BACKGROUND Air temperature and pressure monitoring methods may also be used to (continued) infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO.

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY to the operators, and the ability to compare and verify with indications ANALYSES from other systems is necessary. The system response times and sensitivities are described in the FSAR (Ref. 3).

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leak detrimental to the safety of the unit and the public occur. RCS leakage detection instrumentation satisfies Criterion 1 of the NRC Policy Statement.

LCO One method of protecting against large RCS leakage derives from the ability of instruments to rapidly detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition when RCS LEAKAGE indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment pocket sump level monitor, in combination with a particulate radioactivity monitor, provides an acceptable minimum.

The sample lines supplying the radioactivity monitoring instrumentation are heated (heat traced) to ensure that a representative sample can be obtained.

(continued)

Watts Bar - Unit 2 B 3.4-86 (developmental) B

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2 With the required containment pocket sump level monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere particulate radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Restoration of the required containment pocket sump level monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

(continued)

Watts Bar - Unit 2 B 3.4-87 (developmental) B

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

ACTIONS B.1.1, B.1.2, and B.2 (continued)

With the particulate containment atmosphere radioactivity monitoring instrumentation channel inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

During periods when the heat tracing is inoperable for the sample lines supplying the radioactivity monitoring instrumentation, the particulate channel of the instrumentation is inoperable and grab samples for particulates may not be taken using the sample lines.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere particulate radioactivity monitor.

The 24-hour interval provides periodic information that is adequate to detect leakage. The 30-day Completion Time recognizes at least one other form of leakage detection is available.

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

D.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

(continued)

Watts Bar - Unit 2 B 3.4-88 (developmental) B

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere particulate radioactivity monitor. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere particulate radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner.

The test verifies the alarm setpoint and the relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

REFERENCES 1. 10 CFR 50, Appendix A, General Design Criterion 30, "Quality of Reactor Coolant Pressure Boundary."

2. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0, May 1973.

3. Watts Bar FSAR, Section 5.2.7, "RCPB Leakage Detection Systems."

Watts Bar - Unit 2 B 3.4-89 (developmental) B

RCS Specific Activity B 3.4.16 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.16 RCS Specific Activity BASES BACKGROUND The maximum dose to the whole body and the thyroid that an individual at the site boundary can receive for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months during an accident is specified in 10 CFR 100 (Ref. 1). The maximum dose to the whole body and the thyroid that an individual occupying the Main Control Room can receive for the accident duration is specified in 10 CFR 50, Appendix A, GDC 19.

The limits on specific activity ensure that the doses are held to a small fraction of the 10 CFR 100 limits and within the 10 CFR 50, Appendix A, GDC 19 limits during analyzed transients and accidents.

The RCS specific activity LCO limits the allowable concentration level of radionuclides in the reactor coolant. The LCO limits are established to minimize the offsite and Main Control Room radioactivity dose consequences in the event of a steam generator tube rupture (SGTR) or main steam line break (MSLB) accident.

The LCO contains specific activity limits for both DOSE EQUIVALENT I-131 and gross specific activity. The allowable levels are intended to limit the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose at the site boundary to a small fraction of the 10 CFR 100 dose guideline limits, and ensure the Main Control Room accident dose is within the appropriate 10 CFR 50, Appendix A, GDC 19 dose guideline limits.

The evaluations showed the potential offsite and Main Control Room dose levels for a SGTR and MSLB accident were within the appropriate 10 CFR 100 and GDC 19 guideline limits.

(continued)

Watts Bar - Unit 2 B 3.4-90 (developmental) A

RCS Specific Activity B 3.4.16 BASES (continued)

APPLICABLE The LCO limits on the specific activity of the reactor coolant ensures that SAFETY the resulting 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months doses at the site boundary and Main Control Room ANALYSES accident doses will not exceed the appropriate 10 CFR 100 dose guideline limits and 10 CFR 50, Appendix A, GDC 19 dose guideline limits following a SGTR or MSLB accident. The SGTR and MSLB safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LCO limit and an existing reactor coolant steam generator (SG) tube leakage rate of 150 gallons per day (GPD). The safety analysis assumes the specific activity of the secondary coolant at its limit of 0.1 Ci/gm DOSE EQUIVALENT I-131 from LCO 3.7.14, "Secondary Specific Activity."

The analysis for the SGTR and MSLB accidents establish the acceptance limits for RCS specific activity. Reference to these analyses is used to assess changes to the unit that could affect RCS specific activity, as they relate to the acceptance limits.

The analyses are for two cases of reactor coolant specific activity. One case assumes specific activity at 0.265 Ci/gm DOSE EQUIVALENT I-131 with an iodine spike immediately after the accident that increases the iodine activity in the reactor coolant by a factor of 500 times the iodine production rate necessary to maintain a steady state iodine concentration of 0.265 Ci/gm DOSE EQUIVALENT I-131. The second case assumes the initial reactor coolant iodine activity at 21 Ci/gm DOSE EQUIVALENT I-131 due to a pre-accident iodine spike caused by an RCS transient. In both cases, the noble gas activity in the reactor coolant equals the LCO limit of 100/E Ci/gm for gross specific activity.

The analysis also assumes a loss of offsite power at the same time as the SGTR and MSLB event. The SGTR causes a reduction in reactor coolant inventory. The reduction initiates a reactor trip from a low pressurizer pressure signal or an RCS overtemperature T signal. The MSLB results in a reactor trip due to low steam pressure.

The coincident loss of offsite power causes the steam dump valves to close to protect the condenser. The rise in pressure in the ruptured SG discharges radioactively contaminated steam to the atmosphere through the SG power operated relief valves and the main steam safety valves.

The unaffected SGs remove core decay heat by venting steam to the atmosphere until the cooldown ends.

(continued)

Watts Bar - Unit 2 B 3.4-91 (developmental) B

RCS Specific Activity B 3.4.16 BASES APPLICABLE The safety analysis shows the radiological consequences of an SGTR SAFETY and MSLB accident are within the appropriate 10 CFR 100 and ANALYSES 10 CFR 50, Appendix A, GDC 19 dose guideline limits. Operation with (continued) iodine specific activity levels greater than the LCO limit is permissible, if the activity levels do not exceed 21 Ci/gm DOSE EQUIVALENT I-131, in the applicable specification, for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The safety analysis has concurrent and pre-accident iodine spiking levels up to 21 Ci/gm DOSE EQUIVALENT I-131.

The limits on RCS specific activity are also used for establishing standardization in radiation shielding and plant personnel radiation protection practices.

RCS specific activity satisfies Criterion 2 of the NRC Policy Statement.

LCO The specific iodine activity is limited to 0.265 Ci/gm DOSE EQUIVALENT I-131, and the gross specific activity in the reactor coolant is limited to the number of Ci/gm equal to 100 divided by E (average disintegration energy of the sum of the average beta and gamma energies of the coolant nuclides). The limit on DOSE EQUIVALENT I-131 ensures the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid dose to an individual at the site boundary and accident dose to personnel in the Main Control Room during the Design Basis Accident (DBA) will be within the allowed thyroid dose. The limit on gross specific activity ensures the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months whole body dose to an individual at the site boundary and accident dose to personnel in the Main Control Room during the DBA will be within the allowed whole body dose.

The SGTR and MSLB accident analysis (Ref. 2) shows that the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months site boundary dose levels and Main Control Room accident dose are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of a SGTR or MSLB, lead to site boundary doses that exceed the 10 CFR 100 dose guideline limits, or Main Control Room accident dose that exceed the 10 CFR 50, Appendix A, GDC 19 dose limits.

(continued)

Watts Bar - Unit 2 B 3.4-92 (developmental) A

RCS Specific Activity B 3.4.16 BASES (continued)

APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS average temperature 500°F, operation within the LCO limits for DOSE EQUIVALENT I-131 and gross specific activity are necessary to contain the potential consequences of an accident to within the acceptable Main Control Room and site boundary dose values.

For operation in MODE 3 with RCS average temperature < 500°F, and in MODES 4 and 5, the release of radioactivity in the event of a SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the main steam safety valves.

ACTIONS A.1 and A.2 With the DOSE EQUIVALENT I-131 greater than the LCO limit, samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to demonstrate that the limit of 21 Ci/gm is not exceeded. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample. Sampling is done to continue to provide a trend.

The DOSE EQUIVALENT I-131 must be restored to within limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is required, if the limit violation resulted from normal iodine spiking.

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

(continued)

Watts Bar - Unit 2 B 3.4-93 (developmental) A

RCS Specific Activity B 3.4.16 BASES ACTIONS B.1 and B.2 (continued)

With the gross specific activity in excess of the allowed limit, an analysis must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to determine DOSE EQUIVALENT I-131. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample.

The change within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to MODE 3 and RCS average temperature

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

C.1 If a Required Action and the associated Completion Time of Condition A is not met or if the DOSE EQUIVALENT I-131 is greater than 21 Ci/gm, the reactor must be brought to MODE 3 with RCS average temperature

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

SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross specific activity.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The Surveillance is applicable in MODES 1 and 2, and in MODE 3 with Tavg at least 500°F. The 7-day Frequency considers the unlikelihood of a gross fuel failure during the time.

(continued)

Watts Bar - Unit 2 B 3.4-94 (developmental) A

RCS Specific Activity B 3.4.16 BASES SURVEILLANCE SR 3.4.16.2 REQUIREMENTS (continued) This Surveillance is performed in MODE 1 only to ensure iodine remains within limit during normal operation and following rapid power changes when fuel failure is more apt to occur. The 14-day Frequency is adequate to trend changes in the iodine activity level, considering gross activity is monitored every 7 days. The Frequency, between 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time following fuel failure; samples at other times would provide inaccurate results.

SR 3.4.16.3 A radiochemical analysis forE determination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions.

TheE determination directly relates to the LCO and is required to verify plant operation within the specified gross activity LCO limit. The analysis forE is a measurement of the average energies per disintegration for isotopes with half lives longer than 15 minutes, excluding iodines. The Frequency of 184 days recognizesE does not change rapidly.

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

REFERENCES 1. Title 10, Code of Federal Regulations, Part 100.11, Determination of Exclusion Area, Low Population Zone, and Population Center Distance, 1973.

2. Watts Bar FSAR, Section 15.4, Condition IV - Limiting Faults.

Watts Bar - Unit 2 B 3.4-95 (developmental) A

SG TUBE INTEGRITY B 3.4.17 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.17 STEAM GENERATOR (SG) TUBE INTEGRITY BASES BACKGROUND Steam generator (SG) tubes are small diameter, thin walled tubes that carry primary coolant through the primary to secondary heat exchangers.

The SG tubes have a number of important safety functions. Steam generator tubes are an integral part of the reactor coolant pressure boundary (RCPB) and, as such, are relied on to maintain the primary systems pressure and inventory. The SG tubes isolate the radioactive fission products in the primary coolant from the secondary system. In addition, as part of the RCPB, the SG tubes are unique in that they act as the heat transfer surface between the primary and secondary systems to remove heat from the primary system. This Specification addresses only the RCPB integrity function of the SG. The SG heat removal function is addressed by LCO 3.4.4, RCS Loops - MODES 1 and 2, LCO 3.4.5, RCS Loops - MODE 3, LCO 3.4.6, RCS Loops - MODE 4, and LCO 3.4.7, RCS Loops - MODE 5, Loops Filled.

SG tube integrity means that the tubes are capable of performing their intended RCPB safety function consistent with the licensing basis, including applicable regulatory requirements.

Steam generator tubing is subject to a variety of degradation mechanisms. Steam generator tubes may experience tube degradation related to corrosion phenomena, such as wastage, pitting, intergranular attack, and stress corrosion cracking, along with other mechanically induced phenomena such as denting and wear. These degradation mechanisms can impair tube integrity if they are not managed effectively.

The SG performance criteria are used to manage SG tube degradation.

Specification 5.7.2.12, Steam Generator (SG) Program, requires that a program be established and implemented to ensure that SG tube integrity is maintained. Pursuant to Specification 5.7.2.12, tube integrity is maintained when the SG performance criteria are met. There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. The SG performance criteria are described in Specification 5.7.2.12. Meeting the SG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

(continued)

Watts Bar - Unit 2 B 3.4-96 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES BACKGROUND The processes used to meet the SG performance criteria are defined by (continued) the Steam Generator Program Guidelines (Ref. 1).

APPLICABLE The steam generator tube rupture (SGTR) accident is the limiting design SAFETY basis event for SG tubes and avoiding an SGTR is the basis for this ANALYSES Specification. The analysis of an SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.13, RCS Operational LEAKAGE, plus the leakage rate associated with a double-ended rupture of a single tube. The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than an SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture). In these analyses, the steam discharge to the atmosphere is based on the total primary to secondary LEAKAGE from 150 gallons per day (gpd) per steam generator and 1 gallon per minute (gpm) in the faulted steam generator. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT I-131 is assumed to be equal to the LCO 3.4.16, RCS Specific Activity, limits. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of GDC 19 (Ref. 2), and 10 CFR 100 (Ref. 3) or the NRC approved licensing basis.

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that SG tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the repair criteria be plugged in accordance with the Steam Generator Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging. If a tube was determined to satisfy the repair criteria but was not plugged, the tube may still have tube integrity.

(continued)

Watts Bar - Unit 2 B 3.4-97 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES LCO In the context of this Specification, an SG tube is defined as the entire (continued) length of the tube, including the tube wall, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.

The tube-to-tubesheet weld is not considered part of the tube.

An SG tube has tube integrity when it satisfies the SG performance criteria. The SG performance criteria are defined in Specification 5.7.2.12, Steam Generator Program, and describe acceptable SG tube performance. The Steam Generator Program also provides the evaluation process for determining conformance with the SG performance criteria.

There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. Failure to meet any one of these criteria is considered failure to meet the LCO.

The structural integrity performance criterion provides a margin of safety against tube burst or collapse under normal and accident conditions, and ensures structural integrity of the SG tubes under all anticipated transients included in the design specification. Tube burst is defined as, The gross structural failure of the tube wall. The condition typically corresponds to an unstable opening displacement (e.g., opening area increased in response to constant pressure) accompanied by ductile (plastic) tearing of the tube material at the ends of the degradation. Tube collapse is defined as, For the load displacement curve for a given structure, collapse occurs at the top of the load versus displacement curve where the slope of the curve becomes zero. The structural integrity performance criterion provides guidance on assessing loads that have a significant effect on burst or collapse. In that context, the term significant is defined as An accident loading condition other than differential pressure is considered significant when the addition of such loads in the assessment of the structural integrity performance criterion could cause a lower structural limit or limiting burst/collapse condition to be established. For tube integrity evaluations, except for circumferential degradation, axial thermal loads are classified as secondary loads. For circumferential degradation, the classification of axial thermal loads as primary or secondary loads will be evaluated on a case-by-case basis.

The division between primary and secondary classifications will be based on detailed analysis and/or testing.

(continued)

Watts Bar - Unit 2 B 3.4-98 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES LCO Structural integrity requires that the primary membrane stress intensity in (continued) a tube not exceed the yield strength for all ASME Code,Section III, Service Level A (normal operating conditions), and Service Level B (upset or abnormal conditions) transients included in the design specification.

This includes safety factors and applicable design basis loads based on ASME Code,Section III, Subsection NB (Ref. 4) and Draft Regulatory Guide 1.121 (Ref. 5).

The accident induced leakage performance criterion ensures that the primary to secondary LEAKAGE caused by a design basis accident, other than an SGTR, is within the accident analysis assumptions. The accident analysis assumes that accident induced leakage does not exceed 1 gpm in the faulted SG. The accident induced leakage rate includes any primary-to-secondary LEAKAGE existing prior to the accident in addition to primary-to-secondary LEAKAGE induced during the accident.

The operational LEAKAGE performance criterion provides an observable indication of SG tube conditions during plant operation. The limit on operational LEAKAGE is contained in LCO 3.4.13, RCS Operational LEAKAGE, and limits primary-to-secondary LEAKAGE through any one SG to 150 gallons per day. This limit is based on the assumption that a single crack leaking this amount would not propagate to an SGTR under the stress conditions of a LOCA or a main steam line break. If this amount of LEAKAGE is due to more than one crack, the cracks are very small, and the above assumption is conservative.

APPLICABILITY Steam generator tube integrity is challenged when the pressure differential across the tubes is large. Large differential pressures across SG tubes can only be experienced in MODE 1, 2, 3, or 4.

RCS conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2, 3, and 4. In MODES 5 and 6, primary-to-secondary differential pressure is low, resulting in lower stresses and reduced potential for LEAKAGE.

ACTIONS The ACTIONS are modified by a Note that the Conditions may be entered independently for each SG tube. This is acceptable because the Required Actions provide appropriate compensatory actions for each affected SG tube. Complying with the Required Actions may allow for continued operation, and subsequent affected SG tubes are governed by subsequent Condition entry, and application of associated Required Actions.

(continued)

Watts Bar - Unit 2 B 3.4-99 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES ACTIONS A.1 and A.2 (continued)

Condition A applies if it is discovered that one or more SG tubes examined in an inservice inspection satisfy the tube repair criteria but were not plugged in accordance with the Steam Generator Program as required by SR 3.4.17.2. An evaluation of SG tube integrity of the affected tube(s) must be made. Steam generator tube integrity is based on meeting the SG performance criteria described in the Steam Generator Program. The SG repair criteria define limits on SG tube degradation that allow for flaw growth between inspections while still providing assurance that the SG performance criteria will continue to be met. In order to determine if an SG tube that should have been plugged, has tube integrity, an evaluation must be completed that demonstrates that the SG performance criteria will continue to be met until the next refueling outage or SG tube inspection. The tube integrity determination is based on the estimated condition of the tube at the time the situation is discovered and the estimated growth of the degradation prior to the next SG tube inspection. If it is determined that tube integrity is not being maintained, Condition B applies.

A Completion Time of 7 days is sufficient to complete the evaluation while minimizing the risk of plant operation with a SG tube that may not have tube integrity.

If the evaluation determines that the affected tube(s) have tube integrity, Required Action A.2 allows plant operation to continue until the next refueling outage or SG inspection provided the inspection interval continues to be supported by an operational assessment that reflects the affected tubes. However, the affected tube(s) must be plugged prior to entering MODE 4 following the next refueling outage or SG inspection.

This Completion Time is acceptable since operation until the next inspection is supported by the operational assessment.

B.1 and B.2 If the Required Actions and associated Completion Times of Condition A are not met or if SG tube integrity is not being maintained, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

(continued)

Watts Bar - Unit 2 B 3.4-100 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES (continued)

SURVEILLANCE SR 3.4.17.1 REQUIREMENTS During shutdown periods the SGs are inspected as required by this SR and the Steam Generator Program. NEI 97-06, Steam Generator Program Guidelines (Ref. 1), and its referenced EPRI Guidelines, establish the content of the Steam Generator Program. Use of the Steam Generator Program ensures that the inspection is appropriate and consistent with accepted industry practices.

During SG inspections a condition monitoring assessment of the SG tubes is performed. The condition monitoring assessment determines the as found condition of the SG tubes. The purpose of the condition monitoring assessment is to ensure that the SG performance criteria have been met for the previous operating period.

The Steam Generator Program determines the scope of the inspection and the methods used to determine whether the tubes contain flaws satisfying the tube repair criteria. Inspection scope (i.e., which tubes or areas of tubing within the SG are to be inspected) is a function of existing and potential degradation locations. The Steam Generator Program also specifies the inspection methods to be used to find potential degradation.

Inspection methods are a function of degradation morphology, nondestructive examination (NDE) technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency of SR 3.4.17.1.

The Frequency is determined by the operational assessment and other limits in the SG examination guidelines (Ref. 6). The Steam Generator Program uses information on existing degradations and growth rates to determine an inspection Frequency that provides reasonable assurance that the tubing will meet the SG performance criteria at the next scheduled inspection. In addition, Specification 5.7.2.12 contains prescriptive requirements concerning inspection intervals to provide added assurance that the SG performance criteria will be met between scheduled inspections.

(continued)

Watts Bar - Unit 2 B 3.4-101 (developmental) A

SG TUBE INTEGRITY B 3.4.17 BASES SURVEILLANCE SR 3.4.17.2 REQUIREMENTS (continued) During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging.

The tube repair criteria delineated in Specification 5.7.2.12 are intended to ensure that tubes accepted for continued service satisfy the SG performance criteria with allowance for error in the flaw size measurement and for future flaw growth. In addition, the tube repair criteria, in conjunction with other elements of the Steam Generator Program, ensure that the SG performance criteria will continue to be met until the next inspection of the subject tube(s). Reference 1 provides guidance for performing operational assessments to verify that the tubes remaining in service will continue to meet the SG performance criteria.

The Frequency of prior to entering MODE 4 following an SG inspection ensures that the Surveillance has been completed and all tubes meeting the repair criteria are plugged prior to subjecting the SG tubes to significant primary-to-secondary pressure differential.

REFERENCES 1. NEI 97-06, Steam Generator Program Guidelines.

2. 10 CFR 50 Appendix A, GDC 19, Control Room.

3. 10 CFR 100, Reactor Site Criteria.

4. ASME Boiler and Pressure Vessel Code,Section III, Subsection NB.

5. Draft Regulatory Guide 1.121, Basis for Plugging Degraded Steam Generator Tubes, August 1976.

6. EPRI, Pressurized Water Reactor Steam Generator Examination Guidelines.

Watts Bar - Unit 2 B 3.4-102 (developmental) A

ML100550505

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