Text

Response to NRC Request for Additional Information Regarding TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294).
	ML103360003
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/29/2010
From:	Browning R, Croft W, Raidy T, Schrader K; B & W Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	WCAP-16294, TSTF-10-20
	Download: ML103360003 (185)
	v • d • e

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY November 29, 2010 TSTF-10-20 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to NRC Request for Additional Information Regarding TSTF-432, Revision 0, "Change in Technical Specifications End States (WCAP-16294)."

REFERENCE:

Letter from Barry W. Miller (NRC) to TSTF, "Acceptance for Review and Request for Additional Information for Traveler TSTF-432, Revision 0,

'Change in Technical Specifications End States (WCAP-16294)'," dated July 7, 2010.

Dear Sir or Madam:

In the referenced document, the NRC requested additional information to support the review of TSTF-432, Rev. 0, "Change in Technical Specifications End States (WCAP-16294)." Our response to the request is attached.

This letter supersedes a letter on the same subject submitted by the TSTF on September 28, 2010.

As noted in the letter from B. W. Miller (NRC) to TSTF dated July 7, 2010, the review of TSTF-432 has been granted an exemption from review fees.

Should you have any questions, please do not hesitate to contact us.

Kenneth J. Schrader (PWROG/W) Roy A. Browning (BWROG)

Thomas W. Raidy (PWROG/CE) Wendy E. Croft (PWROG/B&W)

Attachment Enclosure cc: Robert Elliott, Technical Specifications Branch, NRC Michelle Honcharik, Licensing Processes Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

TSTF Response to Letter from B. W. Miller (NRC) to Technical Specifications Task Force, "Acceptance for Review and Request for Additional Information for Traveler TSTF-432, Revision 0, 'Change in Technical Specifications End States (WCAP-16294),' (TAC No.

ME3469)," dated July 7, 2010 The Technical Specifications Task Force (TSTF) proposed changes to the Standard Technical Specifications (STS) NUREG-1431, "Standard Technical Specifications Westinghouse Plants,"

Revision 3.0. The proposed changes implement Risk-Informed Technical Specification Initiative 1, "Technical Specifications Actions End States Modification," in NUREG-1431. The NRC staff requests the following additional information from the TSTF to complete its review of the proposed Traveler TSTF-432.

Basis For Request for Additional Information #1 The NRCs final safety evaluation for Topical Report (TR) WCAP-16294-NP, Revision 0, "Risk-Informed Evaluation to Technical Specification Required Endstates for Westinghouse Nuclear Steam Supply System Pressurized Water Reactors," (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100770146) found the proposed revisions to the STS and Bases acceptable subject to the limitations and conditions shown in Section 4.0. Section 4.0 states, "Licensees requesting the TS changes to operate their plants in accordance with TR WCAP-16294-NP must include the following in the TS Bases to ensure that the implementation of this TR will be consistent with the NRC staffs evaluation:

1. The primary purpose for entry into Mode 4 end states is to accomplish short duration repairs to restore inoperable equipment.

2. The availability of the TDAFW pump is assured while the plant remains in Mode 4 in accordance with the assumption of the TR.

3. Operational procedures have been established to ensure long-term decay heat removal, should the SG cooling be lost while operating in Mode 4.

4. Include the NRC approved-TR as a reference in the TS Bases."

In the Submittal of TSTF-432, Revision 0, each Limiting Condition for Operation (LCO) with modified TS Required Action(s), to a new endstate of MODE 4, has a TS Bases reference to the NRC approved TR and the following paragraphs are added to the TS Bases Actions section:

"Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. ). In MODE 4 there are two means of decay heat removal, which provides diversity and defense in depth. However, voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not Page 1

TSTF Response to Letter from B. W. Miller (NRC) to Technical Specifications Task Force, "Acceptance for Review and Request for Additional Information for Traveler TSTF-432, Revision 0, 'Change in Technical Specifications End States (WCAP-16294),' (TAC No.

ME3469)," dated July 7, 2010 applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." These proposed TS Bases changes meet item 4 of the limitation and conditions section in the NRCs final safety evaluation for TR WCAP-16294-NP.

A reviewers note is added to the TS Bases LCO section in the auxiliary feedwater (AFW) system, TS 3.7.5.

Reviewers notes are useful to NRC reviewers and are available to all licensees. However, the NRC staff has a couple of concerns with the reviewers note. The first concern is the statements, "The requirement to maintain the TDAFW train available in order to remain in MODE 4 will be addressed by a licensing commitment to include a requirement that will be located in the Technical Specification Bases, a Licensee Controlled Document, or implementing procedures" and "The additional requirement to maintain the TDAFW train available in MODE 4 in accordance with WCAP-16294-NP-A, Rev. 1, may be included in this Bases or a reference to the location of this requirement (e.g., a specific location in the Technical Requirements Manual, other licensee controlled document, or the implementing procedure may be included in this Bases." The proposed statements in the reviewers note allow the licensee the option to place the requirement outside of the TS Bases, which is not consistent with the NRCs final safety evaluation. The NRCs final safety evaluation requires licensees requesting the TS changes to operate their plants in accordance with TR WCAP-16294-NP and must include in the TS Bases, the assurance of the Turbine Driven (TD) AFW pump availability while the plant remains in Mode 4.

The second concern is that the requirement is only being placed in the AFW system TS Bases and is not being placed in the TS Bases Actions section(s) for each modified required action. In order to utilize the Mode 4 endstate, a requirement must be established to maintain the TDAFW train available in MODE 4 and it is appropriate to place this requirement in the TS Bases Actions section(s) for each modified required action since it is applicable to each modified required action.

Request for Additional Information #1 Explain how the proposed TS Bases in Traveler TSTF-432 meet Section 4.0, "Limitations and Conditions," items 1, 2 and 3 in the NRC staffs final safety evaluation for TR WCAP-16294-NP.

Response to Request for Additional Information #1 TSTF-432 is revised to expand the Bases discussion of each modified Required Action to include the conditions in the Safety Evaluation for WCAP-16294-NP-A, Rev. 1. The revised first paragraph states:

"Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. ). In MODE 4 the Steam Generators and Page 2

TSTF Response to Letter from B. W. Miller (NRC) to Technical Specifications Task Force, "Acceptance for Review and Request for Additional Information for Traveler TSTF-432, Revision 0, 'Change in Technical Specifications End States (WCAP-16294),' (TAC No.

ME3469)," dated July 7, 2010 Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference ..., the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective."

The second paragraph is not affected.

The Reviewer's Note in the LCO Bases for Specification 3.7.5, "Auxiliary Feedwater," is deleted.

Page 3

WOG-164, Rev. 0 TSTF-432, Rev. 1 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Change in Technical Specifications End States (WCAP-16294)

NUREGs Affected: 1430 1431 1432 1433 1434 Classification 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Exempt Benefit: Shortens Outages See Attached.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: WOG Revision

Description:

Original Issue.

Owners Group Review Information Date Originated by OG: 25-Nov-09 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 14-Dec-09 TSTF Review Information TSTF Received Date: 25-Nov-09 Date Distributed for Review 14-Dec-09 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 22-Dec-09 NRC Review Information NRC Received Date: 22-Dec-09 NRC Comments:

In a letter dated July 7, 2010, the NRC provided a Request for Additional Information on TSTF-432.

Final Resolution: Superceded by Revision TSTF Revision 1 Revision Status: Active Revision Proposed by: NRC 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 TSTF Revision 1 Revision Status: Active Revision

Description:

In a letter dated July 7, 2010, the NRC provided a Request for Additional Information on TSTF-432. The NRC questioned why the conditions for applying the modified end state contained in the NRC's Safety Evaluation for WCAP-16294-NP-A, which provided the technical justification for TSTF-432, were not incorporated in the Traveler. In response, the TSTF made the following changes to TSTF-432:

1) The Reviewer's Note in the Bases for LCO 3.7.5 is deleted.

2) The Bases for each Required Action which allows the modified end state is revised to include the conditions from the WCAP-16294-NP-A Safety Evaluation.

Owners Group Review Information Date Originated by OG: 15-Nov-10 Owners Group Comments (No Comments)

Owners Group Resolution: Date:

TSTF Review Information TSTF Received Date: 15-Nov-10 Date Distributed for Review 15-Nov-10 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 29-Nov-10 NRC Review Information NRC Received Date: 29-Nov-10 Affected Technical Specifications Ref. 3.3.2 Bases ESFAS Instrumentation Action 3.3.2.B ESFAS Instrumentation Action 3.3.2.B Bases ESFAS Instrumentation Action 3.3.2.C ESFAS Instrumentation Action 3.3.2.C Bases ESFAS Instrumentation Action 3.3.2.D Bases ESFAS Instrumentation 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 Action 3.3.2.E Bases ESFAS Instrumentation Action 3.3.2.G Bases ESFAS Instrumentation Action 3.3.2.H Bases ESFAS Instrumentation Action 3.3.2.I Bases ESFAS Instrumentation Action 3.3.2.J Bases ESFAS Instrumentation Action 3.3.2.K ESFAS Instrumentation Action 3.3.2.K Bases ESFAS Instrumentation SR 3.3.2.2 Bases ESFAS Instrumentation SR 3.3.2.4 Bases ESFAS Instrumentation SR 3.3.2.5 Bases ESFAS Instrumentation SR 3.3.2.10 Bases ESFAS Instrumentation Ref. 3.3.7 Bases Control Room Emergency Filtration System Actuation Instrumentation Action 3.3.7.C Control Room Emergency Filtration System Actuation Instrumentation Action 3.3.7.C Bases Control Room Emergency Filtration System Actuation Instrumentation SR 3.3.7.5 Bases Control Room Emergency Filtration System Actuation Instrumentation SR 3.3.7.6 Bases Control Room Emergency Filtration System Actuation Instrumentation Ref. 3.3.8 Bases Fuel Building Air Cleanup System Actuation Instrumentation Action 3.3.8.D Fuel Building Air Cleanup System Actuation Instrumentation Action 3.3.8.D Bases Fuel Building Air Cleanup System Actuation Instrumentation Ref. 3.4.13 Bases RCS Operational Leakage Action 3.4.13.B RCS Operational Leakage Action 3.4.13.B Bases RCS Operational Leakage SR 3.4.13.2 Bases RCS Operational Leakage Ref. 3.4.14 Bases RCS Pressure Isolation Valve Leakage Action 3.4.14.B RCS Pressure Isolation Valve Leakage 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 Action 3.4.14.B Bases RCS Pressure Isolation Valve Leakage SR 3.4.14.1 Bases RCS Pressure Isolation Valve Leakage Ref. 3.4.15 Bases RCS Leakage Detection Instrumentation Action 3.4.15.E RCS Leakage Detection Instrumentation Action 3.4.15.E Bases RCS Leakage Detection Instrumentation Ref. 3.5.3 Bases Emergency Core Cooling System - Shutdown Change

Description:

Deleted Action 3.5.3.A Emergency Core Cooling System - Shutdown Action 3.5.3.A Bases Emergency Core Cooling System - Shutdown Action 3.5.3.B Emergency Core Cooling System - Shutdown Change

Description:

Deleted Action 3.5.3.B Bases Emergency Core Cooling System - Shutdown Change

Description:

Deleted Action 3.5.3.C Emergency Core Cooling System - Shutdown Change

Description:

Deleted Action 3.5.3.C Bases Emergency Core Cooling System - Shutdown Change

Description:

Deleted Ref. 3.5.4 Bases Refueling Water Storage Tank Action 3.5.4.C Refueling Water Storage Tank Action 3.5.4.C Bases Refueling Water Storage Tank Ref. 3.6.6B Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Ref. 3.6.6A Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Ref. 3.6.6C Bases Containment Spray System (Ice Condenser)

Ref. 3.6.6D Bases Quench Spray System (Subatmospheric)

Ref. 3.6.6E Bases Recirculation Spray System (Subatmospheric)

Action 3.6.6A.B Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6C.B Containment Spray System (Ice Condenser)

Action 3.6.6D.B Quench Spray System (Subatmospheric) 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 Action 3.6.6A.B Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6C.B Bases Containment Spray System (Ice Condenser)

Action 3.6.6D.B Bases Quench Spray System (Subatmospheric)

Action 3.6.6A.E Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6A.E Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6B.F Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6E.F Recirculation Spray System (Subatmospheric)

Action 3.6.6B.F Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Action 3.6.6E.F Bases Recirculation Spray System (Subatmospheric)

SR 3.6.6C.2 Bases Containment Spray System (Ice Condenser)

SR 3.6.6D.2 Bases Quench Spray System (Subatmospheric)

SR 3.6.6.4 Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

Ref. 3.6.6B.4 Bases Containment Spray and Cooling Systems (Atmospheric and Dual)

SR 3.6.6E.5 Bases Recirculation Spray System (Subatmospheric)

Ref. 3.6.7 Bases Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

Action 3.6.7.B Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

Action 3.6.7.B Bases Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

Ref. 3.6.11 Bases Iodine Cleanup System (Atmospheric and Subatmospheric)

Action 3.6.11.B Iodine Cleanup System (Atmospheric and Subatmospheric)

Action 3.6.11.B Bases Iodine Cleanup System (Atmospheric and Subatmospheric)

Ref. 3.6.12 Bases Vacuum Relief Valves (Atmospheric and Ice Condenser)

Action 3.6.12.B Vacuum Relief Valves (Atmospheric and Ice Condenser)

Action 3.6.12.B Bases Vacuum Relief Valves (Atmospheric and Ice Condenser) 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 SR 3.6.12.1 Bases Vacuum Relief Valves (Atmospheric and Ice Condenser)

Action 3.6.13.B Shield Building Air Cleanup System (Dual and Ice Condenser)

Action 3.6.13.B Bases Shield Building Air Cleanup System (Dual and Ice Condenser)

Ref. 3.6.14 Bases Air Return System (Ice Condenser)

Action 3.6.14.B Air Return System (Ice Condenser)

Action 3.6.14.B Bases Air Return System (Ice Condenser)

Ref. 3.6.18 Bases Containment Recirculation Drains (Ice Condenser)

Action 3.6.18.C Containment Recirculation Drains (Ice Condenser)

Action 3.6.18.C Bases Containment Recirculation Drains (Ice Condenser)

Ref. 3.7.7 Bases Component Cooling Water System Action 3.7.7.B Component Cooling Water System Action 3.7.7.B Bases Component Cooling Water System Ref. 3.7.8 Bases Service Water System Action 3.7.8.B Service Water System Action 3.7.8.B Bases Service Water System Ref. 3.7.9 Bases Ultimate Heat Sink Action 3.7.9.C Ultimate Heat Sink Action 3.7.9.C Bases Ultimate Heat Sink Ref. 3.7.10 Bases Control Room Emergency Filtration System Action 3.7.10.C Control Room Emergency Filtration System Action 3.7.10.C Bases Control Room Emergency Filtration System SR 3.7.10.3 Bases Control Room Emergency Filtration System SR 3.7.10.4 Bases Control Room Emergency Filtration System SR 3.7.10.10 Bases Control Room Emergency Filtration System Ref. 3.7.11 Bases Control Room Emergency Air Temperature Control System Action 3.7.11.B Control Room Emergency Air Temperature Control System Action 3.7.11.B Bases Control Room Emergency Air Temperature Control System 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 Ref. 3.7.12 Bases ECCS Pump Room Exhaust Air Cleanup System Action 3.7.12.C ECCS Pump Room Exhaust Air Cleanup System Action 3.7.12.C Bases ECCS Pump Room Exhaust Air Cleanup System SR 3.7.12.4 Bases ECCS Pump Room Exhaust Air Cleanup System Ref. 3.7.13 Bases Fuel Building Air Cleanup System Ref. 3.7.13 Bases Fuel Building Air Cleanup System Action 3.7.13.C Fuel Building Air Cleanup System Action 3.7.13.C Bases Fuel Building Air Cleanup System SR 3.7.13.3 Bases Fuel Building Air Cleanup System SR 3.7.13.4 Bases Fuel Building Air Cleanup System SR 3.7.13.5 Bases Fuel Building Air Cleanup System SR 3.7.13.5 Bases Fuel Building Air Cleanup System Ref. 3.7.14 Bases Penetration Room Exhaust Air Cleanup System Action 3.7.14.C Penetration Room Exhaust Air Cleanup System Action 3.7.14.C Bases Penetration Room Exhaust Air Cleanup System SR 3.7.14.3 Bases Penetration Room Exhaust Air Cleanup System SR 3.7.14.4 Bases Penetration Room Exhaust Air Cleanup System SR 3.7.14.5 Bases Penetration Room Exhaust Air Cleanup System Ref. 3.8.1 Bases AC Sources - Operating Action 3.8.1.G AC Sources - Operating Action 3.8.1.G Bases AC Sources - Operating SR 3.8.1.5 Bases AC Sources - Operating SR 3.8.1.6 Bases AC Sources - Operating SR 3.8.1.9 Bases AC Sources - Operating SR 3.8.1.10 Bases AC Sources - Operating SR 3.8.1.11 Bases AC Sources - Operating SR 3.8.1.14 Bases AC Sources - Operating 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-164, Rev. 0 TSTF-432, Rev. 1 SR 3.8.1.15 Bases AC Sources - Operating SR 3.8.1.16 Bases AC Sources - Operating SR 3.8.1.17 Bases AC Sources - Operating SR 3.8.1.18 Bases AC Sources - Operating SR 3.8.1.20 Bases AC Sources - Operating Ref. 3.8.4 Bases DC Sources - Operating Action 3.8.4.D DC Sources - Operating Action 3.8.4.D Bases DC Sources - Operating SR 3.8.4.1 Bases DC Sources - Operating SR 3.8.4.2 Bases DC Sources - Operating SR 3.8.4.3 Bases DC Sources - Operating Ref. 3.8.7 Bases Inverters - Operating Action 3.8.7.B Inverters - Operating Action 3.8.7.B Bases Inverters - Operating Ref. 3.8.9 Bases Distribution Systems - Operating Action 3.8.9.D Distribution Systems - Operating Action 3.8.9.D Bases Distribution Systems - Operating 29-Nov-10 Traveler Rev. 3. Copyright(C) 2010, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-432, Rev. 1 1.0 Description WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Tech Spec Required Action Endstates for Westinghouse NSSS PWRs," (Ref. 1) evaluated the endstates in which the Technical Specification Actions require the unit to be placed if the Required Actions and associated Completion Times are not met. WCAP-16294-NP was approved by the NRC on March 29, 2010. The Technical Specifications contained in NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 3 (Ref. 2), were reviewed to determine the proposed changes to the Required Action endstates. The endstates currently required by the Technical Specifications are defined based on transitioning the unit to a Mode or other specified condition in the Applicability in which the Technical Specification Limiting Condition for Operation (LCO) is not applicable. Mode 5 is the current endstate for LCOs that are applicable in Modes 1 through 4.

The risk of the transition from Mode 1 to Mode 4 or Mode 5 depends on the equipment that is operable. For example, the transition from Mode 4 to Mode 5 can introduce additional risk since it is required to realign the unit from steam generator cooling to residual heat removal, or shutdown cooling. During this realignment, there is an increased potential for loss of shutdown cooling and loss of inventory events, which is reflected in the plant risk calculated using Probabilistic Risk Assessment (PRA). In addition, decay heat removal following a loss of offsite power event in Mode 5 is dependent on Emergency AC power, whereas, in Mode 4 the turbine-driven auxiliary feedwater pump is available without relying on Emergency AC power. Therefore, transitioning to Mode 5 may not always be the appropriate endstate from a risk perspective.

WCAP-16294-NP-A, Rev. 1 evaluates and identifies the appropriate endstate for a number of Technical Specification Required Actions based on the risk of transitioning the unit from Mode 1 to the lower Modes. Mode 4 is justified as an acceptable alternate endstate to Mode 5.

A risk-informed approach, consistent with Regulatory Guides 1.174 and 1.177 (References 3 and 4, respectively) was used to perform the endstate evaluation. The risk associated with the transition from Mode 1 to Modes 4 and 5, and then returning to Mode 1 operation, is assessed both qualitatively and quantitatively. In addition to assessing the risk impact, the impacts on defense-in-depth and safety margins are also considered.

2.0 Proposed Changes The Technical Specification Required Action endstates evaluated for the endstate change are contained in NUREG-1431, "Standard Technical Specifications Westinghouse Plants" (Ref. 2). The Technical Specification number, title, Condition, and current endstate evaluated and the proposed endstate are provided in the following Table:

Page 1

TSTF-432, Rev. 1 Proposed Changes to Endstates Technical Specification # - Current Proposed Condition Title Endstate Endstate 3.3.2-B ESFAS Instrumentation 5 4 3.3.2-C ESFAS Instrumentation 5 4 3.3.2-K ESFAS Instrumentation 5 4 3.3.7-C Control Room Emergency Filtration System Actuation 5 4 Instrumentation 3.3.8-D Fuel Building Air Cleanup System Actuation 5 4 Instrumentation 3.4.13-B RCS Operational Leakage 5 4 3.4.14-B RCS Pressure Isolation Valve Leakage 5 4 3.4.15-E RCS Leakage Detection Instrumentation 5 4 3.5.3-A, B, C Emergency Core Cooling System - Shutdown 5 4 3.5.4-C Refueling Water Storage Tank 5 4 3.6.6A-B Containment Spray and Cooling Systems (Atmospheric and 5 4 Dual) 3.6.6A-E Containment Spray and Cooling Systems (Atmospheric and 5 4 Dual) 3.6.6B-F Containment Spray and Cooling Systems (Atmospheric and 5 4 Dual) 3.6.6C-B Containment Spray System (Ice Condenser) 5 4 3.6.6D-B Quench Spray System (Subatmospheric) 5 4 3.6.6E-F Recirculation Spray System (Subatmospheric) 5 4 3.6.7-B Spray Additive System (Atmospheric, Subatmospheric, Ice 5 4 Condenser, and Dual) 3.6.11-B Iodine Cleanup System (Atmospheric and Subatmospheric) 5 4 3.6.12-B Vacuum Relief Valves (Atmospheric and Ice Condenser) 5 4 3.6.13-B Shield Building Air Cleanup System (Dual and Ice 5 4 Condenser) 3.6.14-B Air Return System (Ice Condenser) 5 4 3.6.18-C Containment Recirculation Drains (Ice Condenser) 5 4 3.7.7-B Component Cooling Water System 5 4 3.7.8-B Service Water System 5 4 3.7.9-C Ultimate Heat Sink 5 4 3.7.10-C Control Room Emergency Filtration System 5 4 Page 2

TSTF-432, Rev. 1 Proposed Changes to Endstates Technical Specification # - Current Proposed Condition Title Endstate Endstate 3.7.11-B Control Room Emergency Air Temperature Control System 5 4 3.7.12-C ECCS Pump Room Exhaust Air Cleanup System 5 4 3.7.13-C Fuel Building Air Cleanup System 5 4 3.7.14-C Penetration Room Exhaust Air Cleanup System 5 4 3.8.1-G AC Sources - Operating 5 4 3.8.4-D DC Sources - Operating 5 4 3.8.7-B Inverters - Operating 5 4 3.8.9-D Distribution Systems - Operating 5 4 Consistent with the Required Action endstate changes listed above, the associated Bases of each affected Technical Specification are revised to reflect the new endstate and to add a brief discussion of why it is appropriate to remain within the Mode of Applicability of the associated LCO, as well as presenting assumptions from the analysis performed to justify the change.

The structure of Specification 3.5.3, "ECCS - Shutdown," is revised to implement the change in required end state. WCAP-16294-NP-A, Rev. 1, justified a change to Specification 3.5.3 to allow remaining in Mode 4 when the required ECCS High Head Safety Injection (HHSI) subsystem is inoperable. Specification 3.5.3 currently allows remaining in Mode 4 when the required ECCS Residual Heat Removal (RHR) subsystem is inoperable. TSTF-353 contained Condition A for an inoperable ECCS RHR subsystem and Conditions B and C for an inoperable ECCS HHSI subsystem. Conditions B and C are eliminated and Condition A is revised to apply to an inoperable ECCS train (RHR or HHSI), which applies a Mode 4 end state to any ECCS train inoperability.

3.0 Background As discussed in Regulatory Guide 1.177, (Ref. 4) acceptable reasons for requesting Technical Specification changes fall into one or more of the following categories:

Improvement to Operational Safety: A change to the Technical Specifications can be made due to reductions in the plant risk or a reduction in the occupational exposure of plant personnel in complying with the Technical Specification requirements.

Consistency with Risk Basis in Regulatory Requirements: Technical Specification requirements can be changed to reflect improved design features in a plant or to Page 3

TSTF-432, Rev. 1 reflect equipment reliability improvements that make a previous requirement unnecessarily stringent or ineffective. Technical Specifications may be changed to establish consistently based requirements across the industry or across an industry group.

Reduce Unnecessary Burdens: The change may be requested to reduce unnecessary burdens in complying with current Technical Specification requirements, based on operating history of the plant or industry in general. This includes extending completion times 1) that are too short to complete repairs when components fail with the plant at-power, 2) to complete additional maintenance activities at-power to reduce plant down time, and 3) to provide increased flexibility to plant operators.

The benefits of revising the Technical Specification Required Action endstates are related primarily to the first two categories.

With regard to operational safety, the risk of the transition from Mode 1 to Mode 4 is lower than the risk of the transition from Mode 1 to Mode 5. The additional mode transition (Mode 4 to Mode 5) involves re-aligning the unit from steam generator cooling to residual heat removal or shutdown cooling . This activity requires system alignment changes that can lead to loss of inventory events and loss of shutdown cooling in the PRA. In addition, in Mode 4, as opposed to Mode 5, additional systems are available for event mitigation that provide a reduced risk once the unit has transitioned to the required endstate. For example, for a loss of offsite power/station blackout (LOSP/SBO) event in the PRA, the turbine driven auxiliary feedwater pump will be available for decay heat removal in Mode 4. In Mode 5, this capability is not available.

Revising the Required Action endstate will also result in increasing unit availability by decreasing the time shutdown. The additional time required to transition to Mode 5 from Mode 4 when shutting down and also to Mode 4 from Mode 5 when restarting can be eliminated with the endstate change. A typical time for the transition from Mode 4 to Mode 5 during shutdown and from Mode 5 to 4 during startup is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . As such, this change will allow a time reduction of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

4.0 Technical Analysis The proposed endstate changes (described in Section 2.0 of this TSTF) are technically justified in WCAP-16294-A, Rev. 1 (Ref. 1).

5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Page 4

TSTF-432, Rev. 1

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

Response: No.

The proposed change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored. The requested technical specifications (TS) permit an end state of Mode 4 rather than an end state of Mode 5 contained in the current TS. In some cases, other Conditions and Required Actions are revised to implement the proposed change. Required Actions are not an initiator of any accident previously evaluated. Therefore, the proposed change does not affect the probability of any accident previously evaluated. The affected systems continued to be required to be operable by the Technical Specifications and the Completion Times specified in the Technical Specifications to restore equipment to operable status or take other remedial Actions remain unchanged. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Tech Spec Required Action Endstates for Westinghouse NSSS PWRs," demonstrates that the proposed change does not significantly increase the consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored. In some cases, other Conditions and Required Actions are revised to implement the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new requirements. The change does not alter assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored. In some cases, other Conditions and Required Page 5

TSTF-432, Rev. 1 Actions are revised to implement the proposed change. Remaining within the Applicability of the LCO is acceptable because WCAP-16294-NP-A demonstrates that the plant risk in MODE 4 is similar to or lower than MODE 5.

As a result, no margin of safety is significantly affected.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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

5.2 Applicable Regulatory Requirements/Criteria The proposed changes do not affect the design requirements or operability requirements of any plant system. The proposed changes involve changes to Technical Specification Required Actions for inoperable components or systems. 10 CFR 50.36 is the only applicable regulatory requirement.

10 CFR 50.36 contains requirements applicable to the content of plant Technical Specifications (e.g., the criteria for selecting systems, structures, or components that should be included in the Technical Specifications, and that appropriate surveillances be included, etc.) however 10 CFR 50.36 does not specify the Required Actions to be included for each Technical Specification. As such, the Technical Specifications affected by the proposed changes continue to meet the requirements contained in 10 CFR 50.36.

Therefore, the Technical Specifications affected by the proposed changes remain consistent with the requirements of 10 CFR 50.36.

Regulatory Guide (RG) 1.174, Rev. 1 and RG 1.177 (References 3 and 4) provide guidance for making Technical Specification changes using risk insights. The proposed risk-informed changes are consistent with the guidance provided in these Regulatory Guides .

In summary, the proposed changes do not involve any design changes or changes to the physical arrangement of components. The proposed changes only revise the current Technical Specification Required Actions and therefore continue to satisfy the requirements of 10 CFR 50.36 and the guidance contained in RG 1.174, Rev. 1 and RG 1.177 for changes to the Technical Specification. Therefore, the proposed changes do not adversely impact the design or performance characteristics of any components or systems.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed changes will not be inimical to the common defense and security or to the health and safety of the public.

Page 6

TSTF-432, Rev. 1 6.0 Environmental Considerations A review has determined that the proposed changes would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

7.0 References

1. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," dated June, 2010.

2. NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Rev. 3, March 2004.

3. Regulatory Guide 1.174, Rev. 1 "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," November 2002.

4. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," August 1998.

5. Letter from Thomas B. Blount (NRC) to Biff Bradley (NEI), "Final Safety Evaluation for Nuclear Energy Institute Topical Report WCAP-16294-NP, Revision 0, 'Risk-Informed Evaluation of Changes to Technical Specification Required Endstates for Westinghouse NSSS [Nuclear Steam Supply System]

PWRs [Pressurized Water Reactors]'," dated March 29, 2010.

Page 7

TSTF-432, Rev. 1 ESFAS Instrumentation 3.3.2 3.3 INSTRUMENTATION 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation LCO 3.3.2 The ESFAS instrumentation for each Function in Table 3.3.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.2-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in Table 3.3.2-1 required channels or for the channel(s) or trains inoperable. train(s).

B. One channel or train B.1 Restore channel or train to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inoperable. OPERABLE status.

OR B.2.1 Be in MODE 3. 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months AND B.2.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 84 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months WOG STS 3.3.2-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One train inoperable. --------------------NOTE-------------------

One train may be bypassed for up to [4] hours for surveillance testing provided the other train is OPERABLE.

C.1 Restore train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR C.2.1 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months AND C.2.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 6036 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months D. One channel inoperable. [ ------------------NOTE-------------------

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

REVIEWERS NOTE----------

The below Note should be used for plants with installed bypass test capability:

One channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing.

]

D.1 Place channel in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR WOG STS 3.3.2-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. One channel inoperable. [ ------------------NOTE-------------------

One additional channel may be bypassed for up to [4] hours for surveillance testing.

REVIEWERS NOTE----------

The below Note should be used for plants with installed bypass test capability:

One channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing.

]

K.1 Place channel in bypass. [6] hours OR K.2.1 Be in MODE 3. [12] hours AND K.2.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. [4218] hours L. One or more channels L.1 Verify interlock is in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. required state for existing unit condition.

OR L.2.1 Be in MODE 3. 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months AND L.2.2 Be in MODE 4. 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months WOG STS 3.3.2-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS Actuation Instrumentation 3.3.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.1.2 Enter applicable Conditions Immediately and Required Actions for one CREFS train made inoperable by inoperable CREFS actuation instrumentation.

OR B.2 Place both trains in Immediately emergency [radiation protection] mode.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Condition A AND or B not met in MODE 1, 2, 3, or 4. C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months D. Required Action and D.1 Suspend movement of Immediately associated Completion [recently] irradiated fuel Time for Condition A assemblies.

or B not met during movement of [recently]

irradiated fuel assemblies.

E. [ Required Action and E.1 Initiate action to restore one Immediately ]

associated Completion CREFS train to OPERABLE Time for Condition A status.

or B not met in MODE 5 or 6.

WOG STS 3.3.7-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS Actuation Instrumentation 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Suspend movement of Immediately associated Completion [recently] irradiated fuel Time for Condition A assemblies in the fuel or B not met during building.

movement of [recently]

irradiated fuel assemblies in the fuel building.

D. [ Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Condition A AND or B not met in MODE 1, 2, 3, or 4. D.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months ]

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.8-1 to determine which SRs apply for each FBACS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.8.2 Perform COT. 92 days SR 3.3.8.3 [ Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED TEST BASIS ]

SR 3.3.8.4 -------------------------------NOTE------------------------------

WOG STS 3.3.8-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a. No pressure boundary LEAKAGE,

b. 1 gpm unidentified LEAKAGE,

c. 10 gpm identified LEAKAGE, and

d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS operational A.1 Reduce LEAKAGE to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months LEAKAGE not within limits.

limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

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

B.2 -------------- NOTE -------------

OR LCO 3.0.4.a is not applicable when entering Pressure boundary MODE 4.

LEAKAGE exists. -------------------------------------

OR Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months Primary to secondary LEAKAGE not within limit.

WOG STS 3.4.13-1 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage 3.4.14 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 [ Isolate the high pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.

[or]

Restore RCS PIV to within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ]

limits.

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

B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months C. [ RHR System C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ]

autoclosure interlock penetration by use of one function inoperable. closed manual or deactivated automatic valve.

WOG STS 3.4.14-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. [ Required containment D.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable. radioactivity monitor to OPERABLE status.

AND OR Required containment air cooler condensate D.2 Restore required 30 days ]

flow rate monitor containment air cooler inoperable. condensate flow rate monitor to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months F. All required monitors F.1 Enter LCO 3.0.3. Immediately inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment atmosphere radioactivity monitor.

SR 3.4.15.2 Perform COT of the required containment 92 days atmosphere radioactivity monitor.

WOG STS 3.4.15-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS - Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS - Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

An RHR train may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned to the ECCS mode of operation.

APPLICABILITY: MODE 4.

ACTIONS

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

LCO 3.0.4.b is not applicable to ECCS high head subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. [ Required ECCS A.1 -------------- NOTE ------------- Immediately ]

residual heat removal LCO 3.0.4.a is not (RHR) subsystemtrain applicable when entering inoperable. MODE 4.

Initiate action to restore required ECCS RHR subsystemtrain to OPERABLE status.

B. Required ECCS [high B.1 Restore required ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months head subsystem] [high head subsystem] to inoperable. OPERABLE status.

C. Required Action and C.1 Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months associated Completion Time [of Condition B] not met.

WOG STS 3.5.3-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

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

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

limits.

OR RWST borated water temperature not within limits.

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

Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.5.4-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6A 3.6 CONTAINMENT SYSTEMS 3.6.6A Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System)

LCO 3.6.6A Two containment spray trains and [two] containment cooling trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. train to OPERABLE status.

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

B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 8454 hours0.0978 days 2.348 hours 0.014 weeks 0.00322 months C. One [required] C.1 Restore [required] 7 days containment cooling containment cooling train to train inoperable. OPERABLE status.

D. Two [required] D.1 Restore one [required] 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment cooling containment cooling train to trains inoperable. OPERABLE status.

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

WOG STS 3.6.6A-1 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6A CONDITION REQUIRED ACTION COMPLETION TIME E.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.6.6A-2 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual) 3.6.6B ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two [required] E.1 Restore one [required] 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment cooling containment cooling train to trains inoperable. OPERABLE status.

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

F.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months G. Any combination of three G.1 Enter LCO 3.0.3. Immediately or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6B.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.6B.2 Operate each [required] containment cooling train 31 days fan unit for 15 minutes.

SR 3.6.6B.3 Verify each [required] containment cooling train 31 days cooling water flow rate is [700] gpm.

WOG STS 3.6.6B-2 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray System (Ice Condenser) 3.6.6C 3.6 CONTAINMENT SYSTEMS 3.6.6C Containment Spray System (Ice Condenser)

LCO 3.6.6C Two containment spray trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment spray 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. train to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 8454 hours0.0978 days 2.348 hours 0.014 weeks 0.00322 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6C.1 Verify each containment spray manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.6C.2 Verify each containment spray pump's developed In accordance head at the flow test point is greater than or equal to with the Inservice the required developed head. Testing Program WOG STS 3.6.6C-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 QS System (Subatmospheric) 3.6.6D 3.6 CONTAINMENT SYSTEMS 3.6.6D Quench Spray (QS) System (Subatmospheric)

LCO 3.6.6D Two QS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One QS train inoperable. A.1 Restore QS train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6D.1 Verify each QS manual, power operated, and 31 days automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.6D.2 Verify each QS pump's developed head at the flow In accordance test point is greater than or equal to the required with the Inservice developed head. Testing Program WOG STS 3.6.6D-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RS System (Subatmospheric) 3.6.6E 3.6 CONTAINMENT SYSTEMS 3.6.6E Recirculation Spray (RS) System (Subatmospheric)

LCO 3.6.6E Four RS subsystems [and a casing cooling tank] shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RS subsystem A.1 Restore RS subsystem to 7 days inoperable. OPERABLE status.

B. Two RS subsystems B.1 Restore one RS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable in one train. to OPERABLE status.

C. [ Two inside RS C.1 Restore one RS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ]

subsystems inoperable. to OPERABLE status.

D. [ Two outside RS D.1 Restore one RS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ]

subsystems inoperable. to OPERABLE status.

E. [ Casing cooling tank E.1 Restore casing cooling tank 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ]

inoperable. to OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND F.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 8454 hours0.0978 days 2.348 hours 0.014 weeks 0.00322 months WOG STS 3.6.6E-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual) 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

LCO 3.6.7 The Spray Additive System shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spray Additive System A.1 Restore Spray Additive 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. System to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 84 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each spray additive manual, power operated, 31 days and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

SR 3.6.7.2 Verify spray additive tank solution volume is 184 days

[2568] gal and [4000] gal.

WOG STS 3.6.7-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ICS (Atmospheric and Subatmospheric) 3.6.11 3.6 CONTAINMENT SYSTEMS 3.6.11 Iodine Cleanup System (ICS) (Atmospheric and Subatmospheric)

LCO 3.6.11 Two ICS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ICS train A.1 Restore ICS train to 7 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.11.1 Operate each ICS train for [ 10 continuous hours 31 days with heaters operating or (for systems without heaters) 15 minutes].

SR 3.6.11.2 Perform required ICS filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.11.3 Verify each ICS train actuates on an actual or [18] months WOG STS 3.6.11-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Vacuum Relief Valves (Atmospheric and Ice Condenser) 3.6.12 3.6 CONTAINMENT SYSTEMS 3.6.12 Vacuum Relief Valves (Atmospheric and Ice Condenser)

LCO 3.6.12 [Two] vacuum relief lines shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One vacuum relief line A.1 Restore vacuum relief line 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.12.1 Verify each vacuum relief line is OPERABLE in In accordance accordance with the Inservice Testing Program. with the Inservice Testing Program WOG STS 3.6.12-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SBACS (Dual and Ice Condenser) 3.6.13 3.6 CONTAINMENT SYSTEMS 3.6.13 Shield Building Air Cleanup System (SBACS) (Dual and Ice Condenser)

LCO 3.6.13 Two SBACS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SBACS train A.1 Restore SBACS train to 7 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.13.1 Operate each SBACS train for [ 10 continuous 31 days hours with heaters operating or (for systems without heaters) 15 minutes].

SR 3.6.13.2 Perform required SBACS filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.13.3 Verify each SBACS train actuates on an actual or [18] months WOG STS 3.6.13-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ARS (Ice Condenser) 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Air Return System (ARS) (Ice Condenser)

LCO 3.6.14 Two ARS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ARS train A.1 Restore ARS train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify each ARS fan starts on an actual or simulated [92] days actuation signal, after a delay of [9.0] minutes and

[11.0] minutes, and operates for 15 minutes.

SR 3.6.14.2 Verify, with the ARS fan dampers closed, each ARS 92 days fan motor current is [20.5] amps and [35.5] amps

[when the fan speed is [840] rpm and [900] rpm].

WOG STS 3.6.14-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Recirculation Drains (Ice Condenser) 3.6.18 3.6 CONTAINMENT SYSTEMS 3.6.18 Containment Recirculation Drains (Ice Condenser)

LCO 3.6.18 The ice condenser floor drains and the refueling canal drains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser floor A.1 Restore ice condenser floor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months drain inoperable. drain to OPERABLE status.

B. One refueling canal B.1 Restore refueling canal 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months drain inoperable. drain to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.6.18-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train A.1 --------------NOTE--------------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for residual heat removal loops made inoperable by CCW.

Restore CCW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

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

B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.7.7-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SWS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Service Water System (SWS)

LCO 3.7.8 Two SWS trains shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SWS train A.1 --------------NOTES-------------

inoperable. 1. Enter applicable and Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by SWS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops

- MODE 4," for residual heat removal loops made inoperable by SWS.

Restore SWS train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

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

B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.7.8-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [ One or more cooling A.1 Restore cooling tower 7 days ]

towers with one cooling fan(s) to OPERABLE tower fan inoperable. status.

REVIEWER'S NOTE----- B.1 Verify water temperature of Once per hour]

The [ ]°F is the maximum the UHS is [90]°F allowed UHS temperature averaged over the previous value and is based on 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.

B. [ Water temperature of the UHS > [90]°F and

[ ]°F.

C. [ Required Action C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time of AND Condition A or B not met. C.2 -------------- NOTE -------------

LCO 3.0.4.a is not OR ] applicable when entering MODE 4.

UHS inoperable [for -------------------------------------

reasons other than Condition A or B]. Be in MODE 54. 3612 hours0.0418 days 1.003 hours 0.00597 weeks 0.00137 months WOG STS 3.7.9-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Filtration System (CREFS)

LCO 3.7.10 Two CREFS trains shall be OPERABLE.

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

The control room boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6],

During movement of [recently] irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREFS train A.1 Restore CREFS train to 7 days inoperable. OPERABLE status.

B. Two CREFS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODE 1, 2, 3, or 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months WOG STS 3.7.10-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)

LCO 3.7.11 Two CREATCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6],

During movement of [recently] irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREATCS train A.1 Restore CREATCS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4. B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Required Action and C.1 Place OPERABLE Immediately associated Completion CREATCS train in Time of Condition A not operation.

met [in MODE 5 or 6, or]

during movement of OR

[recently] irradiated fuel assemblies. C.2 Suspend movement of Immediately

[recently] irradiated fuel assemblies.

D. Two CREATCS trains D.1 Suspend movement of Immediately inoperable [in MODE 5 [recently] irradiated fuel or 6, or] during assemblies.

movement of [recently]

irradiated fuel WOG STS 3.7.11-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS PREACS 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)

LCO 3.7.12 Two ECCS PREACS trains shall be OPERABLE.

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

The ECCS pump room boundary may be opened intermittently under administrative control.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ECCS PREACS A.1 Restore ECCS PREACS 7 days train inoperable. train to OPERABLE status.

B. Two ECCS PREACS B.1 Restore ECCS pump room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trains inoperable due to boundary to OPERABLE inoperable ECCS pump status.

room boundary.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months WOG STS 3.7.12-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS 3.7.13 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [ Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 -------------- NOTE -------------

LCO 3.0.4.a is not OR applicable when entering MODE 4.

Two FBACS trains -------------------------------------

inoperable in MODE 1, 2, 3, or 4 for reasons Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ]

other than Condition B.

D. Required Action and D.1 Place OPERABLE FBACS Immediately associated Completion train in operation.

Time [of Condition A] not met during movement of OR

[recently] irradiated fuel assemblies in the fuel D.2 Suspend movement of Immediately building. [recently] irradiated fuel assemblies in the fuel building.

E. Two FBACS trains E.1 Suspend movement of Immediately inoperable during [recently] irradiated fuel movement of [recently] assemblies in the fuel irradiated fuel building.

assemblies in the fuel building.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each FBACS train for [ 10 continuous 31 days hours with the heaters operating or (for systems without heaters) 15 minutes].

WOG STS 3.7.13-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 PREACS 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Penetration Room Exhaust Air Cleanup System (PREACS)

LCO 3.7.14 Two PREACS trains shall be OPERABLE.

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

The penetration room boundary may be opened intermittently under administrative control.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One PREACS train A.1 Restore PREACS train to 7 days inoperable. OPERABLE status.

B. Two PREACS trains B.1 Restore penetration room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable penetration status.

room boundary.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY WOG STS 3.7.14-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

REVIEWERS NOTE----- F.1 Restore [required] [12] hours ]

This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status.

such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.

F. [ One [required]

[automatic load sequencer] inoperable.

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

G.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated 7 days power availability for each [required] offsite circuit.

WOG STS 3.8.1-4 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger[s on one train] voltage to greater than or inoperable. equal to the minimum established float voltage.

AND A.2 Verify battery float current Once per [12] hours

[2] amps.

AND A.3 Restore battery charger[s] 7 days to OPERABLE status.

[B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ]

on one train] inoperable. OPERABLE status.

C. One DC electrical power C.1 Restore DC electrical [2] hours subsystem inoperable power subsystem to for reasons other than OPERABLE status.

Condition A [or B].

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time not met. AND D.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering WOG STS 3.8.4-1 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 DC Sources - Operating 3.8.4 CONDITION REQUIRED ACTION COMPLETION TIME MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months WOG STS 3.8.4-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Inverters - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 -------------- NOTE -------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54. 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, [frequency], and 7 days alignment to required AC vital buses.

WOG STS 3.8.7-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 -------------- NOTE ------------- 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 54.

E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

WOG STS 3.8.9-2 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

In the event a channel's Trip Setpoint is found nonconservative with respect to the Allowable Value, or the transmitter, instrument Loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection Function(s) affected. When the Required Channels in Table 3.3.2-1 are specified (e.g., on a per steam line, per loop, per SG, etc., basis), then the Condition may be entered separately for each steam line, loop, SG, etc., as appropriate.

When the number of inoperable channels in a trip function exceed those specified in one or other related Conditions associated with a trip function, then the unit is outside the safety analysis. Therefore, LCO 3.0.3 should be immediately entered if applicable in the current MODE of operation.

REVIEWERS NOTE------------------------------------------

Certain LCO Completion Times are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Completion Times as required by the staff Safety Evaluation Report (SER) for the topical report.

A.1 Condition A applies to all ESFAS protection functions.

Condition A addresses the situation where one or more channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.2-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.

B.1, B.2.1, and B.2.2 Condition B applies to manual initiation of:

SI,

Containment Spray,

Phase A Isolation, and

Phase B Isolation.

WOG STS B 3.3.2-38 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

This action addresses the train orientation of the SSPS for the functions listed above. If a channel or train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to return it to an OPERABLE status. Note that for containment spray and Phase B isolation, failure of one or both channels in one train renders the train inoperable. Condition B, therefore, encompasses both situations.

The specified Completion Time is reasonable considering that there are two automatic actuation trains and another manual initiation train OPERABLE for each Function, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months total time) and in MODE 5 4 within an additional 30 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (84 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months total time).

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

C.1, C.2.1, and C.2.2 Condition C applies to the automatic actuation logic and actuation relays for the following functions:

WOG STS B 3.3.2-39 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2

SI,

Containment Spray,

Phase A Isolation,

Phase B Isolation, and

Automatic Switchover to Containment Sump.

This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for restoring the inoperable train to OPERABLE status is justified in Reference 89. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. This is done by placing the unit in at least MODE 3 within WOG STS B 3.3.2-40 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued) an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months total time) and in MODE 5 4 within an additional 30 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (60 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months total time).

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

The Required Actions are modified by a Note that allows one train to be bypassed for up to [4] hours for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 910) that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the average time required to perform train surveillance.

D.1, D.2.1, and D.2.2 Condition D applies to:

Containment Pressure - High 1,

Pressurizer Pressure - Low (two, three, and four loop units),

Steam Line Pressure - Low, WOG STS B 3.3.2-41 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2

Steam Line Differential Pressure - High,

High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low or Coincident With Steam Line Pressure - Low,

Containment Pressure - High 2,

Steam Line Pressure - Negative Rate - High,

High Steam Flow Coincident With Safety Injection Coincident With Tavg - Low Low,

High High Steam Flow Coincident With Safety Injection,

High Steam Flow in Two Steam Lines Coincident With Tavg - Low Low,

SG Water level - Low Low (two, three, and four loop units), and

[SG Water level - High High (P-14) (two, three, and four loop units). ]

WOG STS B 3.3.2-42 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

If one channel is inoperable, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Generally this Condition applies to functions that operate on two-out-of-three logic.

Therefore, failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements.

The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed to restore the channel to OPERABLE status or to place it in the tripped condition is justified in Reference 89.

Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.

[ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for testing, are justified in Reference 89.

]

REVIEWERS NOTE------------------------------------------

The below text should be used for plants with installed bypass test capability:

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance testing. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit is justified in Reference 89.

E.1, E.2.1, and E.2.2 Condition E applies to:

Containment Spray Containment Pressure - High 3 (High, High) (two, three, and four loop units), and

Containment Phase B Isolation Containment Pressure - High 3 (High, High).

WOG STS B 3.3.2-43 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

None of these signals has input to a control function. Thus, two-out-of-three logic is necessary to meet acceptable protective requirements.

However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of-four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion. Furthermore, with one channel bypassed, a single instrumentation channel failure will not spuriously initiate containment spray.

To avoid the inadvertent actuation of containment spray and Phase B containment isolation, the inoperable channel should not be placed in the tripped condition. Instead it is bypassed. Restoring the channel to OPERABLE status, or placing the inoperable channel in the bypass condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , is sufficient to assure that the Function remains OPERABLE and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The Completion Time is further justified based on the low probability of an event occurring during this interval. Failure to restore the inoperable channel to OPERABLE status, or place it in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the next 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 4, these Functions are no longer required OPERABLE.

[ The Required Actions are modified by a Note that allows one additional channel to be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing.

Placing a second channel in the bypass condition for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for testing purposes is acceptable based on the results of Reference 89. ]

REVIEWERS NOTE------------------------------------------

The below text should be used for plants with installed bypass test capability:

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance testing. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit is justified in Reference 89.

WOG STS B 3.3.2-44 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

F.1, F.2.1, and F.2.2 Condition F applies to:

Manual Initiation of Steam Line Isolation,

Loss of Offsite Power,

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure -

Low, and

P-4 Interlock.

For the Manual Initiation and the P-4 Interlock Functions, this action addresses the train orientation of the SSPS. For the Loss of Offsite Power Function, this action recognizes the lack of manual trip provision for a failed channel. For the AFW System pump suction transfer channels, this action recognizes that placing a failed channel in trip during operation is not necessarily a conservative action.

Spurious trip of this function could align the AFW System to a source that is not immediately capable of supporting pump suction. If a train or channel is inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to return it to OPERABLE status. The specified Completion Time is reasonable considering the nature of these Functions, the available redundancy, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems. In MODE 4, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.

G.1, G.2.1, and G.2.2 Condition G applies to the automatic actuation logic and actuation relays for the Steam Line Isolation [,Turbine Trip and Feedwater Isolation,] and AFW actuation Functions.

WOG STS B 3.3.2-45 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

The action addresses the train orientation of the SSPS and the master and slave relays for these functions. If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for restoring the inoperable train to OPERABLE status is justified in Reference 89. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPERABLE status, the unit must be brought to MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.

The Required Actions are modified by a Note that allows one train to be bypassed for up to [4] hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 910) assumption that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the average time required to perform channel surveillance.

[ H.1 and H.2 Condition H applies to the automatic actuation logic and actuation relays for the Turbine Trip and Feedwater Isolation Function.

This action addresses the train orientation of the SSPS and the master and slave relays for this Function. If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status or the unit must be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for restoring the inoperable train to OPERABLE status is justified in Reference 89. The Completion Time for restoring a train to OPERABLE status is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. 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 from full power conditions in an orderly manner and without challenging unit systems. These Functions are no longer required in MODE 3. Placing the unit in MODE 3 removes all requirements for OPERABILITY of the protection channels and actuation functions. In this MODE, the unit does not have analyzed transients or conditions that require the explicit use of the protection functions noted above.

WOG STS B 3.3.2-46 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

The Required Actions are modified by a Note that allows one train to be bypassed for up to [4] hours for surveillance testing provided the other train is OPERABLE. This allowance is based on the reliability analysis (Ref. 910) assumption that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the average time required to perform channel surveillance. ]

I.1 and I.2 Condition I applies to:

[ SG Water Level - High High (P-14) (two, three, and four loop units),

and ]

Undervoltage Reactor Coolant Pump.

If one channel is inoperable, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are allowed to restore one channel to OPERABLE status or to place it in the tripped condition. If placed in the tripped condition, the Function is then in a partial trip condition where one-out-of-two or one-out-of-three logic will result in actuation. Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months requires the unit to be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, these Functions are no longer required OPERABLE.

[ The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to [12] hours for surveillance testing of other channels. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for a second channel to be in the bypassed condition for testing, are justified in Reference 89. ]

REVIEWERS NOTE------------------------------------------

The below text should be used for plants with installed bypass test capability:

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance testing. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for a second channel to be in the bypassed condition for testing, are justified in Reference 89.

WOG STS B 3.3.2-47 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued)

J.1 and J.2 Condition J applies to the AFW pump start on trip of all MFW pumps.

88This action addresses the train orientation of the SSPS for the auto start function of the AFW System on loss of all MFW pumps. The OPERABILITY of the AFW System must be assured by allowing automatic start of the AFW System pumps. If a channel is inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months are allowed to return it to an OPERABLE status. If the function cannot be returned to an OPERABLE status, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to place the unit in MODE 3. 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 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The allowance of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to return the train to an OPERABLE status is justified in Reference 910.

K.1, K.2.1, and K.2.2 Condition K applies to:

RWST Level - Low Low Coincident with Safety Injection, and

RWST Level - Low Low Coincident with Safety Injection and Coincident with Containment Sump Level - High.

RWST Level - Low Low Coincident With SI and Coincident With Containment Sump Level - High provides actuation of switchover to the containment sump. Note that this Function requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. However, placing a failed channel in the tripped condition could result in a premature switchover to the sump, prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in bypass results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within [6] hours is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assuming the WOG STS B 3.3.2-48 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES ACTIONS (continued) inoperable channel has failed high). The [6] hour Completion Time is justified in Reference 1011. If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the unit must be brought toplaced in a MODE in which overall plant risk is reduced. This is done by placing the unit in at least MODE 3 within the following [6] hours and MODE 5 4 within the next 30 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action K.2.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.

[ The Required Actions are modified by a Note that allows placing a second channel in the bypass condition for up to [4] hours for surveillance testing. The total of [12] hours to reach MODE 3 and [4] hours for a second channel to be bypassed is acceptable based on the results of Reference 1011.]

REVIEWERS NOTE------------------------------------------

The below text should be used for plants with installed bypass test capability:

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance WOG STS B 3.3.2-49 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 testing. The channel to be tested can be tested in bypass with the inoperable channel also in bypass. The total of [12] hours to reach MODE 3 and [4] hours for a second channel to be bypassed is acceptable based on the results of Reference 1011.

L.1, L.2.1, and L.2.2 Condition L applies to the P-11 and P-12 [and P-14] interlocks.

With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

WOG STS B 3.3.2-50 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE ----------------------------REVIEWERS NOTE------------------------------------------

REQUIREMENTS In Table 3.3.2-1, Functions 7.b and 7.c were not included in the generic evaluations approved in either WCAP-10271, as supplemented, or WCAP-14333. In order to apply the WCAP-10271, as supplemented, and WCAP-14333 TS relaxations to plant specific Functions not evaluated generically, licensees must submit plant specific evaluations for NRC review and approval.

The SRs for each ESFAS Function are identified by the SRs column of Table 3.3.2-1.

A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.

Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined.

Similarly, train A and train B must be examined when testing channel II, channel III, and channel IV (if applicable). The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.

REVIEWERS NOTE-----------------------------------------

Certain Frequencies are based on approved topical reports. In order for a licensee to use these times, the licensee must justify the Frequencies as required by the staff SER for the topical report.

SR 3.3.2.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

WOG STS B 3.3.2-51 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and reliability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3.3.2.2 SR 3.3.2.2 is the performance of an ACTUATION LOGIC TEST. The SSPS is tested every 92 days on a STAGGERED TEST BASIS, using the semiautomatic tester. The train being tested is placed in the bypass condition, thus preventing inadvertent actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and that there is an intact voltage signal path to the master relay coils. The Frequency of every 92 days on a STAGGERED TEST BASIS is justified in Reference 1112.

SR 3.3.2.3 SR 3.3.2.3 is the performance of an ACTUATION LOGIC TEST as described in SR 3.3.2.2, except that the semiautomatic tester is not used and the continuity check does not have to be performed, as explained in the Note. This SR is applied to the balance of plant actuation logic and relays that do not have the SSPS test circuits installed to utilize the semiautomatic tester or perform the continuity check. This test is also performed every 31 days on a STAGGERED TEST BASIS. The Frequency is adequate based on industry operating experience, considering instrument reliability and operating history data.

WOG STS B 3.3.2-52 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.4 SR 3.3.2.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. This test is performed every 92 days on a STAGGERED TEST BASIS. The time allowed for the testing (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) is justified in Reference 1112. The Frequency of 92 days is justified in Reference 910.

SR 3.3.2.5 SR 3.3.2.5 is the performance of a COT.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.1-1. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as found" and "as left" values must also be recorded and reviewed for consistency with the assumptions of Reference 6.

The Frequency of 184 days is justified in Reference 1112.

WOG STS B 3.3.2-53 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation MODE is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation MODE is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing the slave relay.

This test is performed every [92] days. The Frequency is adequate, based on industry operating experience, considering instrument reliability and operating history data.

SR 3.3.2.7 SR 3.3.2.7 is the performance of a TADOT every [92] days. This test is a check of the Loss of Offsite Power, Undervoltage RCP, and AFW Pump Suction Transfer on Suction Pressure - Low Functions. Each Function is tested up to, and including, the master transfer relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The test also includes trip devices that provide actuation signals directly to the SSPS. The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are verified during CHANNEL CALIBRATION. The Frequency is adequate. It is based on industry operating experience, considering instrument reliability and operating history data.

WOG STS B 3.3.2-54 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.8 SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions and AFW pump start on trip of all MFW pumps. It is performed every [18] months. Each Manual Actuation Function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In some instances, the test includes actuation of the end device (i.e., pump starts, valve cycles, etc.). The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints.

SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.

A CHANNEL CALIBRATION is performed every [18] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Frequency of [18] months is based on the assumption of an

[18] month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

WOG STS B 3.3.2-55 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.10 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time testing acceptance criteria are included in the Technical Requirements Manual, Section 15 (Ref. 1213). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g.,

pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire response time is measured.

REVIEWERS NOTE-----------------------------------------

Applicable portions of the following Bases are applicable for plants adopting WCAP-13632-P-A (Ref. 910). and/or WCAP-14036-P (Ref.

1011).

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 1314) dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

WOG STS B 3.3.2-56 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 1415) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.

The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

ESF RESPONSE TIME tests are conducted on an [18] month STAGGERED TEST BASIS. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time verification of these devices every [18] months. The [18] month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching [1000] psig in the SGs.

SR 3.3.2.11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.8, except that it is performed for the P-4 Reactor Trip Interlock, and the Frequency is once per RTB cycle. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the RTB is cycled.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

WOG STS B 3.3.2-57 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES REFERENCES 1. FSAR, Chapter [6].

2. FSAR, Chapter [7].

3. FSAR, Chapter [15].

4. IEEE-279-1971.

5. 10 CFR 50.49.

6. Plant-specific setpoint methodology study.

7. NUREG-1218, April 1988.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

89. WCAP-14333-P-A, Rev. 1, October 1998.

910.WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

1011. [Plant specific evaluation reference.]

1112. WCAP-15376, Rev. 0. October 2000.

1213. Technical Requirements Manual, Section 15, "Response Times."

1314. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.

1415. WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995.

WOG STS B 3.3.2-58 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS Actuation Instrumentation B 3.3.7 BASES ACTIONS (continued)

C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicableoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 1, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

D.1 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met when [recently]

irradiated fuel assemblies are being moved. Movement of [recently]

irradiated fuel assemblies must be suspended immediately to reduce the risk of accidents that would require CREFS actuation.

WOG STS B 3.3.7-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.4 SR 3.3.7.4 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. This test is performed every 31 days on a STAGGERED TEST BASIS. The Frequency is acceptable based on instrument reliability and industry operating experience.

[ SR 3.3.7.5 SR 3.3.7.5 is the performance of an ACTUATION LOGIC TEST. The train being tested is placed in the bypass condition, thus preventing inadequate actuation. Through the semiautomatic tester, all possible logic combinations, with and without applicable permissives, are tested for each protection function. In addition, the master relay coil is pulse tested for continuity. This verifies that the logic modules are OPERABLE and there is an intact voltage signal path to the master relay coils. This test is performed ever 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 12.

The SR is modified by a Note stating that the Surveillance is only applicable to the actuation logic of the ESFAS Instrumentation. ]

[ SR 3.3.7.6 SR 3.3.7.6 is the performance of a MASTER RELAY TEST. The MASTER RELAY TEST is the energizing of the master relay, verifying contact operation and a low voltage continuity check of the slave relay coil. Upon master relay contact operation, a low voltage is injected to the slave relay coil. This voltage is insufficient to pick up the slave relay, but large enough to demonstrate signal path continuity. This test is performed every 92 days on a STAGGERED TEST BASIS. The Surveillance interval is justified in Reference 12.

The SR is modified by a Note stating that the Surveillance is only applicable to the master relays of the ESFAS Instrumentation. ]

WOG STS B 3.3.7-8 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS Actuation Instrumentation B 3.3.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.9 A CHANNEL CALIBRATION is performed every [18] months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.

REFERENCES 1. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

12. WCAP-15376, Rev. 0, October 2000.

WOG STS B 3.3.7-10 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS Actuation Instrumentation B 3.3.8 BASES ACTIONS (continued)

C.1 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and [recently]

irradiated fuel assemblies are being moved in the fuel building.

Movement of [recently] irradiated fuel assemblies in the fuel building must be suspended immediately to eliminate the potential for events that could require FBACS actuation.

D.1 and D.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicableoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.3.8-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS Actuation Instrumentation B 3.3.8 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3.3.8.2 A COT is performed once every 92 days on each required channel to ensure the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This test verifies the capability of the instrumentation to provide the FBACS actuation. The setpoints shall be left consistent with the unit specific calibration procedure tolerance. The Frequency of 92 days is based on the known reliability of the monitoring equipment and has been shown to be acceptable through operating experience.

SR 3.3.8.3

[ SR 3.3.8.3 is the performance of an ACTUATION LOGIC TEST. The actuation logic is tested every 31 days on a STAGGERED TEST BASIS.

All possible logic combinations, with and without applicable permissives, are tested for each protection function. The Frequency is based on the known reliability of the relays and controls and the multichannel redundancy available, and has been shown to be acceptable through operating experience. ]

SR 3.3.8.4 SR 3.3.8.4 is the performance of a TADOT. This test is a check of the manual actuation functions and is performed every [18] months. Each manual actuation function is tested up to, and including, the master relay coils. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical WOG STS B 3.3.8-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RCS Operational LEAKAGE B 3.4.13 BASES APPLICABILITY (continued)

LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leak tight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified 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 limit, or if unidentified 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 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 54, the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

WOG STS B 3.4.13-4 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS Operational LEAKAGE B 3.4.13 Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

WOG STS B 3.4.13-5 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE REQUIREMENTS (continued)

The RCS water inventory balance must be met with the reactor at steady state operating conditions (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, [and RCP seal injection and return flows]). The Surveillance is modified by two 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 since 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 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.

SR 3.4.13.2 This SR verifies that primary to secondary LEAKAGE is less 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 3.4.20, "Steam Generator Tube Integrity," should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 56. 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.

WOG STS B 3.4.13-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS Operational LEAKAGE B 3.4.13 BASES SURVEILLANCE REQUIREMENTS (continued)

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 the EPRI guidelines (Ref. 56).

REFERENCES 1. 10 CFR 50, Appendix A, GDC 30.

2. Regulatory Guide 1.45, May 1973.

3. FSAR, Section [15].

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

5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

56. EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."

WOG STS B 3.4.13-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage B 3.4.14 BASES LCO (continued)

Reference 7 8 permits leakage testing at a lower pressure differential than 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 by two valves. Required Actions A.1 and A.2 are modified by a Note that the valves used for isolation must meet the same leakage requirements as the PIVs and must be within the RCPB [or the high pressure portion of the system].

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 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time allows the actions and restricts the operation with leaking isolation valves.

WOG STS B 3.4.14-3 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage B 3.4.14 BASES ACTIONS (continued)

[ Required Action A.2 specifies that the double isolation barrier of two valves be restored by closing some other valve qualified for isolation or restoring one leaking PIV. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time after exceeding the limit considers the time required to complete the Action and the low probability of a second valve failing during this time period.

[or]

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. ]

REVIEWERS NOTE-----------------------------------

Two options are provided for Required Action A.2. The second option (72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration) is appropriate if isolation of a second valve would place the unit in an unanalyzed condition.

B.1 and B.2 If leakage cannot be reduced, [the system can not be isolated,] or the other Required Actions accomplished, the plant must be brought to a MODE in which the requirement does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This Action may reduce the leakage and also reduces the potential for a LOCA outside the containment.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 7). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 7, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment WOG STS B 3.4.14-4 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage B 3.4.14 addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 The inoperability of the RHR autoclosure interlock renders the RHR suction isolation valves incapable of isolating in response to a high pressure condition and preventing inadvertent opening of the valves at RCS pressures in excess of the RHR systems design pressure. If the RHR autoclosure interlock is inoperable, operation may continue as long as the affected RHR suction penetration is closed by at least one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This Action accomplishes the purpose of the autoclosure function.

WOG STS B 3.4.14-5 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage B 3.4.14 BASES 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.

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. 89) as contained in the Inservice Testing Program, is within frequency allowed by the American Society of Mechanical Engineers (ASME) Code (Ref. 78), 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 WOG STS B 3.4.14-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS PIV Leakage B 3.4.14 BASES SURVEILLANCE REQUIREMENTS (continued) 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.

[ SR 3.4.14.2 and SR 3.4.14.3 Verifying that the RHR autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be

< [425] psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. The

[18] month Frequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The [18] month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

These SRs are modified by Notes allowing the RHR autoclosure function to be disabled when using the RHR System suction relief valves for cold overpressure protection in accordance with SR 3.4.12.7. ]

REFERENCES 1. 10 CFR 50.2.

2. 10 CFR 50.55a(c).

3. 10 CFR 50, Appendix A, Section V, GDC 55.

4. WASH-1400 (NUREG-75/014), Appendix V, October 1975.

5. NUREG-0677, May 1980.

[ 6. Document containing list of PIVs. ]

7. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

78. ASME Code for Operation and Maintenance of Nuclear Power Plants.

89. 10 CFR 50.55a(g).

WOG STS B 3.4.14-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

[ D.1 and D.2 With the required containment atmosphere radioactivity monitor and the required containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor.

This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period. ]

E.1 and E.2 If a Required Action of Condition A, B, [C], or [D] cannot be met, the plant must be brought to a MODE in which the requirement does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action E.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

WOG STS B 3.4.15-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RCS Leakage Detection Instrumentation B 3.4.15 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.

F.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.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere 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.

WOG STS B 3.4.15-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test verifies the alarm setpoint and 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, [SR 3.4.15.4, and SR 3.4.15.5]

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, Section IV, GDC 30.

2. Regulatory Guide 1.45.

3. FSAR, Section [ ].

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.4.15-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS - Shutdown B 3.5.3 BASES ACTIONS (continued)

With both RHR pumps and heat exchangers inoperable, it would be unwise to require the plant to go to MODE 5, where the only available heat removal system is the RHR. Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status.

B.1 With no ECCS high head subsystem OPERABLE, due to the inoperability of the centrifugal charging pump or flow path from the RWST, the plant is not prepared to provide high pressure response to Design Basis Events requiring SI. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time of immediately to initiate actions that would restore at least one ECCS high head subsystem to OPERABLE status ensures that prompt action is taken to provide the required cooling capacity or to initiate actions to place the plant in MODE 5, where an ECCS train is not required.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 1, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action A.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

C.1 When the Required Actions of Condition B cannot be completed within the required Completion Time, a controlled shutdown should be initiated.

WOG STS B 3.5.3-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS - Shutdown B 3.5.3 Twenty-four hours is a reasonable time, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems or operators.

SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The applicable Surveillance descriptions from Bases 3.5.2 apply.

REFERENCES 1. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

The applicable references from Bases 3.5.2 also apply.

WOG STS B 3.5.3-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RWST B 3.5.4 BASES ACTIONS (continued)

B.1 With the RWST inoperable for reasons other than Condition A (e.g., water volume), it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In this Condition, neither the ECCS nor the Containment Spray System can perform its design function. Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the RWST is not required. The short time limit of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the RWST to OPERABLE status is based on this condition simultaneously affecting redundant trains.

C.1 and C.2 If the RWST cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

WOG STS B 3.5.4-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 RWST B 3.5.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.2 The RWST water volume should be verified every 7 days to be above the required minimum level in order to ensure that a sufficient initial supply is available for injection and to support continued ECCS and Containment Spray System pump operation on recirculation. Since the RWST volume is normally stable and is protected by an alarm, a 7 day Frequency is appropriate and has been shown to be acceptable through operating experience.

SR 3.5.4.3 The boron concentration of the RWST should be verified every 7 days to be within the required limits. This SR ensures that the reactor will remain subcritical following a LOCA. Further, it assures that the resulting sump pH will be maintained in an acceptable range so that boron precipitation in the core will not occur and the effect of chloride and caustic stress corrosion on mechanical systems and components will be minimized.

Since the RWST volume is normally stable, a 7 day sampling Frequency to verify boron concentration is appropriate and has been shown to be acceptable through operating experience.

REFERENCES 1. FSAR, Chapter [6] and Chapter [15].

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.5.4-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES ACTIONS (continued)

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 84 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 4 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore additional time for attempting restoration of the containment spray train to OPERABLE status in MODE 3. This and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

C.1 With one of the required containment cooling trains inoperable, the inoperable required containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded WOG STS B 3.6.6A-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of DBA occurring during this period.

D.1 With two required containment cooling trains inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of DBA occurring during this period.

WOG STS B 3.6.6A-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES ACTIONS (continued)

E.1 and E.2 If the Required Action and associated Completion Time of Condition C or D of this LCO are not met, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action E.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

F.1 With two containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.6.6A.1 REQUIREMENTS WOG STS B 3.6.6A-8 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.

SR 3.6.6A.2 Operating each [required] containment cooling train fan unit for 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The 31 day Frequency was developed considering the known reliability of the fan units and controls, the two train redundancy available, and the low probability of significant degradation of the containment cooling train occurring between surveillances. It has also been shown to be acceptable through operating experience.

WOG STS B 3.6.6A-9 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6A.3 Verifying that each [required] containment cooling train ESW cooling flow rate to each cooling unit is [700] gpm provides assurance that the design flow rate assumed in the safety analyses will be achieved (Ref. 3).

The Frequency was developed considering the known reliability of the Cooling Water System, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

SR 3.6.6A.4 Verifying each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by the ASME Code (Ref. 89). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by abnormal performance. The Frequency of the SR is in accordance with the Inservice Testing Program.

SR 3.6.6A.5 and SR 3.6.6A.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High-3 pressure signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power.

Operating experience has shown that these components usually pass the Surveillances when performed at the [18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

WOG STS B 3.6.6A-10 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6A BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6A.7 This SR requires verification that each [required] containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The [18] month Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6A.5 and SR 3.6.6A.6, above, for further discussion of the basis for the [18] month Frequency.

SR 3.6.6A.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Due to the passive design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the nozzles.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. 10 CFR 50, Appendix K.

3. FSAR, Section [ ].

4. FSAR, Section [ ].

5. FSAR, Section [ ].

6. FSAR, Section [ ].

7. FSAR, Section [ ].

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

89. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.6A-11 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES ACTIONS (continued)

D.1 and D.2 If one required containment spray train is inoperable and one of the required containment cooling trains is inoperable, the inoperable containment spray train or the inoperable containment cooling train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as those given in Required Action C.1.

E.1 If two required containment cooling trains are inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as those given in Required Action C.1.

F.1 and F.2 If any of the Required Actions or associated Completion Times for Condition A, B, C, D, or E of this LCO are not met, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action F.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment WOG STS B 3.6.6B-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

G.1 With any combination of three or more containment spray and containment cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

WOG STS B 3.6.6B-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES SURVEILLANCE SR 3.6.6B.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves, excluding check valves, in the Containment Spray System flow path provides assurance that the proper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct positions prior to being secured. This SR does not require testing or valve manipulation. Rather, it involves verification that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.

SR 3.6.6B.2 Operating each [required] containment cooling train fan unit for 15 minutes ensures that all trains are OPERABLE and all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.

The 31 day Frequency was developed based on the known reliability of the fan units and controls, the two train redundancy available, and the low probability of significant degradation of the containment cooling train occurring between surveillances.

SR 3.6.6B.3 Verifying that each [required] containment cooling train ESW cooling flow rate to each cooling unit is [700] gpm provides assurance that the design flow rate assumed in the analyses will be achieved (Ref. 3). The Frequency was developed considering the known reliability of the Cooling Water System, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances.

SR 3.6.6B.4 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by the ASME Code (Ref. 89). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance.

Such inservice WOG STS B 3.6.6B-8 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray and Cooling Systems (Atmospheric and Dual)

B 3.6.6B BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6B.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Because of the passive design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the spray nozzles.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. 10 CFR 50, Appendix A.

3. FSAR, Section [15].

4. FSAR, Section [6.2].

5. FSAR, Section [ ].

6. FSAR, Section [ ].

7. FSAR, Section [ ].

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

89. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.6B-10 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray System (Ice Condenser)

B 3.6.6C BASES APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the Containment Spray System.

In MODES 5 and 6, the probability and consequences of these events are reduced because of the pressure and temperature limitations of these MODES. Thus, the Containment Spray System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS A.1 With one containment spray train inoperable, the affected train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal and iodine removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period.

B.1 and B.2 If the affected containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 84 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or WOG STS B 3.6.6C-5 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray System (Ice Condenser)

B 3.6.6C other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

The extended interval to reach MODE 5 4 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the containment spray train to OPERABLE status in MODE 3. This additional time and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

SURVEILLANCE SR 3.6.6C.1 REQUIREMENTS Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the Containment Spray System provides assurance that the proper flow path exists for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since they were verified in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment and capable of potentially being mispositioned, are in the correct position.

WOG STS B 3.6.6C-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray System (Ice Condenser)

B 3.6.6C BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6.2 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by the ASME Code (Ref. 56). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6.6.3 and SR 3.6.6.4 These SRs require verification that each automatic containment spray valve actuates to its correct position and each containment spray pump starts upon receipt of an actual or simulated containment spray actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillances when performed at the

[18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The surveillance of containment sump isolation valves is also required by SR 3.6.6.3. A single surveillance may be used to satisfy both requirements.

SR 3.6.6.5 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Because of the passive design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the spray nozzles.

WOG STS B 3.6.6C-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Containment Spray System (Ice Condenser)

B 3.6.6C BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2. FSAR, Section [6.2].

3. 10 CFR 50.49.

4. 10 CFR 50, Appendix K.

5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

56. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.6C-8 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 QS System (Subatmospheric)

B 3.6.6D BASES ACTIONS A.1 If one QS train is inoperable, it must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal and iodine removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal and iodine removal capabilities afforded by the OPERABLE train and the low probability of a DBA occurring during this period.

B.1 and B.2 If the Required Action and associated Completion Time are not met, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 3.6.6D.1 REQUIREMENTS WOG STS B 3.6.6D-4 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 QS System (Subatmospheric)

B 3.6.6D Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the QS System provides assurance that the proper flow path exists for QS System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they were verified to be in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment and capable of potentially being mispositioned are in the correct position.

SR 3.6.6D.2 Verifying that each QS pump's developed head at the flow test point is greater than or equal to the required developed head ensures that QS pump performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by the ASME Code (Ref. 45). Since the QS System pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

WOG STS B 3.6.6D-5 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 QS System (Subatmospheric)

B 3.6.6D BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6D.3 and SR 3.6.6D.4 These SRs ensure that each QS automatic valve actuates to its correct position and each QS pump starts upon receipt of an actual or simulated containment spray actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power.

Operating experience has shown that these components usually pass the Surveillances when performed at an [18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.6D.5 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment during an accident is not degraded. Due to the passive nature of the design of the nozzle, a test at [the first refueling and at] 10 year intervals is considered adequate to detect obstruction of the nozzles.

REFERENCES 1. FSAR, Section [6.2].

2. 10 CFR 50.49.

3. 10 CFR 50, Appendix K.

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

54. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.6D-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RS System (Subatmospheric)

B 3.6.6E BASES ACTIONS (continued)

[ C.1 With two inside RS subsystems inoperable, at least one of the inoperable subsystems must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as given in Required Action B.1. ]

[ D.1 With two outside RS subsystems inoperable, at least one of the inoperable subsystems must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as given in Required Action B.1. ]

[ E.1 With the casing cooling tank inoperable, the NPSH available to the outside RS subsystem pumps may not be sufficient. The inoperable casing cooling tank must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as given in Required Action B.1. ]

F.1 and F.2 If the inoperable RS subsystem(s) [or the casing cooling tank] cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 84 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned WOG STS B 3.6.6E-5 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RS System (Subatmospheric)

B 3.6.6E actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action F.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 4 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the RS subsystem(s) [or casing cooling tank] to OPERABLE status in MODE 3.

This additional time and is reasonable considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

WOG STS B 3.6.6E-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RS System (Subatmospheric)

B 3.6.6E BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6E.4 Verifying the correct alignment of manual, power operated, and automatic valves, excluding check valves, in the RS System and casing cooling tank provides assurance that the proper flow path exists for operation of the RS System. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified as being in the correct position prior to being secured. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment and capable of potentially being mispositioned are in the correct position.

SR 3.6.6E.5 Verifying that each RS [and casing cooling] pump's developed head at the flow test point is greater than or equal to the required developed head ensures that these pumps' performance has not degraded during the cycle. Flow and differential head are normal tests of centrifugal pump performance required by the ASME Code (Ref. 45). Since the QS System pumps cannot be tested with flow through the spray headers, they are tested on bypass flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6.6E.6 These SRs ensure that each automatic valve actuates and that the RS System and casing cooling pumps start upon receipt of an actual or simulated High-High containment pressure signal. Start delay times are also verified for the RS System pumps. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency was considered to be acceptable from a reliability standpoint.

WOG STS B 3.6.6E-8 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 RS System (Subatmospheric)

B 3.6.6E BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6E.7 This SR ensures that each spray nozzle is unobstructed and that spray coverage of the containment will meet its design bases objective. An air or smoke test is performed through each spray header. Due to the passive design of the spray header and its normally dry state, a test at

[the first refueling and at] 10 year intervals is considered adequate for detecting obstruction of the nozzles.

REFERENCES 1. FSAR, Section [6.2].

2. 10 CFR 50.49.

3. 10 CFR 50, Appendix K.

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

45. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.6E-9 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

B 3.6.7 BASES LCO (continued) spray flow until the Containment Spray System suction path is switched from the RWST to the containment sump, and to raise the average spray solution pH to a level conducive to iodine removal, namely, to between [7.2 and 11.0]. This pH range maximizes the effectiveness of the iodine removal mechanism without introducing conditions that may induce caustic stress corrosion cracking of mechanical system components. In addition, it is essential that valves in the Spray Additive System flow paths are properly positioned and that automatic valves are capable of activating to their correct positions.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment requiring the operation of the Spray Additive System. The Spray Additive System assists in reducing the iodine fission product inventory prior to release to the environment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Thus, the Spray Additive System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS A.1 If the Spray Additive System is inoperable, it must be restored to OPERABLE within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The pH adjustment of the Containment Spray System flow for corrosion protection and iodine removal enhancement is reduced in this condition. The Containment Spray System would still be available and would remove some iodine from the containment atmosphere in the event of a DBA. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant flow path capabilities and the low probability of the worst case DBA occurring during this period.

B.1 and B.2 If the Spray Additive System cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 84 54hours.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater WOG STS B 3.6.7-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

B 3.6.7 Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 4 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore for restoration of the Spray WOG STS B 3.6.7-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

B 3.6.7 BASES ACTIONS (continued)

Additive System to OPERABLE status in MODE 3 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5. This is reasonable when considering the reduced pressure and temperature conditions in MODE 3 for the release of radioactive material from the Reactor Coolant System.

SURVEILLANCE SR 3.6.7.1 REQUIREMENTS Verifying the correct alignment of Spray Additive System manual, power operated, and automatic valves in the spray additive flow path provides assurance that the system is able to provide additive to the Containment Spray System in the event of a DBA. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation.

Rather, it involves verification that those valves outside containment and capable of potentially being mispositioned are in the correct position.

SR 3.6.7.2 To provide effective iodine removal, the containment spray must be an alkaline solution. Since the RWST contents are normally acidic, the volume of the spray additive tank must provide a sufficient volume of spray additive to adjust pH for all water injected. This SR is performed to verify the availability of sufficient NaOH solution in the Spray Additive System. The 184 day Frequency was developed based on the low probability of an undetected change in tank volume occurring during the SR interval (the tank is isolated during normal unit operations). Tank level is also indicated and alarmed in the control room, so that there is high confidence that a substantial change in level would be detected.

SR 3.6.7.3 This SR provides verification of the NaOH concentration in the spray additive tank and is sufficient to ensure that the spray solution being injected into containment is at the correct pH level. The 184 day Frequency is sufficient to ensure that the concentration level of NaOH in the spray additive tank remains within the established limits. This is based on the low likelihood of an uncontrolled change in concentration (the tank is normally isolated) and the probability that any substantial variance in tank volume will be detected.

WOG STS B 3.6.7-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Spray Additive System (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

B 3.6.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.7.4 This SR provides verification that each automatic valve in the Spray Additive System flow path actuates to its correct position. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.7.5 To ensure that the correct pH level is established in the borated water solution provided by the Containment Spray System, the flow rate in the Spray Additive System is verified once every 5 years. This SR provides assurance that the correct amount of NaOH will be metered into the flow path upon Containment Spray System initiation. Due to the passive nature of the spray additive flow controls, the 5 year Frequency is sufficient to identify component degradation that may affect flow rate.

REFERENCES 1. FSAR, Chapter [15].

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.6.7-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ICS (Atmospheric and Subatmospheric)

B 3.6.11 BASES ACTIONS A.1 With one ICS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing 100% of the iodine removal needs after a DBA. The 7 day Completion Time is based on consideration of such factors as:

a. The availability of the OPERABLE redundant ICS train,

b. The fact that, even with no ICS train in operation, almost the same amount of iodine would be removed from the containment atmosphere through absorption by the Containment Spray System, and

c. The fact that the Completion Time is adequate to make most repairs.

B.1 and B.2 If the ICS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

WOG STS B 3.6.11-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ICS (Atmospheric and Subatmospheric)

B 3.6.11

5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.6.11-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Vacuum Relief Valves (Atmospheric and Ice Condenser)

B 3.6.12 BASES LCO The LCO establishes the minimum equipment required to accomplish the vacuum relief function following the inadvertent actuation of containment cooling features. Two 100% vacuum relief lines are required to be OPERABLE to ensure that at least one is available, assuming one or both valves in the other line fail to open.

APPLICABILITY In MODES 1, 2, 3, and 4, the containment cooling features, such as the Containment Spray System, are required to be OPERABLE to mitigate the effects of a DBA. Excessive negative pressure inside containment could occur whenever these systems are required to be OPERABLE due to inadvertent actuation of these systems. Therefore, the vacuum relief lines are required to be OPERABLE in MODES 1, 2, 3, and 4 to mitigate the effects of inadvertent actuation of the Containment Spray System, Quench Spray (QS) System, or Containment Cooling System.

In MODES 5 and 6, the probability and consequences of a DBA are reduced due to the pressure and temperature limitations of these MODES. The Containment Spray System, QS System, and Containment Cooling System are not required to be OPERABLE in MODES 5 and 6.

Therefore, maintaining OPERABLE vacuum relief valves is not required in MODE 5 or 6.

ACTIONS A.1 When one of the required vacuum relief lines is inoperable, the inoperable line must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The specified time period is consistent with other LCOs for the loss of one train of a system required to mitigate the consequences of a LOCA or other DBA.

B.1 and B.2 If the vacuum relief line cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned WOG STS B 3.6.12-2 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Vacuum Relief Valves (Atmospheric and Ice Condenser)

B 3.6.12 actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

WOG STS B 3.6.12-3 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Vacuum Relief Valves (Atmospheric and Ice Condenser)

B 3.6.12 BASES SURVEILLANCE SR 3.6.12.1 REQUIREMENTS This SR cites the Inservice Testing Program, which establishes the requirement that inservice testing of the ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with the ASME Code (Ref. 23). Therefore, SR Frequency is governed by the Inservice Testing Program.

REFERENCES 1. FSAR, Section [6.2].

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

23. ASME Code for Operation and Maintenance of Nuclear Power Plants.

WOG STS B 3.6.12-4 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 SBACS (Dual and Ice Condenser)

B 3.6.13 BASES LCO In the event of a DBA, one SBACS train is required to provide the minimum particulate iodine removal assumed in the safety analysis. Two trains of the SBACS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single active failure.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could lead to fission product release to containment that leaks to the shield building. The large break LOCA, on which this system's design is based, is a full power event. Less severe LOCAs and leakage still require the system to be OPERABLE throughout these MODES. The probability and severity of a LOCA decrease as core power and Reactor Coolant System pressure decrease. With the reactor shut down, the probability of release of radioactivity resulting from such an accident is low.

In MODES 5 and 6, the probability and consequences of a DBA are low due to the pressure and temperature limitations in these MODES. Under these conditions, the Filtration System is not required to be OPERABLE (although one or more trains may be operating for other reasons, such as habitability during maintenance in the shield building annulus).

ACTIONS A.1 With one SBACS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing 100% of the iodine removal needs after a DBA. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SBACS train and the low probability of a DBA occurring during this period. The Completion Time is adequate to make most repairs.

B.1 and B.2 If the SBACS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned WOG STS B 3.6.13-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SBACS (Dual and Ice Condenser)

B 3.6.13 actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

WOG STS B 3.6.13-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SBACS (Dual and Ice Condenser)

B 3.6.13 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.6.13.4 The SBACS filter bypass dampers are tested to verify OPERABILITY.

The dampers are in the bypass position during normal operation and must reposition for accident operation to draw air through the filters. The

[18] month Frequency is considered to be acceptable based on damper reliability and design, mild environmental conditions in the vicinity of the dampers, and the fact that operating experience has shown that the dampers usually pass the Surveillance when performed at the [18] month Frequency. ]

SR 3.6.13.5 The proper functioning of the fans, dampers, filters, adsorbers, etc., as a system is verified by the ability of each train to produce the required system flow rate. The [18] month Frequency on a STAGGERED TEST BASIS is consistent with Regulatory Guide 1.52 (Ref. 45) guidance for functional testing.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 41.

2. FSAR, Section [6.5].

3. FSAR, Chapter [15].

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

45. Regulatory Guide 1.52, Revision [2].

WOG STS B 3.6.13-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ARS (Ice Condenser)

B 3.6.14 BASES ACTIONS (continued)

B.1 and B.2 If the ARS train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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 3.6.14.1 REQUIREMENTS Verifying that each ARS fan starts on an actual or simulated actuation signal, after a delay [9.0] minutes and [11.0] minutes, and operates for 15 minutes is sufficient to ensure that all fans are OPERABLE and that all associated controls and time delays are functioning properly. It also ensures that blockage, fan and/or motor failure, or excessive vibration can be detected for corrective action. The [92] day Frequency was developed considering the known reliability of fan motors and controls and the two train redundancy available.

WOG STS B 3.6.14-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ARS (Ice Condenser)

B 3.6.14 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.6.14.4 Verifying the OPERABILITY of the motor operated valve in the Hydrogen Skimmer System hydrogen collection header to the lower containment compartment provides assurance that the proper flow path will exist when the valve receives an actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. This Surveillance also confirms that the time delay to open is within specified tolerances. The 92 day Frequency was developed considering the known reliability of the motor operated valves and controls and the two train redundancy available.

Operating experience has also shown this Frequency to be acceptable. ]

REFERENCES 1. FSAR, Section [6.2].

2. 10 CFR 50, Appendix K.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.6.14-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Recirculation Drains (Ice Condenser)

B 3.6.18 BASES APPLICABILITY (continued)

The probability and consequences of these events in MODES 5 and 6 are low due to the pressure and temperature limitations of these MODES. As such, the containment recirculation drains are not required to be OPERABLE in these MODES.

ACTIONS A.1 If one ice condenser floor drain is inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the drain to OPERABLE status. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1, "Containment," which requires that containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

B.1 If one refueling canal drain is inoperable, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the drain to OPERABLE status. The Required Action is necessary to return operation to within the bounds of the containment analysis. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

C.1 and C.2 If the affected drain(s) cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

WOG STS B 3.6.18-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Recirculation Drains (Ice Condenser)

B 3.6.18 However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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.

WOG STS B 3.6.18-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Containment Recirculation Drains (Ice Condenser)

B 3.6.18 BASES SURVEILLANCE SR 3.6.18.1 REQUIREMENTS Verifying the OPERABILITY of the refueling canal drains ensures that they will be able to perform their functions in the event of a DBA. This Surveillance confirms that the refueling canal drain plugs have been removed and that the drains are clear of any obstructions that could impair their functioning. In addition to debris near the drains, attention must be given to any debris that is located where it could be moved to the drains in the event that the Containment Spray System is in operation and water is flowing to the drains. SR 3.6.18.1 must be performed before entering MODE 4 from MODE 5 after every filling of the canal to ensure that the plugs have been removed and that no debris that could impair the drains was deposited during the time the canal was filled. The 92 day Frequency was developed considering such factors as the inaccessibility of the drains, the absence of traffic in the vicinity of the drains, and the redundancy of the drains.

SR 3.6.18.2 Verifying the OPERABILITY of the ice condenser floor drains ensures that they will be able to perform their functions in the event of a DBA.

Inspecting the drain valve disk ensures that the valve is performing its function of sealing the drain line from warm air leakage into the ice condenser during normal operation, yet will open if melted ice fills the line following a DBA. Verifying that the drain lines are not obstructed ensures their readiness to drain water from the ice condenser. The [18] month Frequency was developed considering such factors as the inaccessibility of the drains during power operation; the design of the ice condenser, which precludes melting and refreezing of the ice; and operating experience that has confirmed that the drains are found to be acceptable when the Surveillance is performed at an [18] month Frequency.

Because of high radiation in the vicinity of the drains during power operation, this Surveillance is normally done during a shutdown.

REFERENCES 1. FSAR, Section [6.2].

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.6.18-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CCW System B 3.7.7 BASES APPLICABILITY (continued)

In MODE 5 or 6, the OPERABILITY requirements of the CCW System are determined by the systems it supports.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

be entered if an inoperable CCW train results in an inoperable RHR loop.

This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

If one CCW train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE CCW train is adequate to perform the heat removal function.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.

B.1 and B.2 If the CCW train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is WOG STS B 3.7.7-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CCW System B 3.7.7 not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

SURVEILLANCE SR 3.7.7.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.

Verifying the correct alignment for manual, power operated, and automatic valves in the CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, WOG STS B 3.7.7-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CCW System B 3.7.7 BASES SURVEILLANCE REQUIREMENTS (continued) sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.7.2 This SR verifies proper automatic operation of the CCW valves on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.7.3 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section [9.2.2].

2. FSAR, Section [6.2].

WOG STS B 3.7.7-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CCW System B 3.7.7

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.7.7-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SWS B 3.7.8 BASES ACTIONS (continued)

LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

B.1 and B.2 If the SWS train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 54 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the SWS components or systems may render those components inoperable, but does not affect the OPERABILITY of the SWS.

WOG STS B 3.7.8-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 SWS B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.8.2 This SR verifies proper automatic operation of the SWS valves on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.8.3 This SR verifies proper automatic operation of the SWS pumps on an actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section [9.2.1].

2. FSAR, Section [6.2].

3. FSAR, Section [5.4.7].

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.7.8-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 UHS B 3.7.9 BASES ACTIONS (continued)

The 7 day Completion Time is reasonable based on the low probability of an accident occurring during the 7 days that one cooling tower fan is inoperable (in one or more cooling towers), the number of available systems, and the time required to reasonably complete the Required Action. ]

[ B.1

REVIEWERS NOTE-----------------------------------

The [ ]°F is the maximum allowed UHS temperature value and is based on temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.

With water temperature of the UHS > [90]°F, the design basis assumption associated with initial UHS temperature are bounded provided the temperature of the UHS averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is

[90]°F. With the water temperature of the UHS > [90]°F, long term cooling capability of the ECCS loads and DGs may be affected.

Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS is > [90]°F, Required Action B.1 is provided to more frequently monitor the water temperature of the UHS and verify the temperature is [90]°F when averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The once per hour Completion Time takes into consideration UHS temperature variations and the increased monitoring frequency needed to ensure design basis assumptions and equipment limitations are not exceeded in this condition. If the water temperature of the UHS exceeds [90]°F when averaged over the previous 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period or the water temperature of the UHS exceeds [ ]°F, Condition C must be entered immediately.]

[ C.1 and C.2 If the Required Actions and Completion Times of Condition [A or B] are not met, or the UHS is inoperable for reasons other than Condition A [or B], the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available WOG STS B 3.7.9-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 UHS B 3.7.9 to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.7.9-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 UHS B 3.7.9 BASES SURVEILLANCE [ SR 3.7.9.1 REQUIREMENTS This SR verifies that adequate long term (30 day) cooling can be maintained. The specified level also ensures that sufficient NPSH is available to operate the SWS pumps. The [24] hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the UHS water level is [562] ft [mean sea level]. ]

[ SR 3.7.9.2 This SR verifies that the SWS is available to cool the CCW System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the average water temperature of the UHS is [90°F]. ]

[ SR 3.7.9.3 Operating each cooling tower fan for [15] minutes ensures that all fans are OPERABLE and that all associated controls are functioning properly.

It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action. The 31 day Frequency is based on operating experience, the known reliability of the fan units, the redundancy available, and the low probability of significant degradation of the UHS cooling tower fans occurring between surveillances. ]

[ SR 3.7.9.4 This SR verifies that each cooling tower fan starts and operates on an actual or simulated actuation signal. The [18] month Frequency is consistent with the typical refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. ]

REFERENCES 1. FSAR, Section [9.2.5].

2. Regulatory Guide 1.27.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.7.9-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS B 3.7.10 BASES ACTIONS (continued) temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREFS train or control room boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident riskin which the overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.7.10-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREFS B 3.7.10 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.10.3 This SR verifies that each CREFS train starts and operates on an actual or simulated actuation signal. The Frequency of [18] months is specified in Regulatory Guide 1.52 (Ref. 34).

SR 3.7.10.4 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air. The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the CREFS. During the emergency mode of operation, the CREFS is designed to pressurize the control room [0.125] inches water gauge positive pressure with respect to adjacent areas in order to prevent unfiltered inleakage. The CREFS is designed to maintain this positive pressure with one train at a makeup flow rate of [3000] cfm. The Frequency of [18] months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 45).

REFERENCES 1. FSAR, Section [6.4].

2. FSAR, Chapter [15].

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

34. Regulatory Guide 1.52, Rev. [2].

45. NUREG-0800, Section 6.4, Rev. 2, July 1981.

WOG STS B 3.7.10-8 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREATCS B 3.7.11 BASES LCO (continued)

The CREATCS is considered to be OPERABLE when the individual components necessary to maintain the control room temperature are OPERABLE in both trains. These components include the heating and cooling coils and associated temperature control instrumentation. In addition, the CREATCS must be operable to the extent that air circulation can be maintained.

APPLICABILITY In MODES 1, 2, 3, 4, [5, and 6,] and during movement of [recently]

irradiated fuel assemblies, the CREATCS must be OPERABLE to ensure that the control room temperature will not exceed equipment operational requirements following isolation of the control room. [The CREATCS is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days), due to radioactive decay.]

[In MODE 5 or 6,] CREATCS may not be required for those facilities that do not require automatic control room isolation.

ACTIONS A.1 With one CREATCS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREATCS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a single failure in the OPERABLE CREATCS train could result in loss of CREATCS function. The 30 day Completion Time is based on the low probability of an event requiring control room isolation, the consideration that the remaining train can provide the required protection, and that alternate safety or nonsafety related cooling means are available.

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable CREATCS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the riskin which the overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater WOG STS B 3.7.11-2 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREATCS B 3.7.11 Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.7.11-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 CREATCS B 3.7.11 BASES ACTIONS (continued)

C.1 and C.2

[In MODE 5 or 6, or] during movement of [recently] irradiated fuel, if the inoperable CREATCS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREATCS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that active failures will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

D.1

[In MODE 5 or 6, or] during movement of [recently] irradiated fuel assemblies, with two CREATCS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

E.1 If both CREATCS trains are inoperable in MODE 1, 2, 3, or 4, the control room CREATCS may not be capable of performing its intended function.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the [safety analyses] in the control room. This SR consists of a combination of testing and calculations. The

[18] month Frequency is appropriate since significant degradation of the CREATCS is slow and is not expected over this time period.

REFERENCES 1. FSAR, Section [6.4].

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.7.11-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS PREACS B 3.7.12 BASES ACTIONS (continued)

If the ECCS pump room boundary is inoperable, the ECCS PREACS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE ECCS pump room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

During the period that the ECCS pump room boundary is inoperable, appropriate compensatory measures [consistent with the intent, as applicable, of GDC 19, 60, 64 and 10 CFR Part 100] should be utilized to protect plant personnel from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the ECCS pump room boundary.

C.1 and C.2 If the ECCS PREACS train or ECCS pump room boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 6). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 6, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or WOG STS B 3.7.12-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS PREACS B 3.7.12 other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system. Monthly heater operations dry out any moisture that may have accumulated in the charcoal from humidity in the ambient air. [Systems with heaters must be operated 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system.] The 31 day Frequency is based on the known reliability of equipment and the two train redundancy available.

WOG STS B 3.7.12-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS PREACS B 3.7.12 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.12.2 This SR verifies that the required ECCS PREACS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The

[VFTP] includes testing HEPA filter performance, charcoal adsorbers efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test Frequencies and additional information are discussed in detail in the [VFTP].

SR 3.7.12.3 This SR verifies that each ECCS PREACS train starts and operates on an actual or simulated actuation signal. The [18] month Frequency is consistent with that specified in Reference 4.

SR 3.7.12.4 This SR verifies the integrity of the ECCS pump room enclosure. The ability of the ECCS pump room to maintain a negative pressure, with respect to potentially uncontaminated adjacent areas, is periodically tested to verify proper functioning of the ECCS PREACS. During the

[post accident] mode of operation, the ECCS PREACS is designed to maintain a slight negative pressure in the ECCS pump room, with respect to adjacent areas, to prevent unfiltered LEAKAGE. The ECCS PREACS is designed to maintain a [-0.125] inches water gauge relative to atmospheric pressure at a flow rate of [3000] cfm from the ECCS pump room. The Frequency of [18] months is consistent with the guidance provided in NUREG-0800, Section 6.5.1 (Ref. 67).

This test is conducted with the tests for filter penetration; thus, an

[18] month Frequency on a STAGGERED TEST BASIS is consistent with that specified in Reference 4.

[ SR 3.7.12.5 Operating the ECCS PREACS bypass damper is necessary to ensure that the system functions properly. The OPERABILITY of the ECCS PREACS bypass damper is verified if it can be specified in Reference 4. ]

WOG STS B 3.7.12-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 ECCS PREACS B 3.7.12 BASES REFERENCES 1. FSAR, Section [6.5.1].

2. FSAR, Section [9.4.5].

3. FSAR, Section [15.6.5].

4. Regulatory Guide 1.52 (Rev. 2).

5. 10 CFR 100.11.

6. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

67. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

WOG STS B 3.7.12-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS B 3.7.13 BASES ACTIONS (continued) applicable, of GDC 19, 60, 61, 63, 64 and 10 CFR Part 100] should be utilized to protect plant personnel from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the fuel building boundary.

[ C.1 and C.2 In MODE 1, 2, 3, or 4, when Required Action A.1 or B.1 cannot be completed within the associated Completion Time, or when both FBACS trains are inoperable for reasons other than an inoperable fuel building boundary (i.e., Condition B), the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 54 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 6). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 6, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

WOG STS B 3.7.13-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS B 3.7.13 BASES ACTIONS (continued)

E.1 When two trains of the FBACS are inoperable during movement of

[recently] irradiated fuel assemblies in the fuel building, action must be taken to place the unit in a condition in which the LCO does not apply.

Action must be taken immediately to suspend movement of [recently]

irradiated fuel assemblies in the fuel building. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.13.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environmental and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.

Monthly heater operation dries out any moisture accumulated in the charcoal from humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system.] The 31 day Frequency is based on the known reliability of the equipment and the two train redundancy available.

[ SR 3.7.13.2 This SR verifies that the required FBACS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The

[VFTP] includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the [VFTP]. ]

[ SR 3.7.13.3 This SR verifies that each FBACS train starts and operates on an actual or simulated actuation signal. The [18] month Frequency is consistent with Reference 67. ]

WOG STS B 3.7.13-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 FBACS B 3.7.13 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.13.4 This SR verifies the integrity of the fuel building enclosure. The ability of the fuel building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FBACS. During the [post accident] mode of operation, the FBACS is designed to maintain a slight negative pressure in the fuel building, to prevent unfiltered LEAKAGE. The FBACS is designed to maintain a [-0.125] inches water gauge with respect to atmospheric pressure at a flow rate of [20,000] cfm to the fuel building. The Frequency of [18] months is consistent with the guidance provided in NUREG-0800, Section 6.5.1 (Ref. 78).

An [18] month Frequency (on a STAGGERED TEST BASIS) is consistent with Reference 67.

[ SR 3.7.13.5 Operating the FBACS filter bypass damper is necessary to ensure that the system functions properly. The OPERABILITY of the FBACS filter bypass damper is verified if it can be closed. An [18] month Frequency is consistent with Reference 67. ]

REFERENCES 1. FSAR, Section [6.5.1].

2. FSAR, Section [9.4.5].

3. FSAR, Section [15.7.4].

4. Regulatory Guide 1.25.

5. 10 CFR 100.

6. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

67. Regulatory Guide 1.52, Rev. [2].

78. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

WOG STS B 3.7.13-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 PREACS B 3.7.14 BASES ACTIONS (continued)

C.1 and C.2 If the inoperable train or penetration room boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

SURVEILLANCE SR 3.7.14.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environmental and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system. Monthly heater operation dries out any moisture that may have accumulated in the charcoal as a result of humidity in the ambient air. [Systems with heaters must be operated for 10 continuous hours with the heaters energized. Systems without heaters need only be operated for 15 minutes to demonstrate WOG STS B 3.7.14-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 PREACS B 3.7.14 the function of the system.] The 31 day Frequency is based on the known reliability of equipment and the two train redundancy available.

SR 3.7.14.2 This SR verifies that the required PREACS testing is performed in accordance with the [Ventilation Filter Testing Program (VFTP)]. The

[VFTP] includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the [VFTP].

[ SR 3.7.14.3 This SR verifies that each PREACS starts and operates on an actual or simulated actuation signal. The [18] month Frequency is consistent with that specified in Reference 56. ]

WOG STS B 3.7.14-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 PREACS B 3.7.14 BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.14.4 This SR verifies the integrity of the penetration room enclosure. The ability of the penetration room to maintain a negative pressure, with respect to potentially uncontaminated adjacent areas, is periodically tested to verify proper function of PREACS. During the [post accident]

mode of operation, the PREACS is designed to maintain a

[-0.125] inches water gauge relative to atmospheric pressure at a flow rate of [3000] cfm in the penetration room, with respect to adjacent areas, to prevent unfiltered LEAKAGE. The Frequency of [18] months is consistent with the guidance provided in NUREG-0800 (Ref. 67).

The minimum system flow rate maintains a slight negative pressure in the penetration room area, and provides sufficient air velocity to transport particulate contaminants, assuming only one filter train is operating. The number of filter elements is selected to limit the flow rate through any individual element to about [3000] cfm. This may vary based on filter housing geometry. The maximum limit ensures that the flow through, and pressure drop across, each filter element are not excessive.

The number and depth of the adsorber elements ensure that, at the maximum flow rate, the residence time of the air stream in the charcoal bed achieves the desired adsorption rate. At least a [0.125] second residence time is necessary for an assumed [99]% efficiency.

The filters have a certain pressure drop at the design flow rate when clean. The magnitude of the pressure drop indicates acceptable performance, and is based on manufacturers' recommendations for the filter and adsorber elements at the design flow rate. An increase in pressure drop or a decrease in flow indicates that the filter is being loaded or that there are other problems with the system.

This test is conducted along with the tests for filter penetration; thus, the

[18] month Frequency is consistent with that specified in Reference 56. ]

[ SR 3.7.14.5 It is necessary to operate the PREACS filter bypass damper to ensure that the system functions properly. The OPERABILITY of the PREACS filter bypass damper is verified if it can be closed. An [18] month Frequency is consistent with that specified in Reference 56. ]

WOG STS B 3.7.14-6 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 PREACS B 3.7.14 BASES REFERENCES 1. FSAR, Section [6.5.1].

2. FSAR, Section [9.4.5].

3. FSAR, Section [15.6.5].

4. 10 CFR 100.

5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

56. Regulatory Guide 1.52, Rev. [2].

67. NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

WOG STS B 3.7.14-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 BASES ACTIONS (continued)

G.1 and G.2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action G.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 89).

Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs WOG STS B 3.8.1-12 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 910), and Regulatory Guide 1.137 (Ref. 1011), as addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of [3740] V is 90% of the nominal 4160 V output voltage. This value, which is specified in ANSI C84.1 (Ref. 1112), allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating.

The specified maximum steady state output voltage of [4756] V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating WOG STS B 3.8.1-13 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients, because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank [and engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%.

The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large uses of fuel oil during this period.

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day [and engine mounted] tanks once every [31] days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 1011). This SR is for preventative maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

WOG STS B 3.8.1-16 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 1112); however, the design of fuel transfer systems is such that pumps operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

SR 3.8.1.7 See SR 3.8.1.2.

[ SR 3.8.1.8 Transfer of each [4.16 kV ESF bus] power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.

The [18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 WOG STS B 3.8.1-17 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.]

Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency and while maintaining a specified margin to the overspeed trip. [For this unit, the single load for each DG and its horsepower rating is as follows:] This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus, or

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

As required by IEEE-308 (Ref. 1213), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 3 seconds specified is equal to 60% of a typical 5 second load sequence interval associated with WOG STS B 3.8.1-18 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. The

[18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 910).

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9].

This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

WOG STS B 3.8.1-19 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

The [18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 910) and is intended to be consistent with expected fuel cycle lengths.

This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety WOG STS B 3.8.1-20 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The DG autostart time of [10] seconds is derived from requirements of the accident analysis to respond to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.

The requirement to verify the connection and power supply of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

WOG STS B 3.8.1-22 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.12 This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time

([10] seconds) from the design basis actuation signal (LOCA signal) and operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.

WOG STS B 3.8.1-23 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(3), requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

[2] hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor WOG STS B 3.8.1-26 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued)

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(5).

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset.

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with WOG STS B 3.8.1-28 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.17 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(8), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated WOG STS B 3.8.1-29 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. ] Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.18 Under accident [and loss of offsite power] conditions loads are sequentially connected to the bus by the [automatic load sequencer]. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The [10]% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

WOG STS B 3.8.1-30 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES SURVEILLANCE REQUIREMENTS (continued) performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910).

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

WOG STS B 3.8.1-32 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter [8].

3. Regulatory Guide 1.9, Rev. 3.

4. FSAR, Chapter [6].

5. FSAR, Chapter [15].

6. Regulatory Guide 1.93, Rev. 0, December 1974.

7. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

89. 10 CFR 50, Appendix A, GDC 18.

910. Regulatory Guide 1.108, Rev. 1, August 1977.

1011. Regulatory Guide 1.137, Rev. [ ], [date].

1112. ASME Code for Operation and Maintenance of Nuclear Power Plants.

1213. IEEE Standard 308-1978.

WOG STS B 3.8.1-33 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

C.1 Condition C represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution system train.

If one of the required DC electrical power subsystems is inoperable for reasons other than Condition A or B (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst- case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

D.1 and D.2 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

WOG STS B 3.8.4-7 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 DC Sources - Operating B 3.8.4 However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

WOG STS B 3.8.4-8 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer ([2.20] Vpc or [127.6] V at the battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 89).

SR 3.8.4.2 This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 910), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied.

This SR provides two options. One option requires that each battery charger be capable of supplying [400] amps at the minimum established float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours.

The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the WOG STS B 3.8.4-9 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps.

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month]

intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 910) and Regulatory Guide 1.129 (Ref. 1011), which state that the battery service test should be performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months].

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial WOG STS B 3.8.4-10 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-[1978].

4. FSAR, Chapter [8].

5. FSAR, Chapter [6].

6. FSAR, Chapter [15].

7. Regulatory Guide 1.93, December 1974.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

89. IEEE-450-[1995].

910. Regulatory Guide 1.32, February 1977.

1011. Regulatory Guide 1.129, December 1974.

WOG STS B 3.8.4-11 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Inverters - Operating B 3.8.7 BASES ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Required Action A.1 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment WOG STS B 3.8.7-3 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Inverters - Operating B 3.8.7 addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.8.7-4 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Inverters - Operating B 3.8.7 BASES SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. FSAR, Chapter [8].

2. FSAR, Chapter [6].

3. FSAR, Chapter [15].

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.8.7-5 Rev. 3.0, 03/31/04

TSTF-432, Rev. 1 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not applyoverall plant risk is reduced. To achieve this status, the unit 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 4 within 36 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator WOG STS B 3.8.9-6 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Distribution Systems - Operating B 3.8.9 cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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

WOG STS B 3.8.9-7 Rev. 3.1, 12/01/05

TSTF-432, Rev. 1 Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

E.1 Condition E corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the [required] AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. FSAR, Chapter [6].

2. FSAR, Chapter [15].

3. Regulatory Guide 1.93, December 1974.

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

WOG STS B 3.8.9-8 Rev. 3.1, 12/01/05

TSTF-10-20, Response to NRC Request for Additional Information Regarding TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294).

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TSTF-10-20, Response to NRC Request for Additional Information Regarding TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294).

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