Text

Update to License Amendment Request: Improvement to the Definition of Operations Involving Positive Reactivity Changes (TSTF-286)
	ML11129A013
Person / Time
Site:	Ginna
Issue date:	05/03/2011
From:	John Carlin; Constellation Energy Group, EDF Development, Ginna
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML11129A013 (46)
	v • d • e

John Carlin Site Vice President R.E. Ginna Nuclear Power Plant, CENG a joint venture of LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax Constellation wEnergvy Jae DF iohn.carlin(dcenqllc.com May 3, 2011 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Update to License Amendment Request: Improvement to the Definition of Operations Involvina Positive Reactivity Changes (TSTF-286)

REFERENCE:

(a) Letter from E. A. Larson, (Ginna LLC) to Document Control Desk, dated July 23, 2009, License Amendment Request:

Improvement to the Definition of Operations Involving Positive Reactivity Changes (TSTF-286), ML092090538 In accordance with the provisions of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted a request in Reference (a) for an amendment to revise the Technical Specification actions requiring suspension of operations involving positive reactivity addition and revise various notes precluding reduction in boron concentration.

Based upon the ongoing NRC staff review of our submittal, Ginna LLC has determined that the proposed change to Required Action LCO 3.9.2.C.2 will be withdrawn. Please find in Attachment (1) a revised mark-up of LCO 3.9.2. Additionally, Attachment (2) contains the list of mark-up inserts for Reference (a) to aid in the review.

Also included in Attachment (3) is a mark-up of the corresponding Ginna Technical Specification Bases pages. The Bases are being submitted for information only.

Should you have questions regarding this matter, please contact Thomas Harding at 585-771-5219, or Thomas. HardingJr(ocenqllc.com.

Attachments: (1) Revised Mark-up of LCO 3.9.2 (2) Inserts for Technical Specification Page Markups (3) Proposed Technical Specification Bases Changes AU) I 0a W PL11\11eC__ 1002Y.1-ecý

Document Control Desk May 3, 2011 Page 2 STATE OF NEW YORK

TO WIT:

COUNTY OF WAYNE I, John T. Carlin, being duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

§bSCribed and sworn before me, a Notary Public in and for the State of New York and County of, Al eon .. , this __Z_ day of MQ&) .. 2011.

WITNESS my Hand and Notarial Seal:

Notary Public' SHARON L MILLER Notae Public, State of New York-Registration No. 01 M16017755 My Commission Expires: MonmreDecember Commission Expires County 21, 2ý-I 1 204cmer10 Date cc: W.M. Dean, NRC D.V. Pickett, NRC Resident Inspector, NRC (Ginna)

ATTACHMENT (1)

REVISED MARK-UP OF LCO 3.9.2 1 -1 R.E. Ginna Nuclear Power Plant, LLC

Nuclear Instrumentation 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One source range A.1 Suspend CORE Immediately neutron flux monitor ALTERATIONS.

inoperable.

AND A.2 S endpo e re tivity Immediately

-=p additi B. Two source range B.1 Initiate action to restore one Immediately neutron flux monitors source range neutron flux inoperable, monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C. No audible count rate. C.1 Suspend CORE Immediately ALTERATIONS.

AND C.2 Suspend positive reactivity Immediately additions.

AND R.E. Ginna Nuclear Power Plant 3.9.2-1 AmendmentX

Nuclear Instrumentation 3.9.2 CONDITION REQUIRED ACTION COMPLETION TIME C.3 Perform SR 3.9.1.1 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.9.2.2 ----- NOTE -----------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 24 months R.E. Ginna Nuclear Power Plant 3.9.2-2 Amendmentx

ATTACHMENT (2)

INSERTS FOR TECHNICAL SPECIFICATION PAGE MARKUPS R.E. Ginna Nuclear Power Plant, LLC

Inserts for Technical Specification PaNe Markups INSERT 1

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

INSERT 2

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

Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SDM.

INSERT 3 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

INSERT 4 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

INSERT 5 No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and INSERT 6 Not applicable to Ginna Technical Specifications.

INSERT 7 less than that required to meet the minimum required boron concentration of LCO 3.9.1 INSERT 8 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

ATTACHMENT (3)

PROPOSED TECHNICAL SPECIFICATION BASES CHANGES R.E. Ginna Nuclear Power Plant, LLC

RTS Instrumentation B 3.3.1 Required Action E.2 is modified by a Note which states that the option to increase THERMAL POWER is not allowed if both intermediate range channels are inoperable or ifTHERMAL POWER is < 5E-11 amps. This prevents the plant from increasing THERMAL POWER when the trip capability of the Intermediate Range Neutron Flux trip Function is not available.

F.1, F.2, and F.3 Condition F applies to the Source Range Neutron Flux trip Function when in MODE 2 with both Intermediate Range Channels < 5E-11amps. In this Condition, the NIS source range performs the monitoring and protection functions. With two channels inoperable, the RTBs and RTBBs must be opened immediately. With the RTBs and RTBBs opened, the core is in a more stable condition.

With one channel inoperable, operations involving positive reactivity additions shall be suspended immediately. This will preclude any power escalation since with only one source range channel OPERABLE, core protection is severely reduced. The inoperable channel must also be

," *A*S

restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

G.1 If the Required Actions of Condition D, E, or F cannot be met within the specified Completion Times, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant 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 . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

H.1, H.2, and H.3 Condition H applies to an inoperable source range channel in MODE 3, 4, or 5 with the CRD System capable of rod withdrawal or all rods not fully inserted. In this Condition, the NIS source range performs the monitoring and protection functions. With two channels inoperable, at least one channel must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable considering the low probability of an event occurring during this interval.

With one of the source range channels inoperable, operations involving positive reactivity additions must be suspended immediately and 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore it to OPERABLE status. The suspension of positive reactivity additions will preclude any power escalation.

R.E. Ginna Nuclear Power Plant B 3.3.1-32 RevisionA!9"

INSERT BASES 1 Required Action F.2 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g., temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided they are accounted for in the calculated SDM.

INSERT BASES 2 Required Action H.2 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g., temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided they are accounted for in the calculated SDM.

RTS Instrumentation B 3.3.1 1.1 and 1.2 If the Source Range trip Function cannot be restored to OPERABLE status within the required Completion Time of Condition H, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, action must be immediately initiated to fully insert all rods. Additionally, the CRD System must be placed in a condition incapable of rod withdrawal within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is sufficient to accomplish the Required Action, and takes into account the low probability of an event occurring during this interval.

J.1 and J.2 Condition J applies when the required Source Range Neutron Flux channel is inoperable in MODE 3, 4, or 5 with the CRD System not capable of rod withdrawal and all rods are fully inserted. In this Condition, the NIS source range performs the monitoring function. With no source range channels OPERABLE, operations involving positive reactivity additions shall be suspended immediately. -ThiS will przluedc Rny power caGGation.

Also, the SDM must be verified once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter as per SR 3.1.1.1, SDM verification. With no source range channels OPERABLE, core protection is severely reduced. Verifying the SDM once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allows sufficient time to perform the calculations and determine that the SDM requirements are met and to ensure that the core reactivity has not changed. Required Action J.1 precludes any positive reactivity additions; therefore, core reactivity should not be increasing, and a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is adequate. The Completion Time of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on operating experience in performing the Required Actions and the knowledge that plant conditions will change slowly.

SF-.*I"

AF..S K.__

Condition K applies to the following reactor trip Functions:

Pressurizer Pressure-Low; Reactor Coolant Flow-Low (Two Loops);

RCP Breaker Position (Two Loops);

Undervoltage-Bus IIA and 1iB; and

Underfrequency-Bus 11A and 1IB.

R.E. Ginna Nuclear Power Plant B 3.3.1-33 Revision.4,2"

INSERT BASES 3 Required Action J.1 is modified by a Note which permits plant temperature changes provided the temperature change is accounted for in the calculated SDM. Introduction of temperature changes, including temperature increases when a positive MTC exits, must be evaluated to ensure they do not result in a loss of required SDM.

RCS Loops - MODES 1 < 8.5% RTP, 2, and 3 B 3.4.5 The Note permits all RCPs to be de-energized for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period in MODE 3. The purpose of the Note is to perform tests that are designed to validate various accident analyses values. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test was satisfactorily performed during the initial startup testing program (Ref. 5). If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again.

The no flow test may be performed in MODE 3, 4, or 5. The Note permits the de-energizing of the pumps in order to perform this test and validate the assumed analysis values. As with the validation of the pump coastdown curve, this test should be performed only once unless the low characteristics of the RCS are changed. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period specified is adequate to perform the desired tests, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

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

QESCT j St. 4. a. No operations are permitted that would dilute the RCS boron concentra ion thr.... MA*nti,1Hni the ,mArgir t, Oritcn.litY. B. rcn Fed4et -n is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

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

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

R.E. Ginna Nuclear Power Plant B 3.4.5-3 Revision,4(K

INSERT BASES 4 with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained

RCS Loops - MODES 1 < 8.5% RTP, 2, and 3 B 3.4.5 B.1 If restoration of the inoperable loop is not possible within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the plant must be brought to MODE 4. In MODE 4, the plant may be placed on the Residual Heat Removal System. The additional Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is compatible with required operations to achieve cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging plant systems.

C.1. C.2, and C.3 If two RCS loops are inoperable, or no RCS loop is in operation, except during conditions permitted by the Note in the LCO section, all CRDMs must be de-energized by opening the RTBs or de-energizing the MG (INSERT\

sets. All operations involving a rcdu.tion of RS boron8 cn.,tretatie ,

must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod

,,,withdrawal. &The immediate Completion Time reflects the importance of (o maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

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

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

SR 3.4.5.2 This SR requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is

_>16% for two RCS loops. If the SG secondary side narrow range water level is < 16%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink for removal of reactor or decay heat. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.

R.E. Ginna Nuclear Power Plant B 3.4.5-5 Revisionx

INSERT BASES 5 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 INSERT BASES 6 Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops - MODE 4 B 3.4.6 Note 1 permits all RCPs and RHR pumps to be de-energized for* 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests that are designed to validate various accident analyses values. One of the tests performed during the startup testing program was the validation of rod drop times during cold conditions, both with and without flow (Ref. 1). If changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values must be revalidated by conducting the test again. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits the de-energizing of the pumps in order to perform this test and validate the assumed analysis values. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron

(~IVA~j-'\concentration 04hzcfere Fmaintaininig the M8Orin to oritGIoai~t'; BSoron

=e'-'--- A- is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

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

Note 2 requires that the pressurizer water volume be < 324 cubic feet (38% level), or that the secondary side water temperature of each SG be

< 501F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature less than or equal to the LTOP enable temperature specified in the PTLR. The water volume limit ensures that the pressurizer willaccommodate the swell resulting from an RCP start. Restraints on the pressurizer water volume and SG secondary side water temperature prevent a low temperature overpressure event due to a thermal transient when an RCP is started and the colder RCS water enters the warmer SG and expands. Violation of this Note places the plant in an unanalyzed condition.

An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.2. RCPs are OPERABLE ifthey are capable of being powered and are able to provide forced flow if required.

R.E. Ginna Nuclear Power Plant B 3.4.6-2 Revisionx

INSERT BASES 7 with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained

RCS Loops - MODE 4 B 3.4.6 B.1 If one RHR loop is inoperable and both RCS loops are inoperable, an inoperable RCS or RHR loop must be restored to OPERABLE status to provide a redundant means for decay heat removal.

If a second loop cannot be restored, the plant must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the plant to MODE 5 is a conservative action with regard to decay heat removal. With only one RHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 (< 200 0 F) rather than MODE 4 (200 to 3500 F). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

Required Action B.1 is modified by a Note stating that only the Required Actions of Condition C are entered if all RCS and RHR loops are inoperable. With all RCS and RHR loops inoperable, MODE 5 cannot be entered and Required Actions C.1 and C.2 are the appropriate remedial actions.

CA and C.2

Ncs*F-cIT 'ASE.S' BIf no loop is OPERABLE or in operation, except during conditions permitted by Note 1 in the LCO section, all operations involving-E-roduction of .RCS borcn encntretorti8 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must A -- be initiated. BeOR. dil'utio. rcquircs fcrczd clrcultltin for prcpcr ,mxingAR,

-tthe margin to criticality must not be reduced in this type of operation.

QThe immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one RCS or RHR loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

Use of control board indication for these parameters is an acceptable verification. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

R.E. Ginna Nuclear Power Plant B 3.4.6-4 RevisionX

INSERT BASES 8 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 INSERT BASES 9 Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops - MODE 5, Loops Filled B 3.4.7 LCO The purpose of this LCO is to require that at least one of the RHR loops be OPERABLE and in operation with an additional RHR loop OPERABLE or one SG with a secondary side water level _>16%. One RHR loop provides sufficient forced circulation to perform the safety functions of the reactor coolant under these conditions. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is one SG with a secondary side water level > 16%.

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

Note 1 permits all RHR pumps to be de-energized _ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests designed to validate various accident analyses values. One of the tests performed during the startup testing program was the validation of rod drop times during cold conditions, both with and without flow (Ref. 1). If changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values must be revalidated by conducting the test again.

The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits de-energizing of the pumps in order to perform this test and validate the assumed analysis values. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron tNSE- SA.E.S I1 concentratio'thcrcfcrc maintai*nig thc margin te criticality. Bcrcn rcduieti*, is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

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

Note 2 allows one RHR loop to be inoperable for a period < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance may be used seperately for each individual loop.

Note 3 requires that the pressurizer water volume be < 324 cubic feet (38% level), or that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of a R.E. Ginna Nuclear Power Plant B 3.4.7-2 Revisionx,

INSERT BASES 10 with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron reduction with coolant at boron concentrations less than required to assure SDM is maintained

RCS Loops - MODE 5, Loops Filled B 3.4.7 Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODE 1 > 8.5% RTP";

LCO 3.4.5, "RCS Loops - MODES 1 < 8.5% RTP, 2, AND 3";

LCO 3.4.6, "RCS Loops - MODE 4";

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

LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-Water Level > 23 Ft" (MODE 6); and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Water Level < 23 Ft" (MODE 6).

ACTIONS A.1 and A.2 If one RHR loop is inoperable and both SGs have secondary side water levels < 16%, redundancy for heat removal is lost. Action must be initiated immediately to restore a second RHR loop to OPERABLE status or to restore at least one SG secondary side water level. Either Required Action A.1 or Required Action A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal. The action to restore must continue until an RHR bop is restored to OPERABLE status or SG secondary side water level is restored.

B.1 and B.2 I NSE.FZT 9ASES u If no RHR loop is in operation, except during conditions permitted by Notes 1 and 4, or if no loop is OPERABLE, all operations involving-e--C_-

rodu-ction Of RCS boron, concentration must be suspended and action to restore one RHR loop to OPERABLE status and operation must be iniiatd.Tc prc'vcnt boron, dilution, forced circul__tion ic reguirod to QN~~cT5-ropo12 ýFd miAing an prosar'.' the ma'rgin to Gplticality in thie ty~,pe of.

-,pef,:,i . The immediate Completion Times reflect the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

R.E. Ginna Nuclear Power Plant B 3.4.7-4 RevisionX'-

INSERT BASES 11 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 INSERT BASES 12 Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 Note 1 permits all RHR pumps to be de-energized for < 15 minutes when switching from one loop to another. The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short and requires that the following conditions be met:

.o

a. --W.p..at.O.. oWo porrn..tcd that wou'ld d"lut the RCS boron concontration,.thrfo9 m .aintaining the mar*gin to ..itficalityi.

Boro Feduation icprohibitod boc~auce a unifoFrm concon_.trAtio dictribu1 t!o throghou49t the RCS cannot be eAnWurcd whon innatural eioFulaticn-;

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

c. No draining operations are permitted that would further reduce the RCS water volume and possibly cause a more rapid heatup of the N E.T BASE.S 14-* remaining RCS inventory.

Note 2 allows one RHR loop to be inoperable for a period of < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permils periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months I allowance may be used seperately for each individual loop.

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

RHR pumps are OPERABLE ifthey are capable of being powered and are able to provide flow if required. Also included are all necessary support systems not addressed by applicable LCOs (e.g., component cooling water and service water).

APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System. The RCS loops are considered not filled from the time period beginning with the opening of isolation valves and draining of the RCS and ending with the completion of filling and venting the RCS.

R.E. Ginna Nuclear Power Plant B 3.4.8-2 Revision.,q'J*"'

INSERT BASES 13 No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

INSERT BASES 14 Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODE 1 > 8.5% RTP";

LCO 3.4.5, "RCS Loops - MODES 1 < 8.5% RTP, 2, and 3";

LCO 3.4.6, "RCS Loops - MODE 4";

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

LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-Water Level _>23 Ft" (MODE 6); and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Water Level < 23 Ft" (MODE 6).

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

The action to restore must continue until the second RHR loop is restored to OPERABLE status.

B.1 and B.2 If no RHR loop is in opeBtion, except during conditions permitted by Note I,,-. 1 1, or if no loop is OPERABLE all operations involving 2 reduction of RCS Tco-; ncetrRtion must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. -Te-PF8Y1t bo ron dil. tion, forc

... ci . .d ..tio. - ....... d t -.P.O.. pr - r m......iXin @..

.th margin to criticality in this type of operation.,The immediate

,,.-<Completion Time reflects the impafncelof maintaining operation for heat CAremoval The action to resbre must continue until one loop is restored to OPERABLE status and operation.

R.E. Ginna Nuclear Power Plant B 3.4.8-3 Revisiong

INSERT BASES 15 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 INSERT BASES 16 Suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

AC Sources - MODES 5 and 6 B 3.8.2 A.2.1. A.2.2. A.2.3. and A.2.4 With the offsite power circuit not available to all required AC electrical trains, the option exists to declare all required features inoperable per Required Action A.1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions

!A,'/*t'E2T /,fJ~fs ,7 mo;,omen-t of irr'-Idi*tod .Fola*c..-.mb.ioc", 3n."d oporntionc in'.*o-'A,-, p.ooti-'

" *_*:Feat:.v!t' ad-d-.t*Q.R.: *6- :.a. aers-ptable ept!-',- te ReqL:!;ed .A..1t R.A.A.

Performance of Required Actions A.2.1, A.2.2, and A.2.3 shall not preclude completion of movement of a component to a safe position or normal cooldown of the coolant volume for the purpose of system temperature control within established procedures.

It is further required to immediately initiate action to restore the required offsite power AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required offsite power sources should be completed as quickly as possile in order to minimize the time during which the plant safety systems may be without sufficient power.

B.1. B.2. B.3. and B.4 With the required DG inoperable, the minimum required diversity of AC power sources is not available.diTeto fuot , .e qomioc, d tp,.tt OnE ioligpasitive rnactiv ity additions be immediately suspendzd Performance of Required Action B.1, B.2, and B.3 shall not preclude completion of movement of a component to a safe position or normal cooldown of the coolant volume for the purpose of temperature control within established procedures.

It is further required to immediately initiate action to restore the required DG to OPERABLE status and to continue this action until restoration is accomplished in order to provide the necessary AC power redundancy to plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DG should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient redundant power.

R.E. Ginna Nuclear Power Plant B 3.8.2-5 RevisionA<

INSERT BASES 17 It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

INSERT BASES 18 It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

DC Sources- MODES 5 and 6 B 3.8.5 The AC powered and DC powered fan ventilation units associated with the Class 1 E battery systems are not required to be OPERABLE for this LCO, but some form of ventilation may be required to meet SR 3.8.6.4 and SR 3.8.6.5.

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6 provide assurance that systems required to mitigate the affects of a DBA and to maintain the plant in the cold shutdown or refueling condition are available.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4, "DC Sources - MODES 1, 2, 3, and 4."

ACTIONS Although two trains may be required by LCO 3.8.10, "Distribution Systems - MODES 5 and 6," the remaining DC electrical train may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS, and operations with a potential for positive reactivity additions. By allowing the option to declare required features inoperable associated with the required inoperable DC power source(s), appropriate restrictions will be implemented in accordance with the LCO ACTIONS of the affected required features. Required features remaining powered from a DC electrical source, even ifthat source is considered inoperable because it is not powering other required features, are not declared inoperable by this Required Action.

A.2.1. A.2.2. A.2.3. and A.2.4 With one or more required DC electrical power sources inoperable, the option exists to declare all required features inoperable per Required Action A.1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made.

.Thoroforo, immodiato s-cpencin of CORE ALTERATIONS, ,ney,-mnt o-,f irrad iatd fuel As12mb!ia, and op.ratione Rs 0.. i n". positive r.actiyity.

addiior-, ... 8Aan opt.blo option to RoqUirzd Aoticn AA. Performance of Required Actions A.2.1, A.2.2, and A.2.3 shall not preclude completion of movement of a component to a safe position or normal cooldown of the coolant volume for the purpose of system temperature control within established procedures.

It is further required to immediately initiate action to restore the required DC electrical power source and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety systems.

R.E. Ginna Nuclear Power Plant B 3.8.5-4 RevisionX

INSERT BASES 19 Therefore allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions) that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

AC Instrument Bus Sources - MODES 5 and 6 B 3.8.8 ACTIONS A.1 Although two trains may be required by LCO 3.8.10, "Distribution Systems - MODES 5 and 6," the remaining OPERABLE AC instrument bus train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and operations with a potential for positive reactivity additions. By allowing the option to declare required features inoperable with the associated AC instrument bus power source inoperable, appropriate restrictions will be implemented in accordance with the LCO ACTIONS of the affected required features. This condition must be entered when the inverters for Instrument Bus A or C are required and inoperable, or the Class 1E CVT for Instrument Bus B is required and inoperable.

A.2.1. A.2.2. A.2.3. and A.2.4 With one or more required AC instrument bus power sources inoperable, the option exists to declare all required features inoperable per Required Action A.1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made.

STherzferz, immediate awspeflsief ef CORE ALTFERATIONS, Fnevement (rA/f,~i AS~S~" ofirraiathf-al 2rrambliee, and Gpor3tions: iolngpocitivo Fmctivity addit*i*n is an a.ceptable option to Ro.quid ^,Acio A.!. Performance of Required Actions A.2.1, A.2.2, and A.2.3 shall not preclude completion of movement of a component to a safe position or normal cooldown of the coolant volume for the purpose of system temperature control within established procedures.

It is further required to immediately initiate action to restore the required AC instrument bus power source and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC instrument bus power source should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power or powered from an alternate power source.

R.E. Ginna Nuclear Power Plant B 3.8.8-4 Revision,2<

INSERT BASES 20 Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions) that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Distribution Systems - MODES 5 and 6 B 3.8.10 ACTIONS Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and operations involving positive reactivity additions. By allowing the option to declare required features associated with an inoperable distribution subsystem or train inoperable, appropriate restrictions are implemented in accordance with the LCO ACTIONS of the affected required features.

A.2.1. A.2.2. A.2.3, A.2.4. and A.2,5 With one or more required electrical power distribution subsystems or trains inoperable, the option exists to declare all required features inoperable per Required Action A.1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. ThIRBfrc~, immedia*t .u.p.nci. n ef CRE ALTERATIONS, MovoMont of irrodiatod fuol ascemblica, and Q

(I{v involving positive reactivity' A.d-ditoN+.

.... +),operations is an a +coptablo option te ,Rfquircd A.ti.n A.A. Performance of Required Actions A.2.1, A.2.2, and A.2.3 shall not preclude completion of movement of a component to a safe position or normal cooldown of the coolant volume for the purpose of system temperature control within established procedures.

It is further required to immediately initiate action to restore the required AC, DC, and AC instrument bus electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems.

In addition to performance of the above conservative Required Actions, a required residual heat removal (RHR) loop may be inoperable. In this case, Required Actions A.2.1, A.2.2, A.2.3, and A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal.

Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered.

Therefore, Required Action A.2.5 requires declaring RHR inoperable, which results in taking the appropriate RHR actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power.

R.E. Ginna Nuclear Power Plant B 3.8.10-5 Revision,4;K

INSERT BASES 21 Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions) that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Boron Concentration B 3.9.1 LCO The LCO requires that a minimum boron concentration be maintained in the refueling canal, the refueling cavity and the portions of the RCS that are hydraulically coupled with the reactor core while in MODE 6. The boron concentration limit specified in the COLR ensures that a core keff of

< 0.95 is maintained during fuel handling operations and that a core keff of

< 1.0 is maintained during a boron dilution event. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a keff < 0.95 during fuel handling operations. In MODES 1 and 2 with keff

>_1.0, LCO 3.1.4, "Rod Group Alignment Limits," LCO 3.1.5, "Shutdown Bank Insertion Limit," and LCO 3.1.6, "Control Bank Insertion Limits" ensure an adequate amount of negative reactivity is available to shut down the reactor. In MODES 2 with keff < 1.0 and MODES 3, 4, and 5, LCO 3.1.1, "SHUTDOWN MARGIN (SDM)" ensures an adequate amount of negative reactivity is available to maintain the reactor subcritical.

ACTIONS A.1, A.2, and A.3 If the boron concentration of the filled portions of the RCS, the refueling canal, and the refueling cavity hydraulically coupled to the reactor core, is less than its limit, an inadvertent criticality may occur due to a boron dilution event or incorrect fuel loading. To minimize the potential of an inadvertent criticality resulting from a fuel loading error or an operation that could cause a reduction in boron concentration, CORE ALTERATIONS and positive reactivity additions must be suspended immediately.

Suspension of CORE ALTERATIONS and positive reactivity additions (i.o., other th-n,

... normal o.ldow.In. of the.olumo coolant fcr the Pur.~e, f..

.y.t.m tepe..atur c.n@trol within; octablishod p.roodurco) shall not preclude moving a component to a safe position.

.2. In addition to immediately suspending CORE ALTERATIONS-ef positive reactivity additions, boration to restore the concentration must be initiated immediately.

R.E. Ginna Nuclear Power Plant B 3.9.1-3 RevisionA!9'

INSERT BASES 22 Operations that individually add limited positive reactivity (e.g., temperature fluctuations from inventory addition or temperature control fluctuations), but when combined with all other operations affecting core reactivity (e.g., intentional boration) result in overall net negative reactivity addition, are not precluded by this action.

Nuclear Instrumentation B 3.9.2 With the discharge of fuel from core positions adjacent to source range detector locations, counts decreasing to zero is the expected response.

Based on this indication alone, source range detection should not be considered inoperable. Following a full core discharge, source range response is verified with the initial fuel assemblies reloaded.

APPLICABILITY In MODE 6, the source range neutron flux monitors must be OPERABLE to determine changes in core reactivity. There are no other direct means available to check core reactivity conditions in this MODE. In MODES 2, 3, 4, and 5, these same installed source range detectors and circuitry are also required to be OPERABLE by LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation."

ACTIONS A.1 and A.2 INSE-RT SASES ?-.*

With only one source range neutron flux monitor OPERABLE, redundancy has been lost. Since these instruments are the only direct means of monitoring core reactivity conditions, CORE ALTERATIONS IIklSUr..JrT A. $ an p" ..... .. .... must be suspended immediately.

Performance of Required Actions A.1 and A.2 shall not preclude completion of movement of a component to a safe position (i.e., other than normal cooldown of the coolant volume for the purpose of system temperature control within established procedures).

B.1 and B.2 With no source range neutron flux monitor OPERABLE there are no direct means of detecting changes in core reactivity. Therefore, actions to restore a monitor to OPERABLE status shall be initiated immediately and continue until a source range neutron flux monitor is restored to OPERABLE status.

Since CORE ALTERATIONS and positive reactivity additions are not to be made per Required Actions A.1 and A.2, the core reactivity condition is stabilized until the source range neutron flux monitors are OPERABLE.

This stabilized condition is determined by performing SR 3.9.1.1 to ensure the required boron concentration exists.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is sufficient to obtain and analyze coolant samples for boron concentration. The Frequency of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures unplanned changes in boron concentration would be identified. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, considering the low probability of a change in core reactivity during this time period.

R.E. Ginna Nuclear Power Plant B 3.9.2-2 Revision,ý2e

INSERT BASES 23 introduction of coolant into the RCS with boron concentration less than required to meet the minimum boron concentration LCO 3.9.1 INSERT BASES 24 Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

RHR and Coolant Circulation - Water Level _>23 Ft B 3.9.4 The LCO permits de-energizing the required RHR pump for short durations provided no operations are permitted that would cause a reduction in the RCS boron concentration. This conditional de-energizing of the required RHR pump does not result in a challenge to the fission product barrier or result in coolant stratification.

RHR and Coolant Circulation-Water Level > 23 Ft satisfies criterion 2 of the NRC Policy Statement.

LCO Only one RHR loop is required for decay heat removal in MODE 6, with the water level __23 ft above the top of the reactor vessel flange, because the volume of water above the reactor vessel flange provides backup decay heat removal capability. One RHR loop is required to be OPERABLE and in operation to provide mixing of borated coolant to minimize the possibility of criticality.

An OPERABLE RHR loop includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. The flow path starts in the RCS loop "A" hot leg and is returned to the RCS loop "B" cold leg. Also included are all necessary support systems not addressed by applicable LCOs (e.g., component cooling water and service water). INSERT ,S SE .

The LCO is modified by a Note that allows the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided no operations are permitted that would cauc ....... in of tho RCS b.rn c.. .... ra....... Bron ro.du..tio is prohibited because uniform concentration distribution cannot be ensured without forced circulation.

This allows the operator to view the core and permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles. This also permits operations such as RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of water in the refueling cavity. Should both RHR loops become inoperable at anytime during operation in accordance with this Note, the Required Actions of this LCO should be immediately taken.

APPLICABILITY One RHR loop must be OPERABLE and in operation in MODE 6, with the water level > 23 ft above the top of the reactor vessel flange, to provide decay heat removal and mixing of the borated coolant. The 23 ft water level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.6, "Refueling Cavity Water Level."

R.E. Ginna Nuclear Power Plant B 3.9.4-2 Revision,2<

INSERT BASES 25 dilute the RCS boron concentration with coolant at boron concentrations less than required to meet the minimum boron concentration of LCO 3.9.1. Boron concentration reduction with coolant at boron concentrations less than required to assure the minimum required RCS boron concentration is maintained

RHR and Coolant Circulation - Water Level > 23 Ft B 3.9.4 Requirements for the RHR System in MODES 1, 2, 3, 4, and 5 are covered by LCO 3.4.6, "RCS Loops - MODE 4;" LCO 3.4.7, "RCS Loops -

MODE 5, Loops Filled;" LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled", LCO 3.5.2, "ECCS-MODES 1, 2, and 3," and LCO 3.5.3, "ECCS-MODE 4". The RHR loop requirements in MODE 6 with the water level

< 23 ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-Water Level < 23 Ft."

ACTIONS A.1, A.2, and A.3 If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations. -Redueed-boron....c...........c.n.occur.b.......ddition.of.....r..ith.....

suspendcd ........ .

With no forced circulation cooling, decay heat removal from the core occurs by natural convection to the heat sink provided by the water above the core. A minimum refueling water level of 23 ft above the reactor vessel flange provides an adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading a fuel assembly, is a prudent action under this condition. Therefore, actions shall be taken immediately to suspend loading irradiated fuel assemblies in the core.

With the plant in MODE 6 and the refueling water level _>23 ft above the top of the reactor vessel flange, removal of decay heat is by ambient losses only. Therefore, corrective actions shall be initiated immediately and shall continue until RHR loop requirements are satisfied.

A.4 If RHR loop requirements are not met, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boiling in that time.

R.E. Ginna Nuclear Power Plant B 3.9.4-3 RevisionX

INSERT BASES 26 Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

RHR and Coolant Circulation - Water Level < 23 Ft B 3.9.5 ACTIONS A.1 and A.2 If less than the required number of RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status or until > 23 ft of water level is established above the reactor vessel flange. When the water level is > 23 ft above the reactor vessel flange, the Applicability changes to that of LCO 3.9.4, and only one RHR loop is required to be OPERABLE and in operation.

An immediate Completion Time is necessary for an operator to initiate corrective actions.

B.1 and B.2 If no RHR loop is in operation, there will be no forced circulation to provide mixing to establish uniform boron concentrations. The pe*e-i--,

f.. r.du. b .do............tERI... by tho additien . . a wer

. f w to.r with QNErIs~ crevzrt a erit*88lt'..

,- eyent. TheFoforo 9noritfiGAr inGIVOlRin a~ Fnduc'tion in-RCSbor-on r......... tr..tio...m .ucbe .. p....d

..... imme..t.ly. Actions shall also be initiated immediately, and continued, to restore one RHR loop to operation. Since the plant is in Conditions A and B concurrently, the restoration of two OPERABLE RHR loops and one operating RHR loop should be accomplished expeditiously.

B.3 If no RHR loop is in operation, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures that dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boiling in that time.

R.E. Ginna Nuclear Power Plant B 3.9.5-3 Revision

INSERT BASES 27 Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

v t e Letter Sequence Request
TAC:ME5444, Define Operations Involving Positive Reactivity Additions (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2011-05-03 [Table View]

ML11129A013

Text

SUBJECT:

REFERENCE:

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