Text

Issuance of Amendment to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (CAC No. MF9666; EPID L-2017-LLA-0223)
	ML18043A505
Person / Time
Site:	Clinton
Issue date:	03/22/2018
From:	Jennivine Rankin; Plant Licensing Branch III
To:	Bryan Hanson; Exelon Generation Co
	Rankin J, NRR/DORL/LPLIIII, 415-1530
References
	CAC MF9666, EPID L-2017-LLA-0223
	Download: ML18043A505 (117)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 March 22, 2018

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NO.

MF9666; EPID L-2017-LLA-0223)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 216 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit No. 1. The amendment consists of changes to the technical specifications (TSs) in response to your application dated May 1, 2017, as supplemented by letters dated November 15, and December 20, 2017.

The amendment replaces existing TS requirements related to "operations with a potential for draining the reactor vessel" with new requirements on reactor pressure vessel water inventory control to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor pressure vessel water level to be greater than the top of active irradiated fuel. The changes are based on TS Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Docket No. 50-461

Enclosures:

1. Amendment No. 216 to NPF-62

2. Safety Evaluation cc w/enclosures: Listserv Sincerely,

~

~ci Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-461 CLINTON POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 216 License No. NPF-62

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (the licensee), dated May 1, 2017, as supplemented by letters dated November 15, and December 20, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-62 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 216, are hereby incorporated into this license.

Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented prior to entering MODE 4 during the next refueling outage, C1R18, currently planned for April 2018.

FOR THE NUCLEAR REGULATORY COMMISSION OJ9.<V_

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: March 2 2, 2 o 1 8

ATTACHMENT TO LICENSE AMENDMENT NO. 216 CLINTON POWER STATION, UNIT NO. 1 FACILITY OPERATING LICENSE NO. NPF-62 DOCKET NO. 50-461 Replace the following pages of the Facility Operating License and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License Remove Insert Page 3 Page 3 TSs Remove Insert Remove Insert Remove Insert 1.0-1 1.0-1 3.3-51 3.3-51 3.6-43 3.6-43 1.0-2 1.0-2 3.3-52 3.3-52 3.6-44 3.6-44 1.0-3 1.0-3 3.3-53 3.3-53 3.6-47 3.6-47 1.0-4 1.0-4 3.3-54 3.6-49 3.6-49 1.0-5 1.0-5 3.3-54a 3.6-51 3.6-51 3.3-32 3.3-32 3.3-54b 3.3-54 3.6-52 3.6-52 3.3-33 3.3-33 3.3-56 3.3-56 3.6-53 3.6-53 3.3-35 3.3-35 3.3-57 3.3-57 3.7-4 3.7-4 3.3-39 3.3-39 3.3-59 3.3-59 3.7-5 3.7-5 3.3-40 3.3-40 3.3-60 3.3-60 3.7-6 3.7-6 3.3-41 3.3-41 3.3-64 3.3-64 3.7-8 3.7-8 3.3-42 3.3-42 3.3-77 3.3-77 3.7-9 3.7-9 3.3-43 3.3-43 3.5-1 3.5-1 3.7-10 3.7-10 3.3-43a 3.5-6 3.5-6 3.8-16 3.8-16 3.3-43b 3.5-7 3.5-7 3.8-17 3.8-17 3.3-43c 3.5-8 3.5-8 3.8-18 3.8-18 3.3-43d 3.5-9 3.5-9 3.8-27 3.8-27 3.3-44 3.3-44 3.5-10 3.5-10 3.8-28 3.8-28 3.3-45 3.3-45 3.5-11 3.5-11 3.8-36 3.8-36 3.3-46 3.3-46 3.5-12 3.5-12 3.8-37 3.8-37 3.3-47 3.3-47 3.6-3 3.6-3 3.8-43 3.8-43 3.3-48 3.3-48 3.6-7 3.6-7 3.3-49 3.3-49 3.6-9 3.6-9 3.3-50 3.3-50 3.6-14 3.6-14 (4)

Exelon Generation Company, pursuant to the Act and to 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)

Exelon Generation Company, pursuant to the Act and 1 O CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

Mechanical disassembly of the GE14i isotope test assemblies containing Cobalt-60 is not considered separation; and (7)

Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, to intentionally produce, possess, receive, transfer, and use Cobalt-60.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 1 O CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1)

Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix 8, as revised through Amendment No. 216, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 216

1.0 USE AND APPLICATION 1.1 Definitions Definitions 1.1

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term ACTIONS AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

CHANNEL CALIBRATION CHANNEL CHECK CHANNEL FUNCTIONAL TEST CLINTON Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

The APLHGR shall be applicable to a specific planar height and is equal to the sum of the LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors.

The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation.

This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.

The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.

(continued) 1.0-1 Amendment No. 216

Definitions 1.1 1.1 Definitions (continued)

CORE ALTERATION CORE OPERATING LIMITS REPORT (COLR)

DOSE EQUIVALENT I-131 DRAIN TIME CLINTON CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel.

The following exceptions are not considered to be CORE ALTERATIONS:

a.

Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);

and

b.

Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle.

These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5.

Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same inhalation CEDE dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present.

The inhalation CEDE dose conversion factors used for this calculation shall be those listed in Table 2.1 of Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," ORNL, 1989.

The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a.

The water inventory above the TAF is divided by the limiting drain rate;

b.

The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all (continued) 1.0-2 Amendment No. 216

Definitions DRAIN TIME (continued)

EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME CLINTON Definitions 1.1 penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.

c.

The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d.

No additional draining events occur; and

e.

Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued) 1.0-3 Amendment No.

216

Definitions 1.1 1.1 Definitions (continued)

END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME INSERVICE TESTING PROGRAM ISOLATION SYSTEM RESPONSE TIME LEAKAGE CLINTON The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.SSa(f).

The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE shall be:

a.

Identified LEAKAGE

1. LEAKAGE into the drywell such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b.

Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c.

Total LEAKAGE Sum of the identified and unidentified LEAKAGE;

d.

Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

(continued) 1.0-4 Amendment No. 216

Definitions 1.1 1.1 Definitions (continued)

LINEAR HEAT GENERATION RATE (LHGR)

LOGIC SYSTEM FUNCTIONAL TEST MINIMUM CRITICAL POWER RATIO (MCPR)

MODE OPERABLE~OPERABILITY RATED THERMAL POWER (RTP)

REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME CLINTON The LHGR shall be the heat generation rate per unit length of fuel rod.

It is the integral of the heat flux over the heat transfer area associated with the unit length.

A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY.

The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

The MCPR shall be the smallest critical power ratio (CPR) that exists in the core for each class of fuel.

The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 3473 MWt.

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued) 1.0-5 Amendment No. 216

ACTIONS (continued)

B.

CONDITION As required by Required Action A.l and referenced in Table 3.3.5.1-1.

CLINTON B.l AND ECCS Instrumentation 3.3.5.1 REQUIRED ACTION

NOTE---------

Only applicable for Functions l.a, l.b, 2.a, and 2.b.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions B.2

NOTE---------

AND B.3 Only applicable for Functions 3.a and 3.b.

Declare High Pressure Core Spray (HPCS)

System inoperable.

Place channel in trip.

3.3-32 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of HPCS initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Amendment No. 216

ACTIONS (continued)

C.

CLINTON CONDITION As required by Required Action A.1 and referenced in Table 3. 3. 5. 1-1.

C.1 AND C.2 REQUIRED ACTION

NOTE--------

Only applicable for Functions 1.c, 1.d, 2.c, and 2.d.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

Restore channel to OPERABLE status.

3.3-33 ECCS Instrumentation

3. 3. 5.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Amendment No. 216

ACTIONS (continued)

E.

CONDITION As required by Required Action A.l and referenced in Table 3.3.5.1-1.

CLINTON E.l AND E.2 REQUIRED ACTION

NOTE---------

Only applicable for Functions l.e, l.f, and 2.e.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

Restore channel to OPERABLE status.

3.3-35 ECCS Instrumentation 3.3.5.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions 7 days

( continued)

Amendment No.

216

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER ACTION A. l REQUIREMENTS VALUE FUNCTION

1. Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)

Subsystems

a. Reactor Vessel Water 1, 2, 3 2 la)

B SR 3.3.5.1.1 2 -14 8. 1 Level-Low Low Low, SR 3.3.5.1.2 inches Level 1 SR

3. 3. 5. 1. 3 (cl SR 3.3.5.1.5 SR

3. 3. 5. 1. 6 lcl

b. Drywell Pressure-High 1,2,3 2 la)

B SR 3.3.5.1.1 s 1. 88 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

c. LPCI Pump A 1, 2, 3 1

C SR 3.3.5.1.2 2 4.5 seconds Start-Time Delay SR 3.3.5.1.4 and Logic card SR 3.3.5.1.5 s 5.5 seconds

d. Reactor Vessel 1, 2, 3 4

C SR 3.3.5.1.1 2 454 psig Pressure-Low SR 3.3.5.1.2 and (Injection Permissive)

SR 3. 3. 5. 1. 3 lcl s 494 psig SR 3. 3. 5. 1. 4 (cl SR 3.3.5.1.5

e. LPCS Pump Discharge 1,2,3 1

E SR 3.3.5.1.1 2 750 gpm Flow-Low (Bypass)

SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

f. LPCI Pump A Discharge 1, 2, 3 1

E SR 3.3.5.1.1 2 900 gpm Flow-Low (Bypass)

SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

g. Manual Initiation 1, 2, 3 1

C SR 3.3.5.1.5 NA (continued)

(a) Also required to initiate the associated diesel generator.

(c)

1.

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined As-Found Tolerance band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2.

The instrument channel setpoint shall be reset to a value within the As-Left Tolerance of the Actual Trip Setpoint; otherwise, the channel shall be declared inoperable.

3.

The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined As-Found Tolerance and As-Left Tolerance bands shall be specified in the ORM.

CLINTON 3.3-39 Amendment No. 216

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 5)

Emergency Core cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A. l REQUIREMENTS VALUE

2.

LPCI B and LPCI C Subsystems

a.

Reactor vessel 1, 2, 3 2 (al B

SR 3.3.5.1.1

?: -148.1 Water Level-Low Low SR 3.3.5.1.2 inches Low, Level 1 SR 3.3.5.l.3icl SR 3.3.5.1.5 SR

3. 3. 5. 1. 6 lcl

b.

Drywell Pressure-1,2,3 2 (al B

SR 3.3.5.1.1

~ 1. 88 psig High SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 C.

LPCI Pump B 1,2,3 1

C SR 3.3.5.1.2

?: 4.5 seconds Start-Time Delay SR 3.3.5.1.4 and Logic Card SR 3.3.5.1.5

~ 5.5 seconds

d.

Reactor Vessel 1, 2, 3 4

C SR 3.3.5.1.1

?: 454 psig Pressure-Low SR 3.3.5.1.2 and (Injection SR

3. 3. 5. 1. 3 lcl

~ 494 psig Permissive)

SR 3. 3. 5. 1.4 lcl SR 3.3.5.1.5

e.

LPCI Pump B and 1,2,3 1 per pump E

SR 3.3.5.1.1

?: 900 gpm LPCI Pump C SR 3.3.5.1.2 Discharge Flow-Low SR 3.3.5.1.3 (Bypass)

SR 3.3.5.1.4 SR 3.3.5.1.5

f.

Manual Initiation 1,2,3 1

C SR 3.3.5.1.5 NA (continued)

(a) Also required to initiate the associated diesel generator.

(c)

1.

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined As-Found Tolerance band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2.

The instrument channel setpoint shall be reset to a value within the As-Left Tolerance of the Actual Trip Setpoint; otherwise, the channel shall be declared inoperable.

3.

The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined As-Found Tolerance and As-Left Tolerance bands shall be specified in the ORM.

CLINTON 3.3-40 Amendment No. 216

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

3. High Pressure Core Spray (HPCS) System

a. Reactor Vessel Water l, 2, 3 4 (al B

SR 3.3.5.1.1 2 -48.1 inches Level-Low Low, SR 3.3.5.1.2 Level 2 SR

3. 3. 5. 1. 3 lcl SR 3.3.5.1.5 SR

3. 3. 5. 1. 6 (cl

b. Drywell 1,2,3 4 (a)

B SR 3.3.5.1.1

~ 1. 88 psig Pressure High SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 C. Reactor Vessel Water 1, 2, 3 2

C SR 3.3.5.1.1

~ 54.6 inches Level-High, SR 3.3.5.1.2 Level 8 SR 3. 3. 5. 1. 3 (cl SR 3.3.5.1.5 SR 3. 3. 5. 1. 6 lcl

d. RCIC Storage Tank 1,2,3 2

D SR 3.3.5.1.1 2 3.0 inches Level-Low SR 3.3.5.1.2 SR

3. 3. 5. 1. 3 (Cl SR

3. 3. 5. 1. 4 lcl SR 3.3.5.1.5

e. Suppression Pool 1, 2, 3 2

D SR 3.3.5.1.1

~ 11 inches Water Level-High SR 3.3.5.1.2 SR 3. 3. 5. 1. 3 (cl SR 3. 3. 5. 1. 4 lcl SR 3.3.5.1.5

f. HPCS Pump 1, 2, 3 1

E SR 3.3.5.1.1 2 120 psig Discharge SR 3.3.5.1.2 Pressure-High SR 3.3.5.1.3 (Bypass)

SR 3.3.5.1.4 SR 3.3.5.1.5

g. HPCS System Flow 1,2,3 1

E SR 3.3.5.1.1 2 500 gpm Rate-Low(Bypass)

SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

h. Manual Initiation 1, 2, 3 1

C SR 3.3.5.1.5 NA (continued)

(a)

Also required to initiate the associated diesel generator.

(c)

1.

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined As-Found Tolerance band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2.

The instrument channel setpoint shall be reset to a value within the As-Left Tolerance of the Actual Trip Setpoint; otherwise, the channel shall be declared inoperable.

3.

The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined As-Found Tolerance and As-Left Tolerance bands shall be specified in the ORM.

CLINTON 3.3-41 Amendment No. 216

FUNCTION

4. Automatic Depressurization System (ADS) Trip System 1 (Logic A and E)

a. Reactor Vessel Water Level-Low Low Low, Level 1

b. Drywell Pressure-High

c. ADS Initiation Timer

d. Reactor Vessel Water Level-Low, Level 3 (Confirmatory)

e. LPCS Pump Discharge Pressure-High

f. LPCI Pump A Discharge Pressure-High

g. ADS Drywell Pressure Bypass Timer

h. Manual Initiation ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 lb) 1, 2 (bl, 3 (bl REQUIRED CHANNELS PER FUNCTION 2

2 1

1 2

2 2

2 CONDITIONS REFERENCED FROM REQUIRED ACTION A. l F

F G

G G

G SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SURVEILLANCE REQUIREMENTS 3.3.5.1.1 3.3.5.1.2

3. 3. 5. 1. 3 lei 3.3.5.1.5

3. 3. 5. 1. 6 lei 3.3.5.1.1 3.3.5.1.2 3.3.5.1.3 3.3.5.1.4 3.3.5.1.5 3.3.5.1.2 3.3.5.1.4 3.3.5.1.5 3.3.5.1.1 3.3.5.1.2 3.3.5.1.3 3.3.5.1.4 3.3.5.1.5 3.3.5.1.1 3.3.5.1.2 3. 3. 5. 1. 3 lei 3. 3. 5. 1. 4 le) 3.3.5.1.5 3.3.5.1.1 3.3.5.1.2

3. 3. 5. 1. 3 le)

3. 3. 5. 1.4 lei 3.3.5.1.5 3.3.5.1.2 3.3.5.1.4 3.3.5.1.5 3.3.5.1.5 ALLOWABLE VALUE c -148.1 inches oc; 1.88 psig oc; 117 seconds c 8.3 inches c 125 psig and

.:c. 176.3 psig c 115 psig and

.'.:. 135 psig oc; 6.5 minutes NA (continued)

(b)

With reactor steam dome pressure> 150 psig.

(c)

1.

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined As-Found Tolerance band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2.

The instrument channel setpoint shall be reset to a value within the As-Left Tolerance of the Actual Trip Setpoint; otherwise, the channel shall be declared inoperable.

3.

The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined As-Found Tolerance and As-Left Tolerance bands shall be specified in the ORM.

CLINTON 3.3-42 Amendment No. 216

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 5 of 5)

Emergency Core Cooling System Instrumentation FUNCTION

5.

ADS Trip System 2 (Logic B and F)

a. Reactor Vessel Water Level-Low Low Low, Level 1

b. Drywell Pressure-High

c. ADS Initiation Timer

d. Reactor Vessel Water Level-Low, Level 3 (Confirmatory)

e. LPCI Pumps B & C Discharge Pressure-High

f. ADS Drywell Pressure Bypass Timer

g. Manual Initiation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl 1, 2 (bl, 3 (bl REQUIRED CHANNELS PER FUNCTION 2

2 1

1 2 per pump 2

2 (b)

With reactor steam dome pressure> 150 psig.

CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 F

F G

G G

SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SR SURVEILLANCE REQUIREMENTS 3.3.5.1.1 3.3.5.1.2 3. 3. 5. 1. 3 (cl 3.3.5.1.5 3. 3. 5. 1. 6 (cl 3.3.5.1.1 3.3.5.1.2 3.3.5.1.3 3.3.5.1.4 3.3.5.1.5 3.3.5.1.2 3.3.5.1.4 3.3.5.1.5 3.3.5.1.1 3.3.5.1.2 3.3.5.1.3 3.3.5.1.4 3.3.5.1.5 3.3.5.1.1 3.3.5.1.2 3. 3. 5. 1. 3 (cl 3. 3. 5. 1. 4 lcl 3.3.5.1.5 3.3.5.1.2 3.3.5.1.4 3.3.5.1.5 3.3.5.1.5 ALLOWABLE VALUE 2 -148.1 inches

1. 88 psig

117 seconds 2 8.3 inches 2 115 psig and

, 135 psig

, 6.5 minutes NA (c)

1.

If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined As-Found Tolerance band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2.

The instrument channel setpoint shall be reset to a value within the As-Left Tolerance of the Actual Trip Setpoint; otherwise, the channel shall be declared inoperable.

3.

The Nominal Trip Setpoint and the methodology used to determine the Nominal Trip Setpoint, the predefined As-Found Tolerance and As-Left Tolerance bands shall be specified in the ORM.

CLINTON 3.3-43 Amendment No. 216

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 LCO 3.3.5.2 APPLICABILITY:

ACTIONS Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

According to Table 3.3.5.2-1.

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A. l Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.2-1 for the channel.

B. As required by B. l Declare associated Immediately Required Action A. l penetration flow and referenced in path(s) incapable of Table 3.3.5.2-1.

automatic isolation.

AND B.2 Calculate DRAIN TIME.

Immed.iately C. As required by C.l Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A. l and referenced in Table 3.3.5.2-1.

(continued)

CLINTON 3.3-43a Amendment No.

216

ACTIONS (continued)

CONDITION D. As required by D.1 Required Action A.1 and referenced in Table 3.3.5.2-1.

OR D.2 E. As required by E.1 Required Action A.1 and referenced in Table 3.3.5.2-1.

F. Required Action and F.1 associated Completion Time of Condition C, D, or E not met.

CLINTON RPV Water Inventory Control Instrumentation 3.3.5.2 REQUIRED ACTION COMPLETION TIME Declare HPCS system 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

Align the HPCS pump 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months suction to the suppression pool.

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

Declare associated Immediately ECCS injection/spray subsystem inoperable.

3.3-43b Amendment No.

216

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE SR 3.3.5.2.1 Perform CHANNEL CHECK.

SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

CLINTON 3.3-43c FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 216

FUNCTION

1.

Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS)

Subsystems

a.

Reactor Vessel Pressure -

Low (Injection Permissive)

b.

LPCS Pump Discharge Flow -

Low (Bypass)

C.

LPCI Pump A Discharge Flow -

Low (Bypass)

2.

LPCI Band LPCI C Subsystems

a.

Reactor Vessel Pressure -

Low (Injection Permissive)

b.

LPCI Pump B and LPCI Pump C Discharge Flow -

Low (Bypass)

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 2)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 4,5 4,5 4,5 4,5 4,5 REQUIRED CHANNELS PER FUNCTION 1 per pumplal 1 per pumplal 1 per pumplal CONDITIONS REFERENCED FROM REQUIRED ACTION A. l C

E E

C E

SURVEILLANCE REQUIREMENTS SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 5

?

5

?

ALLOWABLE VALUE 494 psig 750 gpm 900 gpm 494 psig 900 gpm (continued)

(a)

Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."

CLINTON 3.3-43d Amendment No. 216

FUNCTION

3.

High Pressure Core Spray (HPCS) System

a.

RCIC Storage Tank Level -

Low

b.

HPCS Pump Discharge Pressure - High (Bypass)

C.

HPCS System Flow Rate - Low (Bypass)

4.

RHR System Isolation

a.

Reactor Vessel Water Level -

Low, Level 3

5.

Reactor Water Cleanup (RWCU) System Isolation

a.

Reactor Vessel Water Level -

Low Low, Level 2 RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 2 of 2)

RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 4 (bl 5 (bl 4, 5 4, 5 lei lei REQUIRED CHANNELS PER FUNCTION 2 in one trip system 2 in one trip system CONDITIONS REFERENCED FROM REQUIRED ACTION A. l D

E E

B B

SURVEILLANCE REQUIREMENTS SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 SR 3.3.5.2.1 SR 3.3.5.2.2 ALLOWABLE VALUE

~ 3.0 inches

~ 120 psig

~ 500 gpm

~ 8.3 inches

~ -48.1 inches (a)

Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."

(b)

When HPCS is OPERABLE for compliance with LCO 3. 5. 2, "RPV Water Inventory Control, " and aligned to the RCIC storage tank while tank water level is not within the limits of SR 3.5.2.3.

(c)

When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

CLINTON 3.3-44 Amendment No. 216

3.3 INSTRUMENTATION RCIC System Instrumentation 3.3.5.3 3.3.5.3 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.3 The RCIC System instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

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

Separate Condition entry is allowed for each channel.

A.

B.

C.

CONDITION One or more channels A,l inoperable.

As required by Required Action A. l and referenced in Table 3.3.5.3-1.

As required by Required Action A.l and referenced in Table 3.3.5.3-1.

B.l AND B.2 C.l CLINTON REQUIRED ACTION Enter the Condition referenced in Table 3.3.5.3-1 for the channel.

Declare RCIC System inoperable.

Place channel in trip.

Restore channel to OPERABLE status.

3.3-45 COMPLETION TIME Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of RCIC initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours (continued)

Amendment No. 216

ACTIONS (continued)

D.

CONDITION As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

RCIC System Instrumentation 3.3.5.3 D. l AND REQUIRED ACTION

NOTE----------

Only applicable if RCIC pump suction is not aligned to the suppression pool.

Declare RCIC System inoperable.

D.2.1 Place channel in trip.

OR D.2.2 Align RCIC pump suction to the suppression pool.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of RCIC initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours E.

Required Action and E.1 Declare RCIC System inoperable.

Immediately associated Completion Time of Condition B, C, or D not met.

CLINTON 3.3-46 Amendment No. 216

RCIC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

NOTES-------------------------------------

1.

Refer to Table 3.3.5.3-1 to determine which SRs apply for each RCIC Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows:

(a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 2 and 5; and (bl for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 3, and 4 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.3 Calibrate the analog trip module.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.4 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.5 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.6 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program CLINTON 3.3-47 Amendment No. 216

Table 3.3.5.3-1 (page 1 of 1)

RCIC System Instrumentation 3.3.5.3 Reactor Core Isolation Cooling System Instrumentation CONDITIONS REQUIRED REFERENCED FROM CHANNELS PER REQUIRED ACTION SURVEILLANCE ALLOWABLE FUNCTION FUNCTION A.1 REQUIREMENTS VALUE

1. Reactor Vessel Water 4

B SR 3.3.5.3.1

,, -48.1 inches Level-Low Low, Level 2 SR 3.3.5.3.2 SR 3.3.5.3.3 SR 3.3.5.3.5 SR 3.3.5.3.6

2. Reactor Vessel Water 2

C SR 3.3.5.3.1

,; 52.6 inches Level-High, Level 8 SR 3.3.5.3.2 SR 3.3.5.3.3 SR 3.3.5.3.4 SR 3.3.5.3.5

3. RCIC Storage Tank 2

D SR 3.3.5.3.1

,, 3.0 inches Level-Low SR 3.3.5.3.2 SR 3.3.5.3.3 SR 3.3.5.3.4 SR 3.3.5.3.5

4. Suppression Pool Water 2

D SR 3.3.5.3.1

,; -5 inches Level-High SR 3.3.5.3.2 SR 3.3.5.3.3 SR 3.3.5.3.4 SR 3.3.5.3.5

5. Manual Initiation 1

C SR 3.3.5.3.5 NA CLINTON 3.3-48 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment and Drywell Isolation Instrumentation LCO 3.3.6.1 The primary containment and drywell isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE----------

A.1 Place one channel in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Only applicable to Main affected Function in Steam Line (MSL) isolation trip.

Functions.

A.

One or more Functions with one channel inoperable.

NOTE----------

B.1 Place one channel in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Only applicable to MSL affected Function in isolation Functions.

trip.

B.

One or more Functions with two channels inoperable.

NOTE----------

C.1 Restore two channels 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to MSL in affected Function isolation Functions.

to OPERABLE status.

C.

One or more Functions with three or more channels inoperable.

(continued)

CLINTON 3.3-49 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION

NOTE----------

D.1 Not applicable to MSL isolation Functions.

D.

One or more required channels inoperable.

NOTE---------

Not applicable to MSL isolation Functions.

E.

One or more automatic Functions with isolation capability not maintained.

F.

G.

H.

I.

Required Action and associated Completion Time of Condition A, B, C, D, or E not met.

As required by Required Action F.1 and referenced in Table 3.3.6.1-1.

E.1 F.1 G.1 OR G.2.1 AND G.2.2 H.1 I. l REQUIRED ACTION Place channel in trip.

Restore isolation capability.

Enter the Condition referenced in Table 3.3.6.1-1 for the channel.

Isolate associated MSL.

Be in MODE 3.

Be in MODE 4.

Be in MODE 2.

Isolate the affected penetration flow path(s).

CLINTON 3.3-50 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 6 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation

3. 3. 6.1 ACTIONS (continued)

J.

K.

L.

M.

CONDITION As required by Required Action F.1 and referenced in Table 3.3.6.1-1.

As required by Required Action F.1 and referenced in Table 3. 3. 6. 1-1.

OR Required Action and associated Completion Time of Condition I or J not met.

As required by Required Action F.1 and referenced in Table 3.3.6.1-1.

CLINTON J.1 K.1 AND K.2 L.1 OR L.2 M.1 OR M.2 OR REQUIRED ACTION Isolate the affected penetration flow path (s).

Be in MODE 3.

Be in MODE 4.

Declare associated standby liquid control subsystem inoperable.

Isolate the Reactor Water Cleanup System.

Initiate action to restore channel to OPERABLE status.

Initiate action to isolate the Residual Heat Removal (RHR)

Shutdown Cooling System suction from the reactor vessel.

3.3-51 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 1 hour 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Immediately Immediately (continued)

Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME M.

(Continued)

M.3.1 Initiate action to Immediately restore secondary containment to OPERABLE status.

AND M.3.2 Initiate action to Immediately restore one standby gas treatment (SGT) subsystem to OPERABLE status.

AND M. 3. 3 Initiate action to Immediately restore isolation capability in each required secondary containment and secondary containment bypass penetration flow path not isolated.

AND M.3.4

NOTE-------

Entry and exit is permissible under administrative control.

Initiate action to Immediately close one door in the upper containment personnel air lock.

N.

As required by N. l Isolate the affected Immediately Required Action F.l penetration flow and referenced in path(s).

Table 3.3.6.1-1.

OR N.2 Suspend movement of Immediately recently irradiated fuel assemblies in the primary and secondary containment.

CLINTON 3.3-52 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

NOTES------------------------------------

1.

Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment and Drywell Isolation Function.

2.

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , provided the associated Function maintains isolation capability.

SURVEILLANCE SR 3.3.6.1.1 Perform CHANNEL CHECK.

SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST.

SR 3.3.6.1.3 Calibrate the analog trip module.

CLINTON 3.3-53 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.8 CLINTON SURVEILLANCE Perform CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

Perform LOGIC SYSTEM FUNCTIONAL TEST.

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

Channel sensors are excluded.

Verify the ISOLATION SYSTEM RESPONSE TIME for the main steam isolation valves is within limits.

Perform CHANNEL CALIBRATION.

3.3-54 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 2 of 6)

Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION F.l REQUIREMENTS VALUE

2.

Primary Containment and Drywell Isolation

a. Reactor Vessel Water 1, 2, 3 4 lb)

K SR 3.3.6.1.1 2 -48.1 inches Level-Low Low, Level 2 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.8

b. Drywell Pressure-High 1, 2, 3 4 lb)

K SR 3.3.6.1.1

$ 1. 88 psig SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

c. Deleted

d. Drywell Pressure-1, 2, 3 4 (bl I

SR 3.3.6.1.1

$ 1.88 psig High (ECCS Divisions SR 3.3.6.1.2 1 and 2)

SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

e. Reactor Vessel Water 1, 2, 3 4

SR 3.3.6.1.1 2 -48.1 inches Level-Low Low, Level SR 3.3.6.1.2 2 (HPCS NSPS Div 3 SR 3.3.6.1.3 and 4)

SR 3.3.6.1.6 SR 3.3.6.1.8

f. Drywell Pressure-High 1, 2, 3 4

I SR 3.3.6.1.1

$ 1. 88 psig (HPCS NSPS Div 3 and SR 3.3.6.1.2

4)

SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6 (continued)

(b) Also required to initiate the associated drywell isolation function.

CLINTON 3.3-56 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 6)

Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION F.1 REQUIREMENTS VALUE

2. Primary Containment and Drywell Isolation (continued)

g. Containment Building 4

N SR 3.3.6.1.1

'.". 500 mR/hr Fuel Transfer Pool (cl SR 3.3.6.1.2 Ventilation Plenum SR 3.3.6.1.5 Radiation-High SR 3.3.6.1.6

h. Containment Building 1, 2, 3 4 (bl SR 3.3.6.1.1

'.". 400 mR/hr Exhaust SR 3.3.6.1.2 Radiation-High SR 3.3.6.1.5 SR 3.3.6.1.6 (cl 4

N SR 3.3.6.1.1

'.". 400 mR/hr SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6

i. Containment Building 1, 2, 3 4 (bl SR 3.3.6.1.1

'.". 400 mR/hr Continuous SR 3.3.6.1.2 Containment Purge SR 3.3.6.1.5 (CCP) Exhaust SR 3.3.6.1.6 Radiation-High (cl 4

N SR 3.3.6.1.1

400 mR/hr SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6 j. Reactor Vessel Water 1,2,3 4 (bl SR 3.3.6.1.1 2c -148.1 inches Level-Low Low Low, SR 3.3.6.1.2 Level 1 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.8

k. Containment Pressure-(di 2

I SR 3.3.6.1.1

'.". 3.0 psid High SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6

1. Manual Initiation 1, 2, 3 2 (bl J

SR 3.3.6.1.6 NA (cl 2

N SR 3.3.6.1.6 NA (continued)

(b) Also required to initiate the associated drywell isolation function.

(c)

During movement of recently irradiated fuel assemblies in the primary or secondary containment.

(d)

MODES 1, 2, and 3 with the associated PCIVs not closed.

CLINTON 3.3-57 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 5 of 6)

Primary Containment and Drywell Isolation Instrumentation FUNCTION

3.

RCIC System Isolation (continued)

j. Drywell Pressure - High

k. Manual Initiation

4.

Reactor Water Cleanup (RWCU) System Isolation

a. Differential Flow -

High

b. Differential Flow-Timer

c. RWCU Heat Exchanger Equipment Room Temperature-High

d. RWCU Pump Rooms Temperature-High

e. Main Steam Line Tunnel Ambient Temperature-High

f. Reactor Vessel Water Level-Low Low, Level 2

g. Standby Liquid Control System Initiation

h. Manual Initiation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3 1, 2, 3 1, 2, 3 1, 2, 3 1, 2, 3 1, 2, 3 1,2,3 1,2,3 1,2,3 1, 2, 3 lei CONDITIONS REQUIRED REFERENCED CHANNELS FROM PER REQUIRED FUNCTION ACTION F.l 2

1 2

2 2 per room 2 per room 2

4 2

2 2

J L

J N

SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE SR 3.3.6.1.1 s 1.88 psig SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.6 NA SR 3.3.6.1.1 s 66.1 gpm SR 3.3.6.1.2 SR 3.3.6.1.6 SR 3.3.6.1.8 SR 3.3.6.1.2 s 47 seconds SR 3.3.6.1.4 SR 3.3.6.1.6 SR 3.3.6.1.1 s 205oF SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.1 s 202oF SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.1 s 171°F SR 3.3.6.1.2 SR 3.3.6.1.5 SR 3.3.6.1.6 SR 3.3.6.1.1

~ -48.1 inches SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.8 SR 3.3.6.1.6 NA SR 3.3.6.1.6 NA SR 3.3.6.1.6 NA (continued)

(c) During movement of recently irradiated fuel assemblies in the primary or secondary containment.

CLINTON 3.3-59 Amendment No. 216

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 6 of 6)

Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION F.1 REQUIREMENTS VALUE

5. RHR System Isolation

a. RHR Heat Exchanger 1, 2, 3 2 per room SR 3.3.6.1.1

$ 160°F Ambient SR 3.3.6.1.2 Temperature-High SR 3.3.6.1.5 SR 3.3.6.1.6

b. Reactor Vessel Water 1, 2' 3 lei 4

I SR 3.3.6.1.1 2 8.3 inches Level -

Low, Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

c. Reactor Vessel Water 3lfl 4

M SR 3.3.6.1.1 2 8.3 inches Level Low, Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

d. Reactor Vessel Water 1, 2, 3 4

SR 3.3.6.1.1 2 -148.1 Level Low Low Low, SR 3.3.6.1.2 inches Level 1 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.8

e. Reactor Vessel 1, 2, 3 4

SR 3.3.6.1.1

$ 113 psig Pressure-High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

f. Drywell Pressure-High 1, 2, 3 8

SR 3.3.6.1.1

$ 1. 88 psig SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

g. Manual Initiation 1,2,3 2

J SR 3.3.6.1.6 NA (e)

With reactor steam dome pressure greater than or equal to the RHR cut in permissive pressure.

(f)

With reactor steam dome pressure less than the RHR cut in permissive pressure.

CLINTON 3.3-60 Amendment No. 216

1.

2.

3.

4.

5.

6.

7.

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MODES OR REQUIRED OTHER CHANNELS SPECIFIED PER TRIP SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM REQUIREMENTS VALUE Reactor Vessel Water 1,2,3 2

SR 3.3.6.2.1

<'. -48.1 inches Level-Low Low, Level 2 SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.5 SR 3.3.6.2.6 Drywell Pressure-High 1,2,3 2

SR 3.3.6.2.1

,:; 1. 88 psig SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5 Containment Building Fuel la) 2 SR 3.3.6.2.1

,:; 500 mR/hr Transfer Pool Ventilation SR 3.3.6.2.2 Plenum Exhaust SR 3.3.6.2.4 Radiation-High SR 3.3.6.2.5 Containment Building 1, 2, 3, (al 2

SR 3.3.6.2.1

,:; 400 mR/hr Exhaust Radiation-High SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.5 Containment Building 1, 2, 3, (al 2

SR 3.3.6.2.1

,:; 400 mR/hr Continuous Containment SR 3.3.6.2.2 Purge (CCP) Exhaust SR 3.3.6.2.4 Radiation-High SR 3.3.6.2.5 Fuel Building Exhaust 1,2,3, (bl 2

SR 3.3.6.2.1

,:; 17 mR/hr Radiation-High SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.5 Manual Initiation 1,2,3, (al 1

SR 3.3.6.2.5 NA (a)

During movement of recently irradiated fuel assemblies in the primary or secondary containment.

(b)

During movement of recently irradiated fuel assemblies in the fuel building.

CLINTON 3.3-64 Amendment No. 216

FUNCTION

1.

control Room Air Intake Radiation Monitors Control Room Ventilation System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of 1)

Control Room Ventilation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1, 2, 3, (a}

REQUIRED CHANNELS PER TRIP SYSTEM 1/Intake SURVEILLANCE REQUIRE ME NT S SR 3.3.7.1.1 SR 3.3.7.1.2 SR 3.3.7.1.3 ALLOWABLE VALUE cs; 26 mR/hr (a)

During CORE ALTERATIONS and during movement of irradiated fuel assemblies in the primary or secondary containment.

CLINTON 3.3-77 Amendment No. 216

RPV Water Inventory Control

3. 5. 2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.2 RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One ECCS injection/spray subsystem shall be OPERABLE.

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

One low pressure coolant injection (LPCI) subsystem may be inoperable during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure.

APPLICABILITY:

MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Required ECCS A. l Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray injection/spray subsystem inoperable.

subsystem to OPERABLE status.

B.

Required Action and B.1 Initiate action to Immediately associated Completion establish a method of Time of Condition A water injection not met.

capable of operating without offsite electrical power.

(continued)

CLINTON 3.5-6 Amendment No. 216

ACTIONS (continued)

CONDITION C.

DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

CLINTON C.1 AND RPV Water Inventory Control 3.5.2 REQUIRED ACTION COMPLETION TIME Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment boundary is capable of being established in less than the DRAIN TIME.

C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

(continued) 3.5-7 Amendment No. 216

ACTIONS (continued)

CONDITION D.

DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

CLINTON D.1 AND D.2 AND D.3 AND 0.4 RPV Water Inventory Control 3.5.2 REQUIRED ACTION

NOTE--------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level> TAF for 2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Initiate action to establish secondary containment boundary.

Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

3.5-8 COMPLETION TIME Immediately Immediately Immediately Immediately (continued)

Amendment No. 216

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

E.

CONDITION Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

E.1 REQUIRED ACTION Initiate action to restore DRAIN TIME to z 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

SURVEILLANCE REQUIREMENTS SR 3.5.2.1 SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 CLINTON SURVEILLANCE Verify DRAIN TIME 2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Verify, for a required low pressure ECCS injection/spray subsystem, the suppression pool water level is z 12 ft 8 inches.

Verify, for a required High Pressure Core Spray (HPCS) System, the:

a.

Suppression pool water level is

~ 12 ft 8 inches; or

b.

RCIC storage tank available water volume is z 125,000 gal.

Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

3.5-9 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 216

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 SR 3.5.2.8 CLINTON SURVEILLANCE

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

Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Operate the required ECCS injection/spray subsystem through the recirculation line for~ 10 minutes.

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

3.5-10 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In Accordance with the Surveillance Frequency Control Program Amendment No. 216

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION A.

RCIC System A. l Verify by inoperable.

administrative means High Pressure Core Spray System is OPERABLE.

AND A.2 Restore RCIC System to OPERABLE status.

B.

Required Action and B.l Be in MODE 3.

associated Completion Time not met.

AND B.2 Reduce reactor steam dome pressure to

~ 150 psig.

SURVEILLANCE REQUIREMENTS SR 3.5.3.1 CLINTON SURVEILLANCE Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water.

3.5-11 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 14 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 216

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 SR 3.5.3.5 CLINTON SURVEILLANCE

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

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure

~ 1045 psig and~ 920 psig, the RCIC pump can develop a flow rate~ 600 gpm against a system head corresponding to reactor pressure.

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure

~ 150 psig and~ 135 psig, the RCIC pump can develop a flow rate~ 600 gpm against a system head corresponding to reactor pressure.

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal.

3.5-12 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 216

Primary Containment Air Locks 3.6.1.2 3.6 CONTAINMENT SYSTEMS 3.6.1.2 Primary Containment Air Locks LCO 3.6.1.2 APPLICABILITY:

ACTIONS Each primary containment air lock shall be OPERABLE.

MODES 1, 2, and 3,

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

The following Applicability applies only to the upper containment personnel air lock.

During movement of recently irradiated fuel assemblies in the primary or secondary containment.

NOTES------------------------------------

1.

Entry and exit is permissible to perform repairs of the affected air lock components.

2.

Separate Condition entry is allowed for each air lock.

3.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when air lock leakage results in exceeding overall containment leakage rate acceptance criteria in MODES 1, 2, and 3.

(continued)

CLINTON 3.6-3 Amendment No. 216

ACTIONS (continued)

CONDITION E. Required Action and associated Completion Time of Condition A, B, or C not met during movement of recently irradiated fuel assemblies in the primary or secondary containment.

CLINTON Primary Containment Air Locks 3.6.1.2 REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

E.1 Suspend movement of recently irradiated fuel assemblies in the primary and secondary containment.

3.6-7 COMPLETION TIME Immediately Amendment No. 216

3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, PCIVs 3.6.1.3

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

ACTIONS The following Applicability applies only to secondary containment bypass leakage isolation valves.

During CORE ALTERATIONS, During movement of irradiated fuel assemblies in the primary or secondary containment.

NOTES------------------------------------

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria in MODES 1, 2, and 3.

5. Not applicable for the Inclined Fuel Transfer System (IFTS) penetration when the associated primary containment blind flange is removed, provided that the fuel building fuel transfer pool water is maintained 2 el. 753 ft., the steam dryer pool to reactor cavity pool gate is installed with the seal inflated and a backup air supply provided, the total time the flange is open does not exceed 40 days per operating cycle, and the IFTS transfer tube drain valve(s) remain(s) closed, except that the IFTS tube drain valve(s) may be opened under administrative controls.

(continued)

CLINTON 3.6-9 Amendment No. 216

ACTIONS D.

E.

F.

CONDITION (continued)

Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2' or 3.

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during movement of recently irradiated fuel assemblies in the primary or secondary containment.

CLINTON D. 3 E.1 AND E.2 F.1 REQUIRED ACTION Perform SR 3.6.1.3.5 for the resilient seal purge valves closed to comply with Required Action D.l.

Be in MODE 3.

Be in MODE 4.

NOTE---------

LCO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in primary and secondary containment.

3.6-14 PCIVs 3.6.1.3 COMPLETION TIME Once per 92 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Immediately Amendment No. 216

3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment Secondary Containment 3.6.4.1 LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the primary or secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, containment to 2' or 3.

OPERABLE status.

B.

Required Action and

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

associated Completion LCO 3.0.4.a is not Time of Condition A applicable when entering not met.

MODE 3.

B. l Be in MODE 3.

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

CLINTON 3.6-43 Amendment No. 216

Secondary Containment 3.6.4.1 ACTIONS (continued)

CONDITION C.

Secondary containment inoperable during movement of recently irradiated fuel assemblies in the primary or secondary containment.

SURVEILLANCE REQUtREMENTS C.1 REQUIRED ACTION

NOTE---------

LCO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in the primary and secondary containment.

SURVEILLANCE SR 3.6.4.1.1 SR 3.6.4.1.2 CLINTON Verify secondary containment vacuum is

~ 0.25 inch of vacuum water gauge.

Verify all secondary containment equipment hatches are closed and sealed.

3.6-44 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 216

3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)

LCO 3.6.4.2 Each SCID shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, SCIDs 3.6.4.2 During movement of recently irradiated fuel assemblies in the primary or secondary containment.

ACTIONS

NOTES------------------------------------

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by SCIDs.

(continued)

CLINTON 3.6-47 Amendment No. 216

ACTIONS (continued)

CONDITION D.

Required Action and associated Completion Time of Condition A or B not met during movement of recently irradiated fuel assemblies in the primary or secondary containment.

CLINTON D.l REQUIRED ACTION

NOTE---------

LCO 3.0.3 is not applicable.

SCIDs 3.6.4.2 COMPLETION TIME Suspend movement of Immediately recently irradiated fuel assemblies in the primary and secondary containment.

3. 6-49 Amendment No. 216

3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE..

APPLICABILITY:

MODES 1, 2, and 3, SGT System 3.6.4.3 During movement of recently irradiated fuel assemblies in the primary or secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable.

to OPERABLE status.

B. Required Action and

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

associated Completion LCO 3.0.4.a is not Time of Condition A applicable when entering not met in MODE 1, 2' MODE 3.

or 3.

B.1 Be in MODE 3.

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

CLINTON 3.6-51 Amendment No. 216

ACTIONS (continued)

CONDITION C.

Required Action and associated Completion Time of Condition A not met during movement of recently irradiated fuel assemblies in the primary or secondary containment.

D.

Two SGT subsystems inoperable in MODE 1, 2, or 3.

CLINTON REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

C.1 OR C.2 Place OPERABLE SGT subsystem in operation.

Suspend movement of recently irradiated fuel assemblies in the primary and secondary containment.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

D.1 Be in MODE 3.

3.6-52 SGT System 3.6.4.3 COMPLETION TIME Immediately Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Amendment No. 216

ACTIONS (continued)

CONDITION REQUIRED ACTION E.

Two SGT subsystems inoperable during movement of recently irradiated fuel assemblies in the primary or secondary containment.

E.l Suspend movement of recently irradiated fuel assemblies in the primary and secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SR 3.6.4.3.4 CLINTON SURVEILLANCE Operate each SGT subsystem for

~ 15 continuous minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each SGT subsystem actuates on an actual or simulated initiation signal.

Verify each SGT filter cooling bypass damper can be opened and the fan started.

3.6-53 SGT System 3.6.4.3 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 216

Control Room Ventilation System 3.7.3 3.7 PLANT SYSTEM 3.7.3 Control Room Ventilation System LCO 3.7.3 Two Control Room Ventilation subsystems shall be OPERABLE.

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the primary or secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION A.

One Control Room Ventilat_ion subsystem inoperable for reasons other than Condition C.

B.

Required Action and associated Completion Time of Condition A not met in MODE 1, 2, or 3.

C.

One or more Control Room Ventilation subsystems inoperable due to inoperable CRE boundary in MODE 1, 2, or 3.

CLINTON A.1 REQUIRED ACTION Restore Control Room Ventilation subsystem to OPERABLE status.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

B.1 C.1 AND C.2 AND C. 3 Be in MODE 3.

Initiate action to implement mitigating actions.

Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

Restore CRE boundary to OPERABLE status.

3.7-4 COMPLETION TIME 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 90 days (continued)

Amendment No. 216

Control Room Ventilation System 3.7.3 ACTIONS (continued)

CONDITION D.

Required Action and Associated Completion Time of Condition C not met in MODE l, 2, or 3.

E.

Required Action and associated Completion Time of Condition A not met during REQUIRED ACTION D. l Be in MODE 3.

AND D. 2 Be in MODE 4.

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

LCO 3.0.3 is not applicable.

movement of irradiated E.l fuel assemblies in the primary or secondary containment, or during Place OPERABLE Control Room Ventilation subsystem in high radiation mode.

CORE ALTERATIONS.

F.

Two Control Room Ventilation subsystems inoperable in MODE l, 2, or 3 for reasons other than Condition C.

CLINTON OR E.2.1 AND E.2.2 Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Suspend CORE ALTERATIONS.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

F.l Be in MODE 3.

3.7-5 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Immediately Immediately Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Amendment No. 216

Control Room Ventilation System 3.7.3 ACTIONS (continued)

CONDITION G.

Two Control Room G.l Ventilation subsystems inoperable during movement of irradiated fuel assemblies in the primary or secondary containment, or during AND CORE ALTERATIONS.

OR One or more Control Room Ventilation subsystems inoperable due to inoperable CRE boundary during movement of irradiated fuel assemblies in the primary or secondary containment, or during CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS G.2 SURVEILLANCE REQUIRED ACTION Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Suspend CORE ALTERATIONS.

SR 3.7.3.1 Operate each Control Room Ventilation subsystem with flow through the makeup filter for 2 15 continuous minutes with the heaters operating.

SR 3.7.3.2 CLINTON Operate each Control Room Ventilation subsystem with flow through the recirculation filter for 2 15 minutes.

3.7-6 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 216

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the primary or secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION A.

One control room AC subsystem inoperable.

B.

Two control room AC subsystems inoperable.

C.

Required Action and Associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.

CLINTON A.1 B.1 AND B.2 REQUIRED ACTION Restore control room AC subsystem to OPERABLE status.

Verify control room area temperature

<::: 86 °F.

Restore one control room AC subsystem to OPERABLE status.

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

LCO 3.0.4.a is not applicable when entering MODE 3.

C.l Be in MODE 3.

3.7-8 COMPLETION TIME 30 days Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Amendment No. 216

ACTIONS (continued)

CONDITION D.

Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the primary or secondary containment, or during CORE ALTERATIONS.

CLINTON Control Room AC System 3.7.4 REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

D.l OR D.2.1 AND D.2.2 Place OPERABLE control room AC subsystem in operation.

Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Suspend CORE ALTERATIONS.

3.7-9 COMPLETION TIME Immediately Immediately Immediately (continued)

Amendment No. 216

Control Room AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION E.

Required Action and associated Completion Time of Condition B

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

LCO 3.0.3 is not applicable.

not met during movement of irradiated E.1 fuel assemblies in the primary or secondary containment, or during CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS AND E.2 Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Suspend CORE ALTERATIONS.

SURVEILLANCE SR 3.7.4.1 CLINTON Verify each control room AC subsystem has the capability to remove the assumed heat load.

3.7-10 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 216

AC Sources-Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO

3.8.2 APPLICABILITY

ACTIONS The following AC electrical power sources shall be OPERABLE:

a.

One qualified circuit between the offsite transmission network and the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems-Shutdown";

b.

One diesel generator (DG) capable of supplying one division of the Division 1 or 2 onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3.8.10; and

c.

One qualified circuit, other than the circuit in LCO 3.8.2.a, between the offsite transmission network and the Division 3 onsite Class lE AC electrical power distribution subsystem, or the Division 3 DG capable of supplying the Division 3 onsite Class lE AC electrical power distribution subsystem, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

MODES 4 and 5, During movement of irradiated fuel assemblies in the primary or secondary containment.

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

LCO 3.0.3 is not applicable.

(continued)

CLINTON 3.8-16 Amendment No. 216

ACTIONS (continued)

CONDITION A.

LCO Item a not met.

CLINTON AC Sources~Shutdown 3.8.2 REQUIRED ACTION

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

Enter applicable Condition and Required Actions of LCO 3.8.10, when any required division is de-energized as a result of Condition A.

A.1 OR A.2.1 AND A.2.2 AND A.2.3 Declare affected required feature(s) with no offsite power available from a required circuit inoperable.

Suspend CORE ALTERATIONS.

Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

Initiate action to restore required offsite power circuit to OPERABLE status.

3.8-17 COMPLETION TIME Immediately Immediately Immediately Immediately (continued)

Amendment No. 216

ACTIONS (continued)

CONDITION B.

LCO Item b not met.

B.1 AND B.2 AND B. 3 C.

LCO Item C not met.

C.1 CLINTON REQUIRED ACTION Suspend CORE ALTERATIONS.

Suspend movement irradiated fuel of AC Sources-Shutdown

3. 8. 2 COMPLETION TIME Immediately Immediately assemblies in primary and secondary containment.

Initiate action to Immediately restore required DG to OPERABLE status.

Declare High Pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Core Spray System inoperable.

3.8-18 Amendment No. 216

DC Sources~Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources~Shutdown LCO

3.8.5 APPLICABILITY

ACTIONS The following shall be OPERABLE:

a.

One Class lE DC electrical power subsystem capable of supplying one division of the Division 1 or 2 onsite Class lE DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems -

Shutdown";

b.

One Class lE battery or battery charger, other than the DC electrical power subsystem in LCO 3.8.5.a, capable of supplying the remaining Division 1 or Division 2 onsite Class lE DC electrical power distribution subsystem(s) when required by LCO 3.8.10; and

c.

The Division 3 and 4 DC electrical power subsystems capable of supplying the Division 3 and 4 onsite Class lE DC electrical power distribution subsystems, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

MODES 4 and 5, During movement of irradiated fuel assemblies in the primary or secondary containment.

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

LCO 3.0.3 is not applicable.

A.

CONDITION One battery charger on one division inoperable.

CLINTON A.1 AND A.2 AND A.3 REQUIRED ACTION Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

Verify battery float current~ 2 amps.

Restore battery charger to OPERABLE status.

3.8-27 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days (continued)

Amendment No. 216

DC Sources~Shutdown 3.8.5 ACTIONS (continued)

B.

CONDITION REQUIRED ACTION One or more required B.l Declare affected required feature(s) inoperable.

DC electrical power subsystems inoperable for reasons other than Condition A.

OR OR Required Action and associated Completion Time of Condition A not met.

B.2.1 Suspend CORE ALTERATIONS.

AND B.2.2 AND Suspend movement of irradiated fuel assemblies in the primary and secondary containment.

B.2.3 Initiate action to restore required DC electrical power subsystems to OPERABLE status.

CLINTON 3.8-28 COMPLETION TIME Immediately Immediately Immediately Immediately Amendment No. 216

Inverters-Shutdown

3. 8. 8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters~Shutdown LCO

3.8.8 APPLICABILITY

CLINTON The following Divisional inverters shall be OPERABLE:

a.

One Divisional inverter capable of supplying one division of the Division 1 or 2 onsite Class lE uninterruptible AC bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown"; and

b.

The Division 3 and 4 Divisional inverters capable of supplying the Division 3 and 4 onsite Class lE uninterruptible AC bus electrical power distribution subsystems, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

MODES 4 and 5, During movement of irradiated fuel assemblies in the primary or secondary containment.

3.8-36 Amendment No. 216

ACTIONS Inverters~Shutdown

3. 8. 8

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

LCO 3.0.3 is not applicable.

CONDITION A.

One or more required divisional inverters inoperable.

CLINTON A.1 OR A.2.1 AND A.2.2 AND A.2.3 REQUIRED ACTION Declare affected required feature(s) inoperable.

Suspend CORE ALTERATIONS.

Suspend handling of irradiated fuel assemblies in the primary and secondary containment.

Initiate action to restore required divisional inverters to OPERABLE status.

3.8-37 COMPLETION TIME Immediately Immediately Immediately Immediately Amendment No. 216

Distribution Systems~Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION A.

(continued)

A.2.3 AND A.2.4 Initiate actions to restore required AC, DC, and uninterruptible AC bus electrical power distribution subsystems to OPERABLE status.

Declare associated required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SR 3.8.10.1 CLINTON SURVEILLANCE Verify correct breaker alignments and voltage to required AC, DC, and uninterruptible AC bus electrical power distribution subsystems.

3.8-43 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 216

1.0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 216 TO FACILITY OPERATING LICENSE NO. NPF-62 EXELON GENERATION COMPANY. LLC CLINTON POWER STATION. UNIT NO. 1 DOCKET NO. 50-461 INTRODUCTION By application dated May 1, 2017 (Reference 1 ), as supplemented by letter dated November 15, 2017 (Reference 2), and letter dated December 20, 2017 (Reference 3), Exelon Generation Company, LLC (EGC, the licensee) requested to adopt Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 4), for Clinton Power Station, Unit No. 1 (CPS). The final safety evaluation (SE) for TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (Reference 5).

The proposed changes would replace existing technical specifications (TSs) requirements associated with "operations with a potential for draining the reactor vessel" (OPDRVs), with revised TSs providing an alternative requirement for reactor pressure vessel (RPV) water inventory control (WIC). These alternative requirements would protect Safety Limit 2.1.1.3, which states "Reactor vessel water level shall be greater than the top of active irradiated fuel."

Additionally, a new definition, "DRAIN TIME," would be added to the CPS TSs, Section 1.1, "Definitions." DRAIN TIME would establish requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for MODES 4 and 5 outage related activities. Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system (ECCS) safety injection/spray systems during MODES 4 and 5 would require a properly calculated DRAIN TIME.

The licensee has proposed several variations from the TS changes described in the applicable parts of TSTF-542, Revision 2, or the NRG-approved TSTF SE. These are explained below in Section 2.2.5 and evaluated in Section 3.5 of this SE.

The supplements dated November 15, 2017, and December 20, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register (FR) on July 5, 2017 (82 FR 31096).

2.0

2.1 REGULATORY EVALUATION

System Description The boiling-water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup (RWCU), and shutdown cooling (SOC). Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During operation in MODES 1 (Power Operation - Reactor Mode Switch in Run), 2 (Startup - Reactor Mode Switch in Refuel 1 or Startup/Hot Standby), and 3 (Hot Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature > 200 degrees Fahrenheit (° F)), the TS for instrumentation and ECCS require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should level decrease below the preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss.

During BWR operation in MODE 4 (Cold Shutdown1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature::;; 200° F), and MODE 5 (Refueling2 and Reactor Mode Switch in Shutdown or Refuel), the pressures and temperatures that could cause a LOCA are not present. During certain phases of refueling (MODE 5) a large volume of water is available above the RPV (i.e., the RPV head is removed, the water level is~ 22 feet 8 inches over the top of the RPV flange, with the reactor cavity to steam dryer gate removed).

The large volume of water available in and above the RPV (during much of the time when in MODE 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, typically at other times during a refueling outage, during Cold Shutdown (MODE 4) or Refueling (MODE 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities. There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV.

In comparison to MODES 1, 2, and 3, with typical high temperatures and pressures (especially in MODES 1 and 2), MODES 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the potential sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decrease from potential significant or even unexpected drainage paths. These potential drainage paths in MODES 4 and 5 generally would require less water replacement capability to maintain water above TAF.

To address the drain down potential during MODES 4 and 5, the existing CPS TSs contain specifications that are applicable during OPDRVs, or require suspension of OPDRVs if certain equipment is inoperable. The term OPDRVs is not specifically defined in the TS and historically 1 All reactor vessel head closure bolts fully tensioned.

2 One of more reactor vessel head closure bolts less than fully tensioned.

has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIG TS with attendant equipment operability requirements, required actions and surveillance requirements (SRs), and deleting references to OPDRVs throughout the TSs.

2.2 Proposed TS Changes

Section 2.2.1 discusses the proposed addition of a new definition, "DRAIN TIME" (evaluated below in Section 3.1 ). Section 2.2.2 discusses the proposed revisions to TS 3.3, "Instrumentation," including the proposed revisions to TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," the proposed addition of new TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including Table 3.3.5.2), the proposed renumbering of existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation" to 3.3.5.3, and the proposed revisions to TS pages for TS 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" (including Table 3.3.6.1) (evaluated below in Section 3.2). Section 2.2.3 discusses the proposed revisions to TS 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System," including the proposed revisions to TS 3.5.2 "ECCS-Shutdown" (evaluated below in Section 3.3.1 ). Section 2.2.4 discusses the proposed deletion of existing TS references to OPDRVs (evaluated below in Section 3.6). Section 2.2.5 discusses the CPS plant-specific variations to TSTF-542, Revision 2 (evaluated below in Section 3.5).

2.2.1 Addition of DRAIN TIME Definition Reference 1 includes the following definition of "DRAIN TIME" that would be added to CPS TS Section 1.1, "Definitions."

The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a.

The water inventory above the TAF is divided by the limiting drain rate;

b.

The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the T AF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c.

The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d.

No additional draining events occur; and

e.

Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

2.2.2 TS 3.3, "Instrumentation" The following subsections describe the existing and proposed changes to the CPS TS, Section 3.3, "Instrumentation."

2.2.2.1 TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation" Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1, B.2, C.1, and E.1 which states:

"Only applicable in Modes 1, 2, and 3."

For TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," the applicability in MODES 4 and 5 was proposed for deletion because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.2. MODES 4 and 5 applicability and associated requirements would be deleted for the following functions:

a. Low Pressure Coolant Injection - A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems:

a.

Reactor Vessel Water Level - Low Low Low, Level 1

c.

LPCI Pump A Start - Time Delay Logic Card

d.

Reactor Vessel Pressure - Low (Injection Permissive)

e.

LPCS Pump Discharge Flow-Low (Bypass)

f.

LPCI Pump A Discharge Flow-Low (Bypass)

g.

Manual Initiation

b. LPCI B and LPCI C Subsystems:

a.

Reactor Vessel Water Level - Low Low Low, Level 1

c.

LPCI Pump B Start - Time Delay Logic Card

d.

Reactor Vessel Pressure - Low (Injection Permissive)

e.

LPCI Pump B and LPCI Pump C Discharge Flow-Low (Bypass)

f.

Manual Initiation

c. High Pressure Core Spray (HPCS) System;

a.

Reactor Vessel Water Level - Low Low, Level 2

c.

Reactor Vessel Water Level - High, Level 8

d.

RCIC [Reactor Core Isolation Cooling] Storage Tank Level - Low

f.

HPCS Pump Discharge Pressure - High (Bypass)

g.

HPCS System Flow Rate - Low (Bypass)

h.

Manual Initiation TS Table 3.3.5.1-1 Footnote (a), which states, "[w]hen associated subsystem(s) are required to be OPERABLE," would be deleted. Also, Footnote (c), which states, "[w]hen HPCS is OPERABLE for compliance with LCO [limiting condition for operation] 3.5.2,

'ECCS - Shutdown,' and aligned to the RCIC storage tank while tank water level is not within the limits of SR 3.5.2.2," would be deleted. As a result, existing Footnote (b) would be renumbered as (a), Footnote (d) would be renumbered as (b), and Footnote (e) would be renumbered as (c).

2.2.2.2 New TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed new TS 3.3.5.2 would contain functions that are comprised of requirements moved from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements. The proposed new TS 3.3.5.2 is described below:

3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 APPLICABILITY:

ACTIONS The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

According to Table 3.3.5.2-1.

1\\J()l"~----------------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Enter the Condition Immediately channels referenced in Table 3.3.5.2-inoperable.

1 for the channel.

B. As required by 8.1 Declare associated Immediately Required Action A.1 penetration flow path(s) and referenced in incapable of automatic Table 3.3.5.2-1.

isolation.

AND 8.2 Calculate DRAIN TIME.

Immediately C. As required by C.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 and referenced in Table 3.3.5.2-1.

D. As required by D.1 Declare HPCS system 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 inoperable.

and referenced in Table 3.3.5.2-1.

OR D.2 Align the HPCS pump 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months suction to the suppression pool.

E. As required by E.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.2-1.

F. Required Action and F.1 Declare associated ECCS Immediately associated injection/spray subsystem Completion Time of inoperable.

Condition C, D, or E not met.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Proaram.

SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program.

1.

2.

3.

4. The proposed TS Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation," is shown below and would include 3 footnotes.

APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS PER FROM SPECIFIED FUNCTION REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION A.1 REQUIREMENTS VALUE Low Pressure Coolant Injection - A (LPCI}

and Low Pressure Core Spray (LPCS)

Subsystems

a.

Reactor Vessel Pressure - Low 4,5 4 (a)

C SR 3.3.5.2.1

!5 494 psig (Injection SR 3.3.5.2.2 Permissive)

b.

LPCS Pump 4,5 1 per pump (a)

E SR 3.3.5.2.1

750 gpm Discharge Flow SR 3.3.5.2.2

- Low (Bypass)

C.

LPCI Pump A 4,5 1 per pump (a)

E SR 3.3.5.2.1

.:: 900 gpm Discharge Flow SR 3.3.5.2.2

- Low (Bypass)

LPCI B and LPCI C Subsystems

a.

Reactor Vessel Pressure - Low 4,5 4 (a)

C SR 3.3.5.2.1

!5 494 psig (Injection SR 3.3.5.2.2 Permissive)

b.

LPCI Pump B 4,5 1 per pump (a)

E SR 3.3.5.2.1

.:: 900 gpm and LPCI Pump SR 3.3.5.2.2 C Discharge Flow-Low (Bypass)

High Pressure Core Spray (HPCS)

System 4(b),5(b) 2 (a)

D SR 3.3.5.2.1

3.0 inches

a.

RCIC Storage SR 3.3.5.2.2 Tank Level -

Low 4,5 1 (a)

E SR 3.3.5.2.1

120 psig SR 3.3.5.2.2

b.

HPCS Pump Discharge Pressure - High SR 3.3.5.2.1

500 gpm (Bypass) 4,5 1 (a)

E SR 3.3.5.2.2 C.

HPCS System Flow Rate-Low (Bypass)

AHR System Isolation (c) 2 in one trip B

SR 3.3.5.2.1

.:: 8.3

a.

Reactor Vessel system SR 3.3.5.2.2 inches Water Level -

Low, Level 3

5. Reactor Water Cleanup (RWCU)

System Isolation

a.

Reactor Vessel (c) 2 in one trip B

SR 3.3.5.2.1

~ - 48.1 Water Level -

system SR 3.3.5.2.2 inches Low Low, Level 2

(a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."

(b) When HPCS is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control," and aligned to the RCIC storage tank while tank water level is not within the limits of SR 3.5.2.3.

(c) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

2.2.2.3 Existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation" The existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," and its subsection would be renumbered to 3.3.5.3 in order to maintain the TS numbering conventions.

2.2.2.4 TS 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" In LCO 3.3.6.1-1, Condition O and Required Actions 0.1 and 0.2 were proposed to be deleted.

This is further addressed below in Section 2.2.5.4 (Variation 4). In addition, Required Action N.2.2 was proposed to be deleted. Since Required Action N.2.2 is to be deleted, existing Required Action N.2.1 is renumbered as N.2. This Condition and these three Required Actions are related to OPDRV.

In Table 3.3.6.1-1, "Primary Containment and Drywell Isolation Instrumentation," the following instrumentation functions were proposed to be deleted for MODES 4 and 5 since they are associated to OPDRVs:

FUNCTION

2. Primary Containment and Drywell Isolation

a. Reactor Vessel Water Level - Low Low, Level 2

g. Containment Building Fuel Transfer Pool Ventilation Plenum Radiation - High

h. Containment Building Exhaust Radiation - High

i.

Containment Building Continuous Containment Purge (CCP) Exhaust Radiation - High

j.

Reactor Vessel Water Level - Low Low Low, Level 1 I.

Manual Initiation

4. RWCU System Isolation

f.

Reactor Vessel Water Level - Low Low, Level 2

h. Manual Initiation

5. RHR System Isolation C.

Reactor Vessel Water Level - Low, Level 3 (Applicable MODE 3 is maintained in this Table)

Footnote (c) for Table 3.3.6.1-1, "During operations with a potential for draining the reactor vessel," and Footnote (h), "Only one trip system required in MODES 4 and 5 with RHR Shutdown Cooling System integrity maintained," are proposed to be deleted due to the reference to OPDRV. Since both Footnotes (c) and (h) are to be deleted, existing Footnote (d) is renumbered as (c), Footnote (e) is renumbered as (d), Footnote (f) is renumbered as (e), and Footnote (g) is renumbered as (f).

2.2.3 TS Section 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System" The title of TS Section 3.5 would be revised from "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System" to "Emergency Core Cooling Systems (ECCS), Reactor Pressure Vessel (RPV) Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System."

The title of TS Section 3.5.2 would be revised from "ECCS - Shutdown" to "RPV Water Inventory Control," and TS 3.5.2 would be revised as follows:

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One ECCS injection/spray subsystem shall be OPERABLE.

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

One low pressure coolant injection (LPCI) subsystem may be inoperable during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A. 1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray injection/spray subsystem to subsystem OPERABLE status.

inoperable.

B. Required Action and B.1 Initiate action to establish a Immediately associated method of water injection Completion Time of capable of operating without Condition A not met.

offsite electrical power.

C. DRAIN TIME< 36 C.1 Verify secondary containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months hours and~ 8 boundary is capable of being hours.

established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months C.3 Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 D.1

NC>TE------------

hours.

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > T AF for ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one Immediately standby gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore Immediately associated DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The proposed SR 3.5.2 are shown below:

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure ECCS In accordance with the injection/spray subsystem, the suppression Surveillance Frequency pool is?. 12 ft 8 inches.

Control Program SR 3.5.2.3 Verify, for a required High Pressure Core Spray In accordance with the (HPCS) System, the:

Surveillance Frequency Control Program

a.

Suppression pool water level is ~ 12 ft 8 inches; or

b.

RCIC storage tank available water volume is ~ 125,000 gal.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with the subsystem, locations susceptible to gas Surveillance accumulation are sufficiently filled with water.

Frequency Control Program SR 3.5.2.5

N()TE-----------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required ECCS injection/spray In accordance with the subsystem, each manual, power operated, and Surveillance Frequency automatic valve in the flow path, that is not Control Program locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.6

()perate the required ECCS injection/spray In accordance with the subsystem through the recirculation line for Surveillance Frequency

~ 10 minutes.

Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with the isolating a penetration flow path actuates to the Surveillance isolation position on an actual or simulated Frequency isolation sianal.

Control Proaram SR 3.5.2.8

N()TE--------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance with the subsystem can be manually operated.

Surveillance Frequency 2.2.4 2.2.4.1 Deletion of References to OPDRVs and Other Miscellaneous Changes Deletion of References to OPDRVs In Reference 1, the licensee proposed to delete references to OPDRVs throughout the CPS TSs. These TSs contain references to OPDRVs such as the conditional Applicability "during operations with a potential for draining the reactor vessel," and, if certain conditions are not met, the required actions direct the licensee to "initiate action to suspend OPDRVs," or "initiate action to suspend operations with a potential for draining the reactor," or "initiate action to suspend operations with a potential for draining the reactor vessel (OPDRVs)." The following table is a list of these TSs and their affected sections.

CPS LCO Location of OPDRVs References 3.3.6.2, "Secondary Containment Isolation Table 3.3.6.2-1, "Secondary Containment Instrumentation" Isolation Instrumentation" Footnote (a) 3.3.7.1, "Control Room Ventilation System Table 3.3.7.1-1, "Control Room Ventilation Instrumentation" System Instrumentation" Footnote (a) 3.6.1.2, "Primary Containment Air Locks" Applicability, Condition E Applicability Note was revised to: The following Applicability applies only to the upper containment personnel air lock.

3.6.1.3, "Primary Containment Isolation Applicability (deletion of, "MODES 4 and 5 for Valves (PCIVs)"

RHR Shutdown Cooling System suction from the reactor vessel isolation valves when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1,

'Primary Containment and Drywell Isolation Instrumentation,' Function 5.c"), Condition G Applicability Note was revised to: The following Applicability applies only to secondary containment bypass leakage isolation valve.

3.6.4.1, "Secondary Containment" Applicability, Condition C 3.6.4.2, "Secondary Containment Isolation Applicability, Condition D Dampers (SCIDs)"

3.6.4.3, "Standby Gas Treatment (SGT}

Applicability, Condition C, Condition E System" 3.7.3, "Control Room Ventilation System" Applicability, Condition E, Condition G 3.7.4, "Control Room Air Conditioning (AC)

Applicability, Condition D, Condition E System" 3.8.2, "AC Sources - Shutdown" Condition A, Condition 8 3.8.5, "DC Sources - Shutdown" Condition 8 3.8.8, "Inverters - Shutdown" Condition A 3.8.10, "Distribution Systems - Shutdown" Condition A 2.2.4.2 Other Miscellaneous Changes In a letter dated November 15, 2017 (Reference 2), the licensee corrected titles for TS LCO 3.5.2 for the following electrical power systems LCOs. The proposed changes are shown below.

LCO 3.8.2 c proposed change:

One qualified circuit, other than the circuit in LCO 3.8.2.a, between the offsite transmission network and the Division 3 onsite Class 1 E AC electrical power distribution subsystem, or the Division 3 DG capable of supplying the Division 3 onsite Class IE AC electrical power distribution subsystem, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

LCO 3.8.5 c proposed change:

The Division 3 and 4 DC electrical power subsystems capable of supplying the Division 3 and 4 onsite Class IE DC electrical power distribution subsystems, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

LCO 3.8.8 b proposed change:

The Division 3 and 4 Divisional inverters capable of supplying the Division 3 and 4 onsite Class IE uninterruptible AC bus electrical power distribution subsystems, when the High Pressure Core Spray System is OPERABLE for compliance with LCO 3.5.2, "RPV Water Inventory Control."

2.2.5 CPS Plant-Specific TSTF-542 TS Variations The licensee proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staff's SE. The licensee stated in the license amendment request (LAR) that these variations do not affect the applicability of TSTF-542 or the NRC staff's SE to the proposed license amendment. Specific details of these variations are described in the LAR.

2.2.5.1 Variation 1, TS Table 3.3.5.1-1 instrumentation function names The licensee provided the following information regarding the TS Table 3.3.5.1 variation:

The CPS TS contain the following requirements that differ from the STS

[Standard Technical Specifications] on which TSTF-542 was based, but are encompassed in TSTF-542 justification. There are CPS specific instrumentation functions that differ from the STS. Changes to these instrumentation functions are encompassed by the discussion in Section 3.3.4 of the TSTF-542 justification.

CPS TS Table 3.3.5.1, Functions 1.d and 2.d describe LPCI and LPCS subsystem start permissives on Reactor Pressure Vessel Pressure Low versus Reactor Steam Dome Pressure Low. The function of these instruments is identical to the ones described in the STS and differ in name only; therefore, this nomenclature is retained in the proposed TS Table 3.3.5.2-1, Functions 1.a and 2.a.

[TS] 3.3.5.1 Function 3.d RCIC Storage Tank Level - Low versus Condensate Storage Tank Level - Low. This is likewise a minor difference, as the RCIC storage tank provides the same function as the Condensate Storage Tank described in the STS (i.e., provides water source for the required HPCS system).

2.2.5.2 Variation 2, LPCI alignment note The licensee provided the following information regarding the LPCI alignment note variation:

2.2.5.3 The STS Note applicable to LCO 3.5.2 regarding the Operability of Low Pressure Coolant Injection (LPCI) subsystems during alignment and operation for decay heat removal in CPS LCO 3.5.2 is currently limited to Surveillance Requirement (SR) 3.5.2.4. The proposed CPS, Unit 1 LCO 3.5.2 includes this Note to align with the STS.

Variation 3, Containment air lock The licensee provided the following information regarding the containment air lock variation:

2.2.5.4 CPS, Unit 1 LCO 3.6.1.2, "Primary Containment Air Locks," is currently applicable while in the OPDRV condition. This is due to the fact that for CPS, Unit 1, the upper Primary Containment personnel airlock prevents Primary Containment bypass leakage and forms a portion of the Gas Control Boundary of Secondary Containment. Therefore, since the Primary Containment upper personnel airlock is considered part of the Secondary Containment boundary for CPS, Unit 1, deletion of the applicability of LCO 3.6.1.2 during OPDRVs is addressed by the proposed LCO 3.5.2, "RPV Water Inventory Control."

Specifically, by LCO 3.5.2, Required Actions C.1 and D.2 which: "Verify secondary containment boundary is capable of being established in less than the DRAIN TIME," and the Required Action to "Initiate action to establish secondary containment boundary," respectively.

Variation 4, TS 3.3.6.1 and TS 3.6.1.3, Isolation instrumentation and valves The licensee provided the following information regarding the isolation instrumentation and valves variation:

[The licensee] proposes to delete CPS, Unit 1 LCO 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation," Condition O and LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," Condition G and all of their associated Required Actions.... LCO 3.3.6.1, Condition O is only applicable during the OPDRV condition, and the Applicability for LCO 3.6.1.3 is: When associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment and Drywe/1 Isolation Instrumentation." These changes are justified since all OPDRV requirements are being deleted, and

2.2.5.5 valves Mode 4 and 5 PCIV requirements have been relocated from LCOs 3.3.6.1 and 3.6.1.3 to the proposed LCOs 3.3.5.2 and 3.5.2. Thus, there are no longer any PCIVs required to be operable by LCO 3.3.6.1 or LCO 3.6.1.3 during OPDRVs or during Mode 4 or 5. These requirements are addressed by the proposed LCO 3.3.5.2 and 3.5.2 in their entirety. Following the removal of OPDRV and relocation of Mode 4 and 5 requirements as discussed above, these Conditions and associated Actions in LCO 3.3.6.1 and LCO 3.6.1.3 would never be applicable; therefore, are no longer necessary.

Variation 5, Residual Heat Removal (RHR) Shutdown Cooling System isolation The licensee provided the following information regarding the RHR SOC system variation:

2.2.5.6 The current Applicability for CPS LCO 3.6.1.3 differs slightly from the STS in that it specifically identifies the Residual Heat Removal (RHR) Shutdown Cooling System suction from the reactor vessel isolation valves during Modes 4 and 5, during the movement of recently irradiated fuel assemblies in the primary or secondary containment, and during OPDRVs. This is in contrast to the STS, where the Applicability is described as Modes 1, 2, and 3, and when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1. The purpose of identifying the RHR Shutdown Cooling System isolation valves when required to be OPERABLE per LCO 3.3.6.1 in the LCO 3.6.1.3 Applicability is related to preventing an inadvertent reactor vessel draindown in Modes 4 and 5.

The functions of preventing an inadvertent reactor vessel draindown and specifying PCIV requirements during OPDRVs are addressed in LCOs 3.3.5.2 and 3.5.2 as proposed, and are therefore deleted from the LCO 3.6.1.3 Applicability.

Variation 6, Table 3.3.6.1-1, Primary Containment Isolation Instrumentation Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation" in TSTF-542, Revision 2, modifies Function 2.g, "Containment and Drywell Ventilation Exhaust Radiation High," which is related to the removal of Footnote (b) which states, "... or operations with a potential for draining the reactor vessel."

In Reference 2, CPS proposed to delete the following additional instrumentation from Table 3.3.6.1-1 which also includes a footnote related to OPDRVs:

Function 2, Item a, "Reactor Vessel Water Level-Low Low, Level 2" Function 2, Item g, "Containment Building Fuel Transfer Pool Ventilation Plenum Radiation-High" Function 2, Item h, "Containment Building Exhaust Radiation-High" Function 2, Item i, "Containment Building Continuous Containment Purge (CCP) Exhaust Radiation-High" Function 2, Item j, "Reactor Vessel Water Level-Low Low Low, Level 1" Function 2, Item I, "Manual Initiation" Function 4, Item f, "Reactor Vessel Level-Low Low, Level 2" Function 4, Item h, "Manual Initiation"

2.2.5.7 Variation 7, HPCS Level 8 injection Valve Isolation and ECCS Manual Initiation Functions In Reference 2, the licensee proposed to revise Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation," to reflect the CPS, Unit 1 design. This corrects an issue in TSTF-542 associated with the BWR/5 and BWR/6 ECCS instrumentation requirements. The following instrumentation are proposed to be deleted that were originally in Reference 1.

Manual Initiation:

Function 1.d, LPCI A and LPCS Function 2.c, LPCI B and LPCI C Function 3.e, HPCS Reactor Vessel Water Level High, Level 8 Function 3.a, HPCS 2.3 Applicable Regulatory Requirements and Guidance The regulation at Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(a)(1 ),

requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must also include in the application a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 1 O CFR 50.36(a)(1 ), these TS bases "shall not become part of the technical specifications."

As required by 10 CFR 50.36(c)(1 ), TSs will include items in the following categories:

(1) Safety limits, limiting safety system settings, and limiting control settings.

(i)(A) Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 1 O CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 1 O CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation at 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria. Specifically, Criterion 4, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety," supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation at 1 O CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Pursuant to 1 O CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 1 O CFR 50.34(b).

As described in 1 O CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide reasonable assurance that the health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including the 1 O CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

NUREG-1434, Revision 4 (Reference 6 and 7), contains the STS for BWR/6 plants and is part of the regulatory standardization effort. The NRC staff has prepared STS for each of the light-water reactor (LWR) nuclear designs. The TSTF changes would be incorporated into future revisions of NUREG-1434, Volumes 1 and 2.

The NRC staff's guidance for the review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," dated March 201 O (Reference 8).

2.3.1 CPS, Unit 1, Applicable Design Requirements CPS Updated Safety Analysis Report (USAR) Section 3.1, "Conformance with NRC General Design Criteria [GDC]" (Reference 9), describes an evaluation of the design bases of the CPS as measured against the NRC GDCs for Nuclear Power Plants, Appendix A of 10 CFR Part 50, effective May 21, 1971, and subsequently amended February 20, 1976. The following GDCs are related to this LAR.

Criterion 13 - "Instrumentation and Control." Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary (RCPB), and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Criterion 14 - "Reactor Coolant Pressure Boundary." The RCPB shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.

Criterion 30 - "Quality of Reactor Coolant Pressure Boundary." Components which are part of the RCPB shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

Criterion 33 - "Reactor Coolant Makeup." A system to supply reactor coolant makeup for protection against small breaks in the RCPB shall be provided. The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the RCPB and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 35 - "Emergency Core Cooling." A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that:

a. fuel and cladding damage that could interfere with continued effective core cooling is prevented, and

b. cladding metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished, assuming a single failure.

3.0 TECHNICAL EVALUATION

3.1 Staff Evaluation of Proposed DRAIN TIME Definition As discussed in Section 2.2.1 above, the DRAIN TIME is the time it would take the RPV water inventory to drain from the current level to the TAF assuming the most limiting of the RPV penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action.

The NRC staff reviewed the DRAIN TIME definition in TSTF-542. For the purpose of NRC staff considerations, the term "break" describes a pathway for water to drain from the RPV that has not been prescribed in the "DRAIN TIME" definition in TSTF-542. Based on information furnished by the licensee in Reference 1, the NRC staff has determined that the licensee is appropriately adopting the principles of DRAIN TIME as specified in TSTF-542. The staff has reasonable assurance that the licensee will include all RPV penetrations below the TAF in the determination of DRAIN TIME as potential pathways. As part of this evaluation, the staff reviewed requests for additional information used during the development of TSTF-542, Revision 2, which provided examples of bounding DRAIN TIME calculations for three examples:

(1) water level at or below the RPV flange; (2) water level above the RPV flange with fuel pool gates installed; and (3) water level above the RPV flange with fuel pool gates removed. The DRAIN TIME is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the drain down event. The discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the DRAIN TIME of the RPV.

The NRC staff concluded that the licensee will use methods resulting in conservative calculations to determine DRAIN TIME, thereby, protecting Safety Limit 2.1.1.3, which meets the requirements of 1 O CFR 50.36(c)(3). Based on these considerations, the NRC staff has determined the licensee's proposed addition of the DRAIN TIME definition to the CPS TSs to be acceptable.

3.2 Staff Evaluation of Proposed TS 3.3.5.2, RPV WIC Instrumentation The existing TS 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," is proposed to be renumbered as TS 3.3.5.3. This would achieve consistency within the CPS TS and, therefore, the NRC staff concludes that it is acceptable.

The purpose of the proposed new TS 3.3.5.2, RPV WIC instrumentation, is to support the requirements of the proposed new TS LCO 3.5.2, and the proposed new definition of DRAIN TIME. There are instrumentation and controls and their signal functions that are required for manual pump starts or required as a permissive or operational controls on the equipment of the systems that provide water injection capability, certain start commands, pump protection, and isolation functions. These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable as described in Section 3.3 of this SE for proposed new TS 3.5.2. For CPS, reactor operators also have manual initiation push buttons that automatically align water injection into the reactor vessel.

Specifically, the RPV WIC instrumentation supports operation of the LPCI with subsystems LPCI A, LPCI B, and LPCI C, LPCS, and HPCS, including manual alignment when needed as well as the system isolation of the RHR system and the RWCU system. The equipment involved with each of these systems is described in the evaluation of TS 3.5.2 and the Bases for LCO 3.5.2.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.2 LCO and Applicability In Reference 1, the licensee proposed a new TS 3.3.5.2 to provide alternative instrumentation requirements to support manual alignment of the ECCS injection/spray subsystem required in proposed new TS 3.5.2 and automatic isolation of penetration flow paths that may be credited in the determination of DRAIN TIME. The current TS contain instrumentation requirements related to OPDRVs in TS Table 3.3.5.1-1, TS Table 3.3.6.1-1, TS Table 3.3.6.2-1, and TS Table 3.3.7.1-1. These requirements from TS Table 3.3.5.1-1 and TS Table 3.3.6.1-1 would be consolidated into proposed new TS 3.3.5.2. The evaluation of deletion of references to OPDRVs from TS Table 3.3.6.2-1 and TS Table 3.3. 7.1-1 can be found below in Section 3.6 of this SE.

The proposed LCO 3.3.5.2 would state:

The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

The proposed Applicability would state, "According to Table 3.3.5.2-1."

TSTF-542 selected Table 3.3.5.2-1 to contain those instrumentation functions needed to support manual alignment of the ECCS injection/spray subsystem required by LCO 3.5.2, and automatic isolation of penetration flow paths that may be credited in a calculation of DRAIN TIME. The functions in Table 3.3.5.2-1 are moved from existing TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and TS 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation" functions that are required in MODES 4 or 5 or during OPDRVs.

Creation of TS 3.3.5.2 places these functions in a single location with requirements appropriate to support the safety function for TS 3.5.2.

The NRC staff concluded that the licensee's proposed alternative is acceptable for CPS since either HPCS, LPCS, or LPCI (or all three) subsystems would be available to perform the intended function to inject water into the RPV, which is consistent with the NRG-approved TSTF-542.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.2 Actions Section 2.2.2.2 above describes the new proposed TS 3.3.5.2. The NRC staff has determined that the licensee's proposed new TS 3.3.5.2 Actions are sufficient and necessary because when one or more instrument channels are inoperable, the equipment and function controlled by these instruments cannot complete the required function in the normal manner. The Actions are evaluated as follows:

Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.2-1 and directs the licensee to immediately enter the Condition referenced in Table 3.3.5.2-1 for that channel.

Action B (concerning the RHR system isolation and RWCU system isolation functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 requires a re-calculation of DRAIN TIME, but automatic isolation of the affected penetration flow paths cannot be credited.

Action C (concerning LPCS and LPCI reactor pressure low permissive functions necessary for ECCS subsystem manual alignment) addresses an event in which the permissive is inoperable and manual start of ECCS using the control board switches is prevented. The function must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive function instrument in the trip condition, manual pump injection may now be performed using the preferred control board switches. This 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months completion time is acceptable, because the reactor operator can take manual control of the pump and the injection valve to inject water into the RPV and achieve the safety function. The time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months also provides reasonable time for evaluation and placing the channel in trip.

Action D (concerning loss of adequate water supply for the HPCS system), addresses an event in which there is an inadequate water supply. The instrumentation functions have the ability to detect low-water setpoint in the RCIC storage tank and actuate valves to realign HPCS suction water source to the suppression pool. The RCIC storage tank Level - Low Function indicates multiple, inoperable channels within the same function resulting in a loss of the automatic ability to swap suction to the Suppression Pool. The HPCS system must be declared inoperable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or the HPCS pump suction must be realigned to the suppression pool, since, if realigned, the function is already performed. This one hour is acceptable, because it provides sufficient time to take the action in order to minimize the possible risk of HPCS being needed without an adequate water source by allowing time for restoration or alignment of the HPCS pump suction to the suppression pool.

Action E (concerning LPCS/LPCI/HPCS pump discharge flow bypass functions and HPCS discharge pressure high pressure - bypass function) addresses an event in which the bypass is inoperable and there is a risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open.

In these conditions, the operator can take manual control of the pump and the injection.

Similar to the justification in Action C, while this is not the preferred method, the ECCS subsystem pumps can be started manually and the valves can be opened manually.

The 24-hour completion time is acceptable, because the functions can be performed manually and it allows time for the operator to evaluate and have necessary repairs completed.

Action F is needed and becomes necessary if the Required Action and associated completion time of Conditions C, D, or E are not met. If they are not met, then the associated ECCS injection/spray subsystem may be incapable of performing the intended function, and the ECCS subsystem must be declared inoperable immediately.

These Actions direct the licensee to take appropriate actions as necessary and enter immediately into the conditions referenced in Table 3.3.5.2-1. The NRC staff has determined that these Actions satisfy the requirements of 1 O CFR 50.36(c)(2)(i) by providing a remedial action permitted by the TS until the LCO can be met. Therefore, the staff has concluded that there is reasonable assurance that the licensee will take appropriate Actions during an unexpected drain event to either prevent or to mitigate RPV water level being lowered to the TAF and that the licensee's proposed changes are acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.2 Surveillance Requirements The proposed new TS 3.3.5.2 SRs include Channel Checks and Channel Functional Tests numbered SR 3.3.5.2.1 and SR 3.3.5.2.2, respectively.

The NRC staff finds that these tests are sufficient and adequate because they are essential to ensure the functions of TS 3.3.5.2 are operable (i.e., capable of performing the specified safety function in support of TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in MODES 4 and 5). The NRC staff finds that the proposed SRs of LCO 3.3.5.2 as described in Section 3.3.3 of the TSTF-542 justification, satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

SR 3.3.5.2.1 would require a Channel Check and applies to all functions. Performance of the Channel Check would ensure 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 related channels. A Channel Check is significant in assuring that there is a low probability of an undetected complete channel failure and is a key safety practice to verifying the instrumentation continues to operate properly between each Channel Functional Test. The frequency of in accordance with the Surveillance Frequency Control Program (SFCP), is consistent with the existing requirements and supports operating shift situational awareness.

SR 3.3.5.2.2 would require a Channel Functional Test and applies to all functions. A Channel Functional Test is the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability of all devices in the channel required for channel operability. It would be performed on each required channel to ensure that the entire channel will perform the intended function and the frequency would be in accordance with the SFCP.

This is acceptable because it is consistent with the existing requirements for these functions. In addition, if licensees so desire, this SR could be included as part of a refueling activity, since during refueling outages, periods in MODES 4 and 5 are often 30 days or less.

TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a Channel Calibration or a surveillance to calibrate the trip unit. This was because a draining event in MODES 4 or 5 is not an analyzed accident and, therefore, there is no accident analysis on which to base the calculation of a setpoint. The purpose of the functions is to allow ECCS manual alignment or to automatically isolate a penetration flow path, but no specific RPV water level is assumed for those actions. Therefore, the MODE 3 allowable value was chosen for use in MODES 4 and 5 as it will perform the desired function. Calibrating the functions in MODES 4 and 5 is not necessary, as TS 3.3.5.1 and TS 3.3.6.1 continue to require the functions to be calibrated on an established interval. Similarly, there are no accident analysis assumptions on response time because a draining event in MODES 4 or 5 is not an analyzed accident. This is acceptable, because this is adequate to ensure that the channel responds with the required pumping systems to inject water when needed and isolation equipment to perform when commanded.

ECCS Response Time (SR 3.5.1.8) and Isolation System Response Time (SR 3.3.6.1.7) testing ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Proposed new TS 3.3.5.2 does not include SRs to participate in any ECCS Response Time testing and Isolation System Response Time testing.

This is acceptable because the purpose of these tests are to ensure that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis, but a draining event in MODES 4 or 5 is not an analyzed accident and, therefore, there are no accident analysis assumptions on response time and there are alternate manual methods for achieving the safety function. A potential draining event in MODES 4 and 5 is a slower event than a LOCA. More significant protective actions are required as the calculated DRAIN TIME decreases.

3.2.4 Staff Evaluation of Proposed Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation" In order to support the requirements of proposed TS 3.5.2, the associated instrumentation requirements would be designated in Table 3.3.5.2-1. These instruments would be required to be operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2 (Section 3.3 below).

Proposed Table 3.3.5.2-1 specifies the instrumentation that shall be operable for each function in the table for MODES 4 and 5 (or other specified conditions), the required number of channels per function, conditions referenced from Required Action A.1, SR for the functions, the allowable value, and footnotes concerning items of the table.

Proposed Table TS 3.3.5.2-1 presents details on the functions required to support the equipment and functions of TS 3.5.2. The NRC staff finds the presentation in this table to be acceptable, because this section sufficiently discusses the purpose of the functions, the applicability, the number of required channels, the references to the condition to be entered by letter (e.g., A, 8, C) if the function is inoperable, the applicable SRs, the selection of the allowable value, and justification of differences between the existing and proposed TS functions.

This RPV WIC instrumentation set is acceptable, because it is adequate to ensure that the channels of instrumentation respond with the required accuracy permitting pumps systems to operate to inject water when needed and isolating equipment when commanded to support the prevention of or to mitigate a potential RPV draining event.

Each of the ECCS subsystems in MODES 4 and 5 can be started by manual alignment of a small number of components. Automatic initiation of an ECCS injection/spray subsystem may be undesirable because it could lead to overflowing the RPV cavity, due to injection rates of thousands of gallons per minute. Thus, there is adequate time to take manual actions (e.g.,

hours versus minutes). Considering the action statements as the DRAIN TIME decreases (the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in DRAIN TIME less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), there is sufficient time for the reactor operators to take manual action to stop the draining event, and to manually start an ECCS injection/spray subsystem or additional method of water injection as needed. Consequently, there is no need for automatic initiation of ECCS to respond to an unexpected draining event. This is acceptable because a draining event is a slow evolution when compared to a design basis LOCA assumed to occur at a significant power level.

3.2.4.1 Staff Evaluation of Proposed Table 3.3.5.2-1 Functions For the Table 3.3.5.2-1 Functions 1.a and 2.a, LPCS and LPCI Systems, Reactor Vessel Pressure - Low (Injection Permissive), these signals would be used as permissives and protection for these low pressure ECCS injection/spray subsystem manual alignment functions.

These functions would ensure that the reactor pressure has fallen to a value below these subsystems' maximum design pressure before permitting the operator to open the injection valves of the low pressure ECCS subsystems. Even though the reactor steam dome pressure is expected to virtually always be below the ECCS maximum design pumping pressure during MODES 4 and 5, the Reactor Vessel Pressure - Low signals are required to be operable and capable of permitting initiation of the ECCS. The proposed Allowable Value is :5 494 pounds per square inch gauge (psig), with four required channels per function, as it is currently in CPS TS Table 3.3.5.1-1. The proposed allowable value is revised to eliminate the low pressure limit and to retain the high pressure limit. The RPV pressure is well below the lower limit in MODES 4 and 5; therefore, the low pressure limit is not needed.

For the Table 3.3.5.2-1 Functions 1.b, 1.c, and 2.b, LPCS and LPCI Systems, LPCI and Low Pressure Core Spray Pump Discharge Flow - Low (Bypass), these instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump where applicable allowable values specified are high enough to ensure that the pump flow rate is sufficient to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.

For LPCS the existing Allowable Value is~ 750 gallons per minute (gpm) and the existing required channels per function is 1 and was previously found in CPS TS Table 3.3.5.1-1. The proposed Allowable Value remains as ~ 750 psig and the proposed required channels per function is changed to one per pump.

For LPCI A, B, and C subsystems, the existing Allowable Value is ~ 900 gpm and the existing required channels per function is 1 and was previously found in CPS TS Table 3.3.5.1-1. The proposed Allowable Value remains as ~ 900 psig and the proposed required channels per function is changed to one per pump.

For the Table 3.3.5.2-1 Function 3.a, HPCS System, RCIC Storage Tank Level - Low, the low level signal in the RCIC storage tank indicates the lack of an adequate supply of makeup water from this primary source for HPCS. Normally, the water source for the suction for HPCS is the RCIC storage tank. If the water level in the RCIC storage tank falls below a preselected level, instrumentation logic controls valves so suction is then opened from the suppression pool. First the suppression pool suction valve is automatically opened and then the RCIC storage tank suction valve is automatically closed in a manner to ensure that an adequate supply of makeup water is available to the HPCS pump. The RCIC Storage Tank Level - Low signals are initiated from two level transmitters. The RCIC Storage Tank Level - Low Function allowable value is high enough to ensure adequate pump suction head while water is being taken from the RCIC storage tank. The existing Allowable Value is~ 3.0 inches and the existing required channels per function is 2 and was previously found in CPS TS Table 3.3.5.1-1. The proposed Allowable Value remains at ~ 3.0 inches and the proposed required channels per function remains at 2.

For the Table 3.3.5.2-1 Functions 3.b and 3.c, HPCS System, HPCS Pump Discharge Pressure - High (Bypass) and HPCS System Flow Rate - Low (Bypass), the minimum flow instruments are provided to protect the HPCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow and high pump discharge pressure are sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump or the discharge pressure is low (indicating the HPCS pump is not operating).

For the HPCS high pressure function high allowance value, this setpoint is set high enough to ensure that the valve will not open when the pump is not operating. The existing Allowable Value is ~ 120 psig and the existing required channels per function is 1 and was previously found in CPS TS Table 3.3.5.1-1. The proposed Allowable Value remains at ~ 120 psig and the proposed required channels per function remains at 1.

For HPCS low flow function, the existing allowable value is~ 500 gpm and the existing required channels per function is 1 and was previously found in CPS TS Table 3.3.5.1-1. The proposed allowable value remains at ~ 500 gpm and the proposed required channels per function remains at 1.

For the Table 3.3.5.2-1 Function 4.a, RHR System Isolation, Reactor Vessel Water Level - Low, Level 3, the function is only required to be operable when automatic isolation of the associated RHR system penetration flow path is credited in calculating DRAIN TIME. The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level dropping below the TAF, but if the instrument function is inoperable, a closed path cannot be credited and a drain time calculation must be re-performed. The existing Allowable Value is

.:: 8.3 inches and the existing required channels per function is 4 and was previously found in CPS TS Table 3.3.6.1-1. The proposed Allowable Value remains at.:: 8.3 inches and the proposed required channels per function is changed to 2 in one trip system.

For the Table 3.3.5.2-1 Function 5.a, RWCU System Isolation, Reactor Vessel Water Level - Low Low, Level 2, the function is only required to be operable when automatic isolation of the associated RWCU system penetration flow path is credited in calculating DRAIN TIME.

The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level dropping below the TAF, but if the instrument function is inoperable, a closed path cannot be credited and a DRAIN TIME calculation must be re-performed. This function is not applicable in MODES 4 or 5 in TS 3.3.6.1, but is being added to TS 3.3.5.2 to support crediting the automatic isolation of the RWCU system in calculating DRAIN TIME. The existing Allowable Value is.:: - 48.1 inches and the existing required channels per function is 4 and was previously found in CPS TS Table 3.3.6.1-1. The proposed Allowable Value remains at.:: - 48.1 inches and the proposed required channels per function is changed to 2 in one trip system.

The NRC staff finds that proposed new LCO 3.3.5.2 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined that the licensee's proposed changes to LCO 3.3.5.2 are acceptable.

3.3 Staff Evaluation of TS 3.5.2, RPV WIC The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2.

The proposed LCO 3.5.2 would state, in part, "One ECCS injection/spray subsystem shall be OPERABLE."

"One ECCS injection/spray subsystem" is defined as either one of the three LPCI subsystems (LPCI A, LPCI B, or LPCI C), one LPCS system, or one HPCS system. The LPCI subsystem and the LPCS system consist of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. The HPCS system consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or RCIC storage tank to the RPV.

The ECCS pumps are high-capacity pumps, with flow rates of thousands of gpm. Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual alignmenVstart of an ECCS pump would provide the necessary water source to counter these expected drain rates. The LPCI subsystem (only LPCI A or LPCI B subsystems) are to be considered operable during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable. (This position was later modified by the licensee and approved by the NRC staff to consider the LPCI subsystem to be inoperable during alignment and operation for decay heat removal - See SE Section 3.5.2). Decay heat removal in MODES 4 and 5 is not affected by the proposed change in TSTF-542 as these requirements on the number of RHR SOC subsystems that must be operable and in operation to ensure adequate decay heat removal from the core are unchanged. These requirements can be found in the CPS TS 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.7, "Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods," TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.9, "Residual Heat Removal (RHR) Low Water Level." These CPS decay heat removal requirements are similar to the STS and can be found in the NUREG-1434, TS 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.7, "Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods," TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.9, "Residual Heat Removal (RHR) - Low Water Level." Based on these considerations, the NRC staff finds that the water sources provide reasonable assurance that the lowest functional capability required for safe operation is maintained and the safety limit is protected.

The proposed LCO 3.5.2 would also state that DRAIN TIME of RPV water inventory to the TAF shall be ;:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed applicability for TS 3.5.2 is MODES 4 and 5.

The proposed LCO 3.5.2 note would state (per LAR dated May 1, 2017):

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

The proposed addition of this Note and the proposed deletion of a similar Note from existing SR 3.5.2.4 is evaluated in Section 3.5.2 of this SE (Variation 2).

The NRC staff reviewed the proposed TS 3.5.2, focusing on ensuring that the fuel remains covered with water and on the changes made compared to the current TS. The proposed TS 3.5.2 contains Conditions A through E based on either required ECCS injection/spray subsystem operability or DRAIN TIME.

The current TS LCO states that two ECCS injection/spray subsystems shall be operable, whereas the proposed LCO 3.5.2 states that only one ECCS injection/spray subsystem shall be operable. This change is reflected in Condition A. The change from two ECCS injection/spray subsystem to one ECCS injection/spray subsystem is because this redundancy is not required.

With one ECCS injection/spray subsystem and nonsafety-related injection sources, defense-in-depth (DID) will be maintained. The DID measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The proposed MODES 4 and 5 applicability of TS 3.5.2 is appropriate given that the TS requirements on ECCS in MODES 1, 2, and 3 will be unaffected.

The proposed Condition A states that if the required ECCS injection/spray subsystem is inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Proposed Condition B states that if Condition A is not met, a method of water injection capable of operating without offsite electrical power shall be established immediately. The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour completion time.

The proposed Condition C states that for a DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (C.1) verify secondary containment boundary is capable of being established in less than the DRAIN TIME with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.2) verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.3) verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection should the DRAIN TIME be< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and

~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operations.

The proposed Condition D states that for a DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (D.1) immediately initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and (0.2) immediately initiate action to establish secondary containment boundary, and (0.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (0.4) immediately initiate action to verify one standby gas treatment system is capable of being placed in operation. Additionally, there is a Note stating that required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power, which is similar to proposed Condition B. The current CPS TS for Condition D are similar to the proposed for when Required Action C.2 is not met. The proposed Condition D provides adequate protection should the DRAIN TIME be< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operation.

The proposed Condition E states that when the required action and associated completion time of Condition C or Dis not met, or the DRAIN TIME is< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then immediately initiate action to restore DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed Condition Eis new, as it is not present in the current CPS TS. The proposed Condition E is acceptable as it provides the necessary step to restore the DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should the other conditions not be met, or if the DRAIN TIME is< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The NRC staff reviewed the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the TAF with the water sources available and maintaining DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 Surveillance Requirements The proposed TS 3.5.2 SRs include verification of DRAIN TIME, verification of water levels/volumes that support LPCS system and LPCI subsystems, verification of water levels/volumes that support HPCS system, verification of water filled pipes to preclude water hammer events, verification of correct valve positions for the required ECCS injection/spray subsystem, operations of ECCS injection/spray systems through the recirculation line, verification of valves credited for automatic isolation actuated to the isolation position, and verification that the required ECCS injection/spray subsystem can be manually operated. Each of the eight SRs are described below.

SR 3.5.2.1: The DRAIN TIME would be determined or calculated, and required to be verified to be.:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the SFCP. This surveillance would verify that the LCO for DRAIN TIME is met. Numerous indications of changes in RPV level are available to the operator. The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant (normally three operator shifts). Changes in RPV level would necessitate recalculation of the DRAIN TIME.

SR 3.5.2.2: The suppression pool water level(.:: 12 feet 8 inches) for a required low pressure ECCS injection/spray subsystem is required to be verified to ensure pump net positive suction head and vortex prevention is available for the LPCI/LPCS subsystem required to be operable by the LCO. Indications are available either locally or in the control room regarding suppression pool water level. This surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.3: The suppression pool water level(.:: 12 feet 8 inches) or RCIC storage tank level

(.:: 125,000 gallons) for a required HPCS system is required to be verified to ensure pump net positive suction head and vortex prevention is available for the HPCS subsystem required to be operable by the LCO. Indications are available either locally or in the Control Room regarding suppression pool water level and RCIC storage tank level. This surveillance is required to be performed in accordance with the SFCP.

SR 3.5.2.4: The surveillance requirement to verify the ECCS injection/spray subsystem piping is sufficiently filled with water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one ECCS injection/spray subsystem to be operable instead of two. SR 3.5.2.4 wording would change from "Verify, for each required ECCS... " to "Verify, for the required ECCS... " This change clarifies the requirement to maintain consistency with the proposed LCO. Maintaining the pump discharge lines of the required ECCS injection/spray subsystem sufficiently full of water ensures that the ECCS subsystem will perform properly. One acceptable method of ensuring that the lines are full is to vent at the high points. This surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.5: The SR to verify the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2.

Similar to the change discussed above for proposed SR 3.5.2.4, changes to SR 3.5.2.5 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "Verify, for the required ECCS injection/spray subsystem, each manual... " would replace "Verify each required ECCS injection/spray subsystem manual,... " SR 3.5.2.5 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This SR would not apply to valves that are locked, sealed, or otherwise secured in position, since these valves would be verified to be in the correct position prior to locking, sealing, or securing. This surveillance would be required to be performed in accordance with the SFCP.

A Note is maintained from the existing SR 3.5.2.4 that states; "Not required to be met for system vent flow paths opened under administrative controls." The Note exempts system vent flow paths opened under administrative control. The administrative control includes stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

SR 3.5.2.6: The required ECCS injection/spray subsystem would be required to be operated through its recirculation line for~ 10 minutes in accordance with the SFCP. This would demonstrate that the subsystem is capable for operation to support TS 3.5.2, RPV WIC.

Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 1 O minutes is based on engineering judgement.

SR 3.5.2.7: Verification that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. This surveillance is required to be performed in accordance with the SFCP.

SR 3.5.2.8: This SR would state, "Verify the required ECCS injection/spray subsystem can be manually operated." It would demonstrate that the required ECCS subsystem could be manually initiated to provide additional RPV water inventory, if needed. By operating the associated pump and valve switches which operates all active components, water flow can be demonstrated by recirculation through the test line. Vessel injection/spray may be excluded from the SR, per the existing Note. The manual initiation push button for the ECCS subsystems are not used to satisfy this SR, see Variation 7, Sections 2.2.5.7 and 3.5.7 of this SE. This surveillance would be required to be performed in accordance with the SFCP.

The NRC staff evaluated each of these proposed SRs associated with the proposed LCO 3.5.2 and concluded that they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. The NRC staff concluded that each of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating experience and 10 CFR 50.36(c)(3) for surveillance requirements by ensuring that the necessary quality of systems and components are maintained.

3.4 TS Table 3.3.5.1-1, "ECCS Instrumentation" LCO 3.3.5.1 currently states that, "[t]he ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE," with the applicability as stated in the table. Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," currently contains requirements for function operability during MODES 4 and 5 when the associated ECCS subsystem(s) are required to be operable per LCO 3.5.2, "ECCS - Shutdown." Conforming changes were proposed for the Actions table of LCO 3.3.5.1 as well.

For the following functions in Table 3.3.5.1-1, MODES 4 and 5 requirements would be either deleted or relocated to proposed Table 3.3.5.2-1.

FUNCTION MODES4AND5 MODES4AND5 REQUIREMENTS REQUIREMENTS DELETED RELOCATED TO TABLE 3.3.5.2-1

1. Low Pressure Coolant Injection - A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems;

a.

Reactor Vessel Water Level - Low Low Low, Yes Level 1 C.

LPCI Pump A Start - Time Delay Loqic Card Yes

d.

Reactor Vessel Pressure - Low (Injection Function 1.a Permissive)

e.

LPCS Pump Discharge Flow-Low (Bypass)

Function 1.b

f.

LPCI Pump A Discharge Flow-Low (Bypass)

Function 1.c

g.

Manual Initiation Yes

2.

LPCI B and LPCI C Subsystems;

a.

Reactor Vessel Water Level - Low Low Low, Yes Level 1 C.

LPCI Pump B Start - Time Delay Logic Card Yes

d.

Reactor Vessel Pressure - Low (Injection Function 2.a Permissive)

e.

LPCI Pump B and LPCI Pump C Discharge Flow-Function 2.b Low (Bypass)

f.

Manual Initiation Yes

3. High Pressure Core Spray (HPCS) System;

a.

Reactor Vessel Water Level - Low Low, Level 2 Yes C.

Reactor Vessel Water Level - High, Level 8 Yes

d.

RCIC Storage Tank Level - Low Function 3.a

f.

HPCS Pump Discharge Pressure - High Function 3.b (Bypass)

g.

HPCS System Flow Rate - Low (Bypass)

Function 3.c

h.

Manual Initiation Yes As shown in the table above, nine functions above would be deleted completely to support the consolidation of RPV WIC instrumentation requirements into proposed TS 3.3.5.2. The other eight functions would be moved to proposed TS Table 3.3.5.2-1 as discussed in Section 3.2.4.1 of this SE.

The CPS TS currently require automatic initiation of ECCS pumps on low Reactor Vessel water level. However, in MODES 4 and 5, automatic initiation of ECCS pumps could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment.

The NRC staff finds acceptable the deletion of TS Table 3.3.5.1-1 Functions 1.a, 2.a, and 3.a because manual ECCS alignment is preferred over automatic initiation during MODES 4 and 5, and the operator would be able to use other, more appropriately sized pumps if needed to mitigate a draining event. In addition, the NRC staff finds acceptable the deletion of TS Table 3.3.5.1-1 Functions 1.c and 2.c for the LPCI A and B pump start time delay relays. The purpose of these time delays is to stagger the automatic start of LPCI pumps thus limiting the starting transients on the emergency buses. The staggered starting of ECCS pumps is unnecessary for manual ECCS operation.

The deletion of manual initiations Functions 1.g, 2.f, 3.h, and HPCS vessel water high Level 8 interlock (Function 3(c)) are evaluated in Variation 7 in Section 3.5.7 of this SE.

3.5 Staff Evaluation of Proposed Technical Variations The licensee proposed the following seven technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staff's SE for TSTF-542. The licensee stated in the LAR that these variations do not affect the applicability of TSTF-542 or the NRC staff's SE for TSTF-542 to the proposed license amendment. The NRC staff evaluated each variation below.

3.5.1 Variation 1, TS Table 3.3.5.1-1 instrumentation function names As described in Section 2.2.5.1 of this SE, the CPS TS contain instrumentation functions that differ from the STS.

CPS TS Table 3.3.5.1-1, Functions 1.d and 2.d, describe LPCI and LPCS subsystem start permissives on Reactor Pressure Vessel Pressure - Low versus Reactor Steam Dome Pressure - Low.

CP TS Table 3.3.5.1-1, Function 3.d, RCIC Storage Tank Level - Low versus Condensate Storage Tank Level - Low.

The NRC staff finds that the instrumentation name differences, which are a part of the existing license, are an acceptable variation and do not change the conclusion that TSTF-542 is applicable to the CPS TS.

3.5.2 Variation 2, LPCI alignment note As described in Section 2.2.5.2 of this SE, the May 1, 2017, LAR has the following Note for TS SR 3.5.2.4:

One low pressure coolant injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

In the May 1, 2017, LAR, the licensee proposed to delete this Note from SR 3.5.2.4 and add a similar note to the new TS 3.5.2, consistent with TSTF-542. The proposed Note states:

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

This is a minor variation of the Note location and a slight variation of the Note content ("One" versus "A"). The NRC staff finds that these differences do not alter the conclusion that TSTF-542 is applicable to the CPS TS.

After Reference 1 was submitted for the NRC staff review on May 1, 2017, the licensee submitted an LAR dated, May 4, 2017 (Reference 10), in which the licensee proposed to replace the above Note with a new Note that reads as follows:

One low pressure coolant injection (LPCI) subsystem may be inoperable during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure.

The licensee determined that the current Note could potentially allow operating conditions to exist that could adversely impact the function of the RHR system because high pressure, high temperature water when introduced to the low pressure piping could result in voiding in the suction piping, RHR pump cavitation, water hammer, and associated RHR system damage.

The NRC staff approved the request to modify the Note by amendment dated January 22, 2018 (Reference 11 ), and authorized the use of the new Note in CPS LCO 3.5.2. The rationale to replace the Note with one that declares the pump "INOPERABLE," rather than "OPERABLE,"

was further discussed in the associated staff SE.

3.5.3 Variation 3, Containment air lock As described in Section 2.2.5.3 of this SE, CPS TS LCO 3.6.1.2, "Primary Containment Air Locks," is currently applicable while in the OPDRV condition and since the primary containment upper personnel airlock is considered part of the secondary containment boundary for CPS, deletion of the applicability of LCO 3.6.1.2 during OPDRVs is addressed by the proposed LCO 3.5.2, "RPV Water Inventory Control."

The NRC staff finds that this variation is equivalent to current TS requirements for the Primary Containment Air Locks and is consistent with the treatment of other secondary containment boundaries as discussed in Section 3.4.2, "Other Proposed Changes - Containment, Containment Isolation Valves, and Standby Gas Treatment Requirements," of the justification for TSTF-542, Revision 2. Therefore, the NRC staff finds that this difference does not alter the conclusion that TSTF-542 is applicable to the CPS TS.

3.5.4 Variation 4, TS 3.3.6.1 and TS 3.6.1.3, Isolation instrumentation and valves As described in Section 2.2.5.4 of this SE, the licensee proposes to delete CPS TS LCO 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation," Condition O and LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," Condition G and all of their associated Required Actions.

The NRC staff finds that this variation is consistent with the treatment of other primary containment isolation instruments as discussed in Section 3.4.1.2, "TS 3.3.6.1A and 3.3.6.1 b, Primary Containment Isolation Instrumentation," and in Section 3.4.2, "Other Proposed Changes

- Containment, Containment Isolation Valves, and Standby Gas Treatment Requirements," of the justification for TSTF-542, Revision 2. The NRC staff finds that the existing TS LCO 3.3.6.1, Condition 0, and LCO 3.6.1.3, Condition G, are only applicable during the OPDRV condition and, therefore, that these differences do not alter the conclusion that TSTF-542 is applicable to the CPS TS.

3.5.5 Variation 5, RHR SOC system isolation valves As described in Section 2.2.5.5 of this SE, the current applicability for CPS TS LCO 3.6.1.3 differs slightly from the STS in that it specifically identifies the RHR SOC suction from the reactor vessel isolation valves during MODES 4 and 5, during CORE ALTERATIONS, during the movement of irradiated fuel assemblies in the primary or secondary containment, and during OPDRVs.

CPS TS LCO 3.6.1.3 Applicability states, in part:

MODES 4 and 5 for RHR Shutdown Cooling System suction from the reactor vessel isolation valves when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation," Function 5.c.

This is in contrast to the STS, where the Applicability is described as MODES 1, 2, and 3, and when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1.

The purpose of identifying the RHR SOC system isolation valves when required to be OPERABLE per LCO 3.3.6.1 in the CPS TS LCO 3.6.1.3 Applicability is related to preventing an inadvertent reactor vessel draindown in MODES 4 and 5.

The NRC staff finds that the functions of preventing an inadvertent reactor vessel draindown and specifying PCIV requirements during OPDRVs are addressed in LCOs 3.3.5.2 and 3.5.2 as proposed, and are, therefore, deleted from the LCO 3.6.1.3 Applicability. Therefore, the NRC staff finds that this difference does not alter the conclusion that TSTF-542 is applicable to the CPS TS.

3.5.6 Variation 6, Table 3.3.6.1-1, Primary Containment Isolation Instrumentation Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation" in TSTF-542, Revision 2, modifies Function 2.g, "Containment and Drywell Ventilation Exhaust Radiation High," which is related to the removal of Footnote (b) which states,"... or operations with a potential for draining the reactor vessel."

The licensee proposed to delete from Table 3.3.6.1-1 additional instrumentation including:

Function 2, Item a, "Reactor Vessel Water Level-Low Low, Level 2" Function 2, Item g, "Containment Building Fuel Transfer Pool Ventilation Plenum Radiation-High" Function 2, Item h, "Containment Building Exhaust Radiation-High" Function 2, Item i, "Containment Building Continuous Containment Purge (CCP) Exhaust Radiation-High" Function 2, Item j, "Reactor Vessel Water Level-Low Low Low, Level 1" Function 2, Item I, "Manual Initiation" Function 4, Item f, "Reactor Vessel Level-Low Low, Level 2" Function 4, Item h, "Manual Initiation" In Reference 2, the licensee provided as clarification for this proposed change that all of these instrument functions serve to isolate primary containment penetrations that bypass secondary containment; therefore, they function to isolate a portion of the secondary containment boundary for CPS. Under the proposed TS 3.5.2 requirements, Secondary Containment must be isolated or capable of being isolated in less than the DRAIN TIME when the DRAIN TIME is less than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , but automatic secondary containment isolation is not required.

The NRC staff finds that the licensee removed the appropriate instrumentation from TS Table 3.3.6.1-1 consistent with Section 3.4.1.3, "TS 3.3.6.2A and 3.3.6.2B, Secondary Containment Isolation Instrumentation," of the justification for TSTF-542, Revision 2. A draining event is a slow evolution when compared to a design basis LOCA that is assumed to occur at full power, and thus there is adequate time to take manual actions (i.e., hours versus minutes). There is sufficient time for the licensed operators to take manual action to stop the draining event, or to establish the secondary containment boundary and to isolate the secondary containment penetration flow paths before secondary containment isolation would be required. This can be found specifically in LCO 3.5.2, Required Actions C.1 and D.2, which state, "Verify secondary containment boundary is capable of being established in less than the DRAIN TIME," and "Initiate action to establish secondary containment boundary," respectively. Consequently, there is no need for automatic initiation of secondary containment isolation to respond to an unexpected draining event. Therefore, the NRC staff finds Variation 6 to be acceptable.

3.5.7 Variation 7, HPCS Level 8 Injection Valve Isolation and ECCS Manual Initiation Functions In Reference 2, the licensee proposed to revise Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation," to reflect the CPS design. This would correct an issue in TSTF-542 associated with the BWR/5 and BWR/6 ECCS instrumentation requirements. Specifically, the following instrumentation are proposed to be deleted that were originally in Reference 1.

Manual Initiation:

Function 1.d, LPCI A and LPCS Function 2.c, LPCI B and LPCI C Function 3.e, HPCS Reactor Vessel Water Level High, Level 8 Function 3.a, HPCS The licensee provided the following additional information:

The purpose of the manual initiation functions is to allow manual actuation of the ECCS subsystems required by TS 3.5.2 to mitigate a draining event. Licensed operators in the Main Control Room have the capability to manually start the LPCI, LPCS, and HPCS pumps and to manually align valves to add water inventory, if needed. This can be accomplished without the "Manual Initiation" functions, and the "Reactor Vessel Water Level-High, Level 8" function associated with HPCS. If the water level is above Level 8, and HPCS is the required ECCS subsystem, the Level 8 function can be intentionally defeated to allow the HPCS injection valve to be opened, if needed to control inventory. All actions can be performed from the Main Control Room and can be accomplished well within the one-hour minimum drain time limit specified in TS 3.5.2, Condition E.

The Reactor Vessel Water Level High, Level 8 signal (i.e., TSTF-542, Table 3.3.5.2-1, Function 3.a) prevents overfilling of the reactor vessel into the main steam lines by closing the HPCS injection valves when the water level is above the Level 8 setpoint. Therefore, if HPCS is the required ECCS subsystem and the water level is above Level 8, using the "Manual Initiation" Function 3.e will not result in inventory injection into the reactor vessel until the water level drops below the Level 8 setpoint. If the Level 8 function is retained in Table 3.3.5.2-1, the function would need to be rendered inoperable in order to inject water when the water level is above the Level 8 setpoint.

To address the changes associated with the proposed additional variation discussed above, EGG also proposes that [SR] 3.5.2.8 be modified to verify that the CPS, Unit 1 required ECCS injection/spray subsystem can be manually operated from the Main Control Room in accordance with the [SFCP]. This will ensure that the required ECCS injection/spray subsystem is Operable and can be manually aligned to provide RPV inventory makeup, if required to do so, without delay.

In Reference 1, SR 3.5.2.8 stated:

1\\JOTE-------------------------------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.

By Reference 2, the licensee proposed to modify SR 3.5.2.8 to state:

1\\JOTE-------------------------------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

TS 3.3.5.2, Condition E and associated Required Actions and Completion Times, as described in Reference 1 and consistent with TSTF-542, are shown below.

COI\\JDITIOI\\J REQUIRED ACTIOI\\J COMPLETIOI\\J TIME E. As required by Required E.1 Declare HPCS system 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced inoperable.

in Table 3.3.5.2-1.

AI\\JD E.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status The licensee proposed to deleted Condition E and associated Required Actions and Completion Times. The remaining functions and conditions would be renumbered accordingly.

The I\\JRC staff finds that the proposed manual initiation functions and HPCS Vessel Water Level 8 function can be deleted. Table 3.3.5.2-1, Functions 1.d, 2.c, 3.a, and 3.e, as described in TSTF-542 (and Reference 1) are not needed to actuate the LPCI, LPCS, and HPCS subsystem components to mitigate a draining event. As previously stated in Section 3.3 of this SE, the ECCS pumps are high-capacity pumps, with flow rates of thousands of gpm. Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates, but at undesirable flow rates in MODES 4 and 5 draindown events.

Therefore, the NRC staff finds the deletions of these manual initiation functions from proposed CPS TS Table 3.3.5.2-1 and the revision to SR 3.5.2.8 acceptable.

The NRC staff also finds that TS 3.3.5.2, Condition E and associated Required Actions and Completion Times, which are associated with the HPCS Level 8 instrumentation, are no longer needed and, therefore, their deletion is acceptable since the Level 8 function can be intentionally defeated, by procedure, to allow the HPCS injection valve to be opened, if needed to control inventory.

3.6 Staff Evaluation of Proposed Deletion of References to OPDRVs Section 2.2.4 of this SE lists the numerous OPDRVs references proposed for deletion. The proposed changes would replace the existing specifications related to OPDRVs with revised specifications for RPV WIC. For example, the proposed changes would remove:

When associated subsystem(s) are required to be OPERABLE When HPCS is OPERABLE for compliance with LCO 3.5.2, "ECCS - Shutdown" and aligned to the RCIC storage tank while tank water level is not within the limits of SR 3.5.2.2 During operations with a potential for draining the reactor vessel Only one trip system required in MODES 4 and 5 with RHR SDC system integrity maintained OPDRVs MODES 4 and 5 for RHR SDC System suction from the reactor vessel isolation valves when associated isolation instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment and Drywell Isolation Instrumentation,"

Function 5.c Initiation action to suspend operations with a potential for draining the reactor vessel (OPDRVs)

During OPDRV Initiate actions to restore valves(s) to OPERABLE status The term OPDRVs is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions, and SRs and deleting references to OPDRVs throughout the TS.

The existing CPS TSs contain instrumentation requirements related to OPDRVs in four separate TS. The proposed new TS 3.3.5.2 consolidates the instrumentation requirements into a single location to simplify the presentation and to provide requirements consistent with TS 3.5.2. The remaining TSs with OPDRVs requirements are for containment, containment isolation valves, SGT system, control room habitability, temperature control, and electrical sources. Each of these systems' requirements during OPDRVs were proposed for consolidation into the proposed new TS 3.5.2 for RPV WIC, based on the appropriate plant conditions and calculated DRAIN TIME.

The NRC staff has determined that the deletion of OPDRVs references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a simplified alternative set of controls for ensuring water level is maintained above the TAF and, therefore, that these changes are acceptable.

3.7 TS 3.10, Special Operations, and TSTF-484 The current CPS TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operation," allows performance of an inservice leak or hydrostatic test with the average reactor coolant temperature greater than 200 °F, while considering operational conditions to still be in MODE 4, provided that certain secondary containment LCOs are met.

TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" (Reference 12),

revised LCO 3.10.1 to expand its scope to include operations where temperature exceeds 200 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

By Amendment No. 211, dated February 22, 2017, the N RC approved changes to CPS TS LCO 3.10.1 in accordance with TSTF-484 (Reference 13). The NRC staff's SE for this amendment stated, in part, that "two low pressure ECCS injected/spray subsystems are required to be operable in MODE 4 by TS 3.5.2, 'ECCS-Shutdown."' For CPS, the ECCS injection/spray subsystems are defined as three LPCI subsystems, the LPCS system, and the HPCS System.

However, per the proposed new LCO 3.5.2, which would replace the requirements of LCO 3.5.2, for the TSTF-542 LAR, only one ECCS injection/spray subsystem would be required to be operable in MODE 4.

Changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is acceptable because, as stated previously in Section 3.3 of this SE, this level of redundancy is not required, even during application of LCO 3.10.1. When the licensee applies LCO 3.10.1 at the end of a refueling outage, an exceptionally large volume of water is present in the reactor vessel since the vessel is nearly water solid. There is much more water in the reactor vessel than is present during power operation and more than is present during most of an outage.

Small leaks from the reactor coolant system (RCS) would be detected by inspections before a significant loss of inventory occurred. In the event of a large RCS leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. At low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Therefore, the reasoning that operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room remains valid.

As stated previously in Section 3.3 of this SE, with one ECCS injection/spray subsystem and nonsafety-related injection sources, DID will be maintained. The DID measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

After consideration of the reasoning presented in this SE and after additional review of Reference 9, the NRC staff determined that the LCOs 3.3.5.2 and 3.5.2 adopted as part of TSTF-542 are satisfactory and will therefore be acceptable even during application of LCO 3.10.1.

3.8 Technical Conclusion CPS Safety Limit 2.1.1.3 requires that reactor vessel water level shall be greater than the top of active irradiated fuel. Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions. The TS changes evaluated within this SE establish new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during MODES 4 and 5 operations.

The RCS is at a low operating temperature(< 200 °F) and is depressurized during MODES 4 and 5 conditions. An event involving a loss of inventory while in the shutdown condition is judged to not exceed the capacity of one ECCS subsystem. The accidents that are postulated to occur during shutdown conditions, the fuel handling accident (USAA 15.7.4) and radioactive gas waste system leak or failure (USAA 15.7.1 ), do not involve a loss of inventory. The equipment and instrumentation associated with the RPV WIC TS do not provide detection or mitigation related to these design basis accidents.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem along with requirements to maintain a sufficiently long DRAIN TIME that plant operators would have time to diagnose and mitigate an unplanned draining event. The NRC staff has determined that the LCO 3.5.2 and LCO 3.3.5.2 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility, and therefore, meet the LCO requirements of 1 O CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.2 provide remedial actions to be taken in the event the LCO is not satisfied, therefore, meeting the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed Action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The NRC staff evaluated the proposed DRAIN TIME definition, TS 3.5.2, which contains the requirements for RPV WIC, and TS 3.3.5.2, which contains the requirements for instrumentation necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff concludes that the proposed revisions are acceptable because they consolidate and clarify the RPV WIC requirements, which meet 1 O CFR 50.36(c)(2)(ii), Criterion 4, to establish LCOs for structures, systems, or components significant to public health and safety as evidenced by operating experience.

The licensee proposed to delete OPDRVs references from the TS Applicability, Conditions, Required Actions, and Footnotes. The NRC staff has reviewed the proposed changes and determined that the deletion of the OPDRVs references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a clarified and simplified alternative set of controls for ensuring that water level is maintained above the TAF.

The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.2. The NRC staff finds that the proposed TS SRs 3.5.2 are acceptable since they support TS 3.5.2 DRAIN TIME requirements, assure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, ECCS injection/spray subsystems are adequately filled (mitigates effects of gas accumulation or voiding), the subsystems have verified valve positions to support RPV injection, verified pumps provide adequate flow to support DRAIN TIME and RPV injection, verification of automatic isolation, and ECCS injection/spray subsystems can be manually operated to inject via main control room push buttons. The NRC staff finds that the three SRs proposed for TS 3.3.5.2 are sufficient and adequate, because they are essential to ensure that the functions are capable of performing their specified safety functions in support of TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in MODES 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 1 O CFR 50.36(c)(2)(ii) and 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed changes against each of the CPS applicable design requirements listed in Section 2.3 1 of this SE. The NRC staff finds that the proposed changes for MODES 4 and 5 operations, as they relate to the proposed TS changes for the new DRAIN TIME definition and the removal of OPDRVs references, remain consistent with the GDCs in that the CPS design requirements for instrumentation, reactor coolant leakage detection, the RCPB, and reactor coolant makeup are unaffected.

The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. In accordance with the 10 CFR 50.36(a)(1) requirement, the licensee provided TS Bases changes in the license amendment request. The NRC staff has concluded that the TS Bases changes provided describe the basis for the affected TS and follow the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing CPS requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with TSTF-542 and Chapter 16 of the SRP.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment on February 13, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (82 FR 31096, dated July 5, 2017). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

Letter from Exelon Generation Company, LLC, Clinton Power Station, Unit 1, Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," dated May 1, 2017, Agencywide Documents Access and Management System (ADAMS) Accession No. ML17121A517.

2.

Letter from Exelon Generation Company, LLC, Clinton Power Station, Unit 1, Supplement to Clinton Power Station, Unit 1 Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control,"

dated November 15, 2017, ADAMS Accession No. ML17319A297.

3.

Letter from Exelon Generation Company, LLC, Clinton Power Station, Unit 1, Supplement to Clinton Power Station, Unit 1 Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control,"

dated December 20, 2017, ADAMS Accession No. ML17354A180.

4.

Enclosure to Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016, ADAMS Accession No. ML16074A448.

5.

Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (TAC No. MF3487),

dated December 20, 2016, ADAMS Accession No. ML16343B008.

6.

Standard Technical Specifications, General Electric BWR/6 Plants, Revision 4.0, Volume 1, Specifications (NUREG-1434), dated April 2012, ADAMS Accession No. ML12104A195.

7.

Standard Technical Specifications, General Electric BWR/6 Plants, Revision 4.0, Volume 2, Bases (NUREG-1434), dated April 2012, ADAMS Accession No. ML12104A196.

8.

NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 16, "Technical Specifications,"

dated March 2010, ADAMS Accession No. ML100351425.

9.

Clinton Power Station, Unit 1, Updated Safety Analysis Report, Revision 19, Chapter 3, "Design of Structures, Components, Equipment, and Systems," dated October 2017, ADAMS Accession No. ML17305A094.

10.

Letter from Exelon Generation Company, LLC, Clinton Power Station, Unit 1, "License Amendment Request to Clarify RHR Subsystem Operability Requirements during Decay Heat Removal Operations," dated May 4, 2017, ADAMS Accession No. ML17124A121.

11.

Letter from U.S. NRC to Exelon Generation Company, LLC, "Clinton Power Station, Unit No. 1 - Issuance of Amendment Regarding Residual Heat Removal Subsystem Operability Requirements during Decay Heat Removal Operations (CAC No. MF9684; EPID L-2017-LLA-0225)," dated January 22, 2018, ADAMS Accession No. ML17324A354.

12.

TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," dated May 5, 2010, ADAMS Accession No. ML052930102.

13.

Letter from U.S. NRC to Exelon Generation Company, LLC, "Clinton Power Station, Unit No. 1 - Issuance of Amendment Regarding lnservice Leak and Hydrostatic Testing Operations (CAC No. MF7559)," dated February 22, 2017, ADAMS Accession No. ML17027A038.

Principal Contributors: Muhammad Razzaque, NRR/DSS/SRXB Rossnyev Alvarado, NRR/DE/EICB Larry Wheeler, NRR/DSS/STSB Date of issuance: March 22, 2018

AC ADAMS BWR CFR CCP CPS DC DID DG ECCS EGC o F FR GDC gpm HPCS LAR LCO LOCA LPCI LPCS LWR OPDRVs NRC psig PCIV RCIC RCPB RHR RPV RCS RWCU SDC SE SFCP LIST OF ACRONYMS Alternating Current Agencywide Documents Access and Management System Boiling-Water Reactor

[Title 10 of the] Code of Federal Regulations Continuous Containment Purge Clinton Power Station, Unit 1 Direct Current Defense in Depth Diesel Generator Emergency Core Cooling System Exelon Generation Company, LLC degree Fahrenheit Federal Register General Design Criteria gallons per minute High-Pressure Core Spray License Amendment Request Limiting Condition for Operation Loss-Of-Coolant Accident Low-Pressure Coolant Injection Low-Pressure Core Spray Light-water Reactor Operations with Potential for Draining the Reactor Vessel U.S. Nuclear Regulatory Commission pounds per square inch gauge Primary Containment Isolation Valve Reactor Core Isolation Cooling Reactor Coolant Pressure Boundary Residual Heat Removal Reactor Pressure Vessel Reactor Coolant System Reactor Water Cleanup Shutdown Cooling Safety Evaluation Surveillance Frequency Control Program

SGT SR SRP STS TAF TS TSTF USAR WIC Standby Gas Treatment Surveillance Requirement Standard Review Plan Standard Technical Specification top of active fuel Technical Specification Technical Specifications Task Force Updated Safety Analysis Report Water Inventory Control

ML18043A505

via memo OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA N RR/DSS/SRXB/BC*

NAME JRankin SRohrer JWhitman DATE 02/15/2018 2/14/2018 02/05/2018 OFFICE NRR/DE/EICB/BC*

OGC-NLO NRR/DORL/LPL3/BC NAME MWaters JWachutka DWrona DATE 02/05/2018 02/26/2018 03/22/2018

v t e Letter Sequence Approval
CAC:MF9666, Reactor Pressure Vessel Water Inventory Control (Approved, Closed) EPID:L-2017-LLA-0223, Reactor Pressure Vessel Water Inventory Control (Approved, Closed)
Initiation Acceptance Supplement, Supplement Administration Questions 3 October 2017 Answers Results Approval Other:
MONTHYEAR2017-12-20 [Table View]

ML18043A505

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

3.8.2 APPLICABILITY

3.8.5 APPLICABILITY

3.8.8 APPLICABILITY

2.1 REGULATORY EVALUATION

2.2 Proposed TS Changes

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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